The Compliance Risk Assessment of EU REACH SVHC in Articles of IC Package by Studies of Analysis Methodology

Companies may have legal obligations resulting from the inclusion of the Candidate List of substances of very high concern (SVHC) in a concentration above 0.1% w/w in an Article, as defined under EU REACH Regulation and Waste Framework Directive (SCIP Database) if they place articles on the EU market. Only a few studies have so far been made on how to determine the contents of the Chemical in Product (CiP). The approach to identifying the risk associated with the SVHC in the IC package is mainly to collect and review large information from the supplier chain or by chemical analysis. This article tries to discuss the current challenges for data collection and identifying risks with chemical substances in the IC package. Based on the chemical test results of 2-benzyl-2-dimethylamino-4’-morpholinobutyrophenone and bisphenol A, it was found that the test results of SVHC could be affected by numerous factors such as tested sample form (e.g., powder or flaky shaped), tested sample curing conditions, and chemical analytical methods. Although chemical analysis provides more accurate information for SVHC, when utilizing chemical analysis for checking legal compliance, we still need to compare and analyze the result of chemical substances analysis with the materials self-declaration provided by suppliers to judge whether the data are reasonable.