Compliance with the REACH Regulation
- Global/Ricoh Group
Under the REACH Regulation1, a European regulatory framework on chemical substances, producers and importers of substances, preparations and articles (i.e., products, parts, etc. that are given shape during the manufacturing processes, such as the main units of equipment, electronic parts, paper, and packaging materials) produced in, or imported into, the EU are required to register and give notice of all chemical substances included in their products whose quantity is above certain threshold levels. The producers and importers are also required to fulfill their duties to communicate information regarding designated substances contained in products2 to customers and general consumers. It is anticipated that the number of chemical substances subject to this regulation will eventually exceed 1,500. The Ricoh Group established the REACH Compliance Working Group with 180 attendees from the production division (including the general sales division) in February 2008 to solidify Ricoh’s REACH compliance system. The core mission of the working group is to develop a system that will allow us to collect and manage chemical substance information accurately and efficiently from partners both upstream and downstream in the supply chain, including manufacturers of materials, chemicals, and parts, as well as Ricoh Group production facilities, and to provide the information to customers upon their request.
As one of the founders of the Joint Article Management Promotion consortium (JAMP), Ricoh worked to develop an information communication system on chemical substances for the consortium’s use. Based on the JAMP system, the Ricoh Group formulated common rules regarding and developed a database for the communication of chemical substance information in fiscal 2008. We then held explanation meetings for some 1,200 Japanese, Chinese, and Korean suppliers. In fiscal 2009, the system started operation, allowing us to take stock of existing and potential issues and improve the level of our efforts in this area. To ensure the accuracy and completeness of our information collection on chemical substances, we have conducted training sessions targeting employees in procurement and quality management divisions and others, and approximately 120 employees have been certified as“leaders” of our chemical substance information management efforts. We have also developed and provided to our suppliers easyto-understand manuals and guidance materials explaining how to access the information on chemicals contained in Ricoh products using JAMP tools. From October 2009, the information on SVHC in products for the European market has been made available on our website3. The Ricoh Group is fully able to comply with REACH requirements and is ready to respond promptly to future development of the regulations.
- 1This is a new EU regulatory framework for the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH). It requires the registration and management of all chemical substances used in businesses in accordance with their conditions of use to ensure safe assessment of chemical substances. It came into force on June 1, 2007, and the regulations have been gradually enforced since June 1, 2008.
- 2Called “Substances of Very High Concern (SVHC),” these are substances on the European Chemicals Agency’s candidate list for eventual inclusion in Annex XIV.
- 3On the Health & Safety Information page of Ricoh Europe’s website, see REACH FAQs, Q3 “SVHC – Machines”
The relationship among substance groups whose use for equipment is either prohibited, restricted, or controlled by the Ricoh Group and substance groups regulated by the European RoHS Directive
Enhancing collaboration with JAMP, aiming to contribute to the realization of a society in which the impact of chemical substances on the environment is minimized
- Global/Ricoh Group
In accordance with the REACH Regulation, effective in 2007, under which registration of applicable chemical substances started in 2008, all manufacturers exporting products to Europe now need to get ready for full compliance. Since this regulation is being applied across the entire supply chain, manufacturers of materials, chemicals, and parts in the upstream and middle-stream must provide information on chemical substances used by them to each client they deal with. To ensure this information is communicated and disclosed efficiently and smoothly, it was recognized in the industry that there was a need to develop common rules, formats, and a database that can be shared by all manufacturers.
Based on this recognition of the need to develop and disseminate a common industry-wide communication system to share information on chemical substances contained in articles1to enhance the competitiveness of the industry, the Joint Article Management Promotion-consortium (JAMP) was established in September 2006. Under the leadership of 17 promoter companies, including manufacturers of electrical machinery, chemicals, and precision machinery, JAMP is said to be the world’s first industrywide organization of its kind. One of the major missions of JAMP is to create the Material Safety Data Sheet plus (MSDSplus) and the Article Information Sheet (AIS)2, which are basic sheets used for the communication of information on chemical substances contained in products. JAMP has developed JAMP-IT, an information network system that enables manufacturers to register their chemical substances information on the JAMP server and share it among members. Launched in June 2009, this system eliminates the need for individual manufacturers to develop their own communication systems, and enables them to meet the requirements of the REACH Regulations efficiently. The joint consortium signed a memorandum for cooperation in the field of chemical substances management with a Korean government agency in December 2009, and Thai and Malaysian government agencies in March 2010. This move is expected to promote global use of the JAMP system and help supply chains to meet global standards appropriately.
Ricoh, agreeing with the purpose of JAMP, joined the consortium as a promoter company. Ricoh has played an important role in JAMP since its inception as a member of both the Project Planning & Implementation Committee and the Internationalization Planning & Implementation Committee, aiming to support the administrative work for the operation of the organization and to improve the international harmonization of the system. In December 2009, the Ricoh Group announced that it may use JAMP-GP as a group communication infrastructure, in combination with RaVender- Net (Networking for Venders and Ricoh), the Group’s information communication network for suppliers. In October 2010, the Group began to disclose the MSDSplus and AIS chemicals list for its main products through JAMP-IT. We plan to add chemical information of other products to the list, thereby continuing to update the list. Through these measures and activities, Ricoh will continue working to contribute to the realization of a society in which the impact of chemical substances on the environment is minimized.
- 1Defined as “objects that have a shape and whose size is measurable,” including manufactured goods and components designed to have specific forms. More specifically, “articles” refers to equipment and devices, electronics parts, paper products and packaging materials.
- 2The basic communication sheets recommended by JAMP to provide information on chemical substances contained in products.
Communication system developed by JAMP to communicate information on chemical substances contained in articles
AIS (Article Information Sheet)
AIS is a communication sheet that JAMP standardized for providing information on chemical substances contained in articles. JAMP recommends using the sheet to deliver to downstream manufacturers data related to articles, including mass, material, and part (in which part of the article the chemical substance is used). Data on regulated substances should also be included if contained in articles, including content level, name, content amount and concentration.
The downstream manufacturers receive MSDS or MSDSplus, which are also JAMP communication sheets, from upstream manufacturers that include information on chemical substances involved in their processes. The downstream manufacturers process the obtained data, reflecting changes in substances causedby their manufacturing process, and convey the revised data using an AIS to the manufacturers further down the stream. An AIS for an article built up of multiple components can be prepared by integrating all every AIS for each component. The purpose of the AIS is to convey information on regulated substances that might remain in finished articles above the permissible level, along the entire supply chain from upstream to downstream. This is a key tool—combined with MSDSplus and component AIS, which can be integrated into one for an article consisting of multiple components—to complete the chemical substance information communication system proposed by JAMP for extended usage across industries and business types.