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European Union REACH Regulation - Questions and Answers


Note: This Question & Answer (Q&A) document provides information regarding Boeing's response to the European Union's (EU) REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation. The REACH regulation is complex -- this Q&A document is not intended to instruct customers, suppliers or other third-parties whether or not REACH applies to them or what their specific compliance obligations, if any, may be. Customers, suppliers, and/or other third-parties are advised to seek appropriate legal or business counsel to determine REACH applicability, scope and compliance obligations, if any. No warranty is made or given regarding the accuracy, completeness or suitability of the information contained herein, and neither Boeing nor its subsidiaries, affiliates, joint ventures, officers, directors, agents or employees shall be liable for any reliance on this Q&A document by any Boeing customer or supplier or by any other third-party under any theory of law.

Nothing herein should be construed as a commitment or agreement to perform or refrain from any action or undertaking on behalf of any customer, supplier or third party. This Q&A document does not modify or amend any past, present or future contract or other agreement with any Boeing customers or suppliers nor does it or shall it create any contractual relationship with any third party.

REACH Overview | General Regulatory Questions | REACH and Boeing | Supplier Questions | Customer Questions | Contact Information


Q1: What is REACH?
A: REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a comprehensive regulation for tracking, testing, and reporting on chemicals used in the European Union (EU). (See Q2 for more details on where REACH applies.) This rule applies to EU entities, including Boeing's EU suppliers and EU customers that import, use, or manufacture chemical substances in the EU. REACH has a broad impact on the chemical industry and impacts chemical materials and products used for aerospace applications.

The major regulatory requirements of REACH relevant to Boeing are shown below. Compliance with the REACH regulation may require Boeing's EU suppliers, processors and customers to coordinate with their respective supply chains.

  • Registration of substances
    Subject to certain thresholds, EU entities who manufacture or import substances on their own or in mixtures and EU entities who produce or import articles (e.g., aircraft, aircraft parts and components) that contain substances intended for release (greater than one metric ton per year) must register those substances with the European Chemicals Agency (ECHA). More details on Registration here, including the list of registered substances.
  • Notification of substances in articles
    EU producers or importers of articles must notify ECHA if the articles contain a Substance of Very High Concern (SVHC) in concentrations greater than 0.1% of the article weight, and if the SVHC in those articles is greater than one metric ton per year - unless there is no exposure of the SVHC to humans or the environment during normal or reasonably foreseeable conditions of use or the substance is registered for that use. Notifications for SVHCs are due six months after inclusion of those substances on ECHA's candidate SVHC list. (The list of candidate SVHCs is linked here.)
  • Communication of safe-use information
    EU entities who produce, import, or distribute articles containing SVHCs above certain concentrations must provide users with sufficient information to allow safe use of the article. At a minimum, this requires identification of SVHCs in the article. ECHA's candidate SVHC list is linked here.
  • Authorisation to use SVHCs listed in Annex XIV
    EU entities must apply for Authorisation to place on the market for use or to use themselves any SVHC listed in Annex XIV of REACH. Many conditions must be satisfied for Authorisation to be granted for continued (though temporary) use of an Annex XIV listed substance beyond the substance's "sunset date". Authorisations for continued use are time-limited with a typical review period between four and seven years. The Annex XIV Authorisation List of substances is linked here.
  • Restrictions listed in Annex XVII
    Restricted substances (on their own, in a mixture or in an article) are substances for which manufacture, placing on the market or use is limited or banned in the European Union (if the specified condition for restriction is met). The Annex XVII List of Restrictions is linked here.
REACH guidance documents on the ECHA website are linked here.
REACH questions and answers on the ECHA website are linked here.
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Q2: Where does REACH apply?
A: REACH applies in all Member States of the European Union, plus Iceland, Liechtenstein and Norway -- collectively known as the European Economic Area (EEA).

Q3: Who is responsible for compliance?
A: EU entities are responsible for being in compliance. EU member state authorities are responsible for enforcing compliance.

Q4: Are other countries expected to impose similar requirements? Or more strict requirements?
A: The United Kingdom (UK), no longer a part of the EU, has its own, nearly identical, REACH regulation. UK REACH is linked here. The European Union has candidate countries and potential candidates as well. These countries include Albania, Montenegro, North Macedonia, Serbia, Turkey, Bosnia and Herzegovina, and Kosovo. Once a country is accepted into the European Union, they will also need to adopt REACH.

In addition to EU REACH, various chemical tracking, testing, reporting and chemical management regulations and systems are in development globally.

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Q5: What is Boeing's strategy for complying with REACH?
A: REACH compliance requirements apply to European Union entities. Boeing entities located within the EU are subject to these compliance requirements, but it is believed there will be significantly more impact to Boeing's EU suppliers and customers. Accordingly, Boeing is working on several initiatives to avoid supply chain disruptions and provide support to customers. These initiatives include development of risk mitigation plans for Annex XIV and Annex XVII substances used in EU production and maintenance operations, and continued research and development of environmentally-preferred materials and processes.

Q6: Can military products be 'exempted' from REACH requirements?
A: Individual member states may grant substance-specific exemptions for national security reasons. Information on Member State policies relative to defense exemptions is linked here.

Q7: Which Substances of Very High Concern (SVHCs) are in Boeing products?
A: Boeing is aware of certain SVHCs in commercial aircraft and defense products (and in specification and maintenance materials). For specific information regarding a particular part or product, customers may inquire to Boeing for further information.

Q8: Doesn't Boeing have a "duty to communicate information on substances in articles"?
A: REACH compliance requirements apply to European Union entities. Boeing's EU suppliers and customers may need to provide safe-use information for articles (e.g., aircraft, spare parts) containing SVHCs to users or consumers of those articles. Where applicable, Boeing is prepared to support suppliers and customers by providing material, process, and product information (refer to Q7 and Q23).

Q9: Will Boeing eliminate all the chemicals on the candidate SVHC list from its products?
A: The candidate SVHC list does not require elimination of chemical substances from any products. ECHA will gather data on the chemicals' use, health and environmental impacts, and availability/feasibility of alternatives before determining if candidate SVHC list chemicals should be subjected to Authorisation or restriction. If specific chemicals used on Boeing products become subject to Authorisation or restriction, Boeing will continue to work with its suppliers and customers as appropriate to identify and support options that suppliers and customers may pursue (e.g., implementation of substitute materials and processes, Authorisation for continued use, etc.).

Q10: Which SVHCs will be placed on Annex XIV and will Boeing seek Authorisation for their continued use?
A: SVHCs placed on Annex XIV are linked here. Boeing will continue to work with its suppliers and customers to determine potential impacts and, if technically feasible and appropriate, identify alternatives for use in the EU. If alternatives are not available, Boeing will support applications for Authorisation (see Q18) to allow the continued use (where needed) of those substances.

Q11: How is the aerospace industry responding to REACH?
A: Aerospace industry associations in the US and EU are actively involved in REACH compliance and advocacy. The AIA (Aerospace Industries Association) Chemicals Subcommittee is responsible for coordinating REACH activities in the US aerospace industry. Other working groups at AIA address specific aspects of REACH, such as engineering and supply chain. AIA also works closely with the AeroSpace and Defence (ASD) Industries Association of Europe (linked here). ASD and its national aerospace associations have cooperated to create REACH dedicated working groups to assist the aerospace industry in preparing for and implementing the REACH requirements.

Boeing is a participant in the trade association International Aerospace Environmental Group (IAEG) a non-profit organization of global aerospace companies created to collaborate on and share innovative environmental solutions for the industry. REACH is addressed in many IAEG efforts, including Workgroup 1 Materials and Substances Declarations (which includes maintenance of the Aerospace and Defense Declarable Substances List), Workgroup 2 Replacement Technologies, and Workgroup 5 REACH Authorisation.

Q12: What is an Only Representative, and will Boeing be designating one?
A: Certain foreign entities can appoint a natural or legal person established in the European Economic Area (EEA) (an Only Representative) to fulfill the obligations on importers under REACH. Boeing does not plan to designate an Only Representative (OR).

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Q13: What is Boeing telling its suppliers?
A: Boeing communicates with suppliers to remind them of their contractual obligation to comply with laws, their need to inform Boeing Procurement Agents of potential chemical reformulations, and to convey requirements for understanding and declaring the chemical composition of supplied materials and parts. Targeted requests for data are sent to suppliers and qualified processors directly from Boeing, through Assent (see Q15), or through consultants working IAEG industry efforts. Boeing also works individually with suppliers to implement environmentally-preferred materials and processes.

Q14: How many Boeing suppliers are or may be affected by REACH?
A: Boeing has several hundred European suppliers and processors who are subject to REACH requirements. The full extent of the impact to those suppliers (and their supply chains) largely depends on the extent to which aerospace-critical substances are restricted in the EU. Boeing's non-EU suppliers will also be impacted by REACH as EU Customer importing and reporting requirements change, and as production materials become obsolete.

Q15: Will suppliers be required to declare the chemical composition of materials, parts, or assemblies supplied to Boeing?
A: Boeing is implementing requirements for suppliers to provide chemical profile declarations, upon request. Boeing is using the IPC-1754 Material Declaration for Aerospace and Defence standard and the Aerospace and Defence Declarable Substances List (AD-DSL) as part of an approach that minimizes supply chain business disruptions by promoting the efficient exchange of chemical profile data that are necessary for compliance and production continuity. Boeing is working with Assent, Inc. as our business process and data exchange technology partner to gather chemical substance declaration data from suppliers. Boeing suppliers may be contacted directly by Assent with educational resources and an onboarding guide on how to provide the necessary data. Boeing suppliers may verify the legitimacy of these requests by contacting their Boeing procurement agents and copying BoeingREACH@exchange.boeing.com. More details on the IPC-1754 standard and related tools for chemical declarations can be seen on the International Aerospace Environmental Group (IAEG®) website here, which includes a useful introductory video.

Q16: Will Boeing suppliers be required to eliminate SVHCs in supplier materials, parts, and assemblies?
A: REACH does not require the elimination of SVHCs in articles, unless those SVHCs are listed in Annex XVII, and the conditions of the restriction apply to the supplied materials and parts. However, SVHCs that are listed on the Annex XIV Authorisation List, linked here, are restricted from use in the EU on their listed sunset dates. Boeing continues to analyze the impact of Annex XIV listed substances (refer to Q10) and is prepared to provide technical support on applications for Authorisation to allow the continued use (where needed) of Annex XIV listed substances.

Q17: Should Boeing suppliers remove Annex XIV restricted substances from supplied materials, parts, and assemblies?
A: Suppliers need to continue working to contract requirements, including process and material specifications, drawings, and other requirements specified in existing contracts. As contractually required, suppliers of specification materials shall notify their Boeing Procurement Agent if they plan to reformulate materials to eliminate Annex XIV listed substances (or any other substances). Requalification of materials can be a costly and time-consuming process. Likewise, component and assembly suppliers may be required to notify their Procurement Agent if parts, equipment, and assemblies are constructed from new materials. Flammability, performance and certification requirements may need to be verified. Suppliers in the EU must also comply with all applicable regulatory requirements which may include REACH downstream user requirements.

Q18: Will Boeing apply for Authorisation to allow suppliers to continue using substances listed on Annex XIV?

A: In certain cases where Annex XIV substances are used to manufacture Boeing hardware, and there are no qualified alternatives, Boeing is participating in consortia and industry groups that are developing technical dossiers that can be used by aerospace suppliers and customers to apply for Authorisation. Filing an application for Authorisation is then the responsibility of the EU manufacturer, importer, or user of Annex XIV listed substances. Examples of such consortia and industry groups include the Chromium Compounds for Surface Treatment (CCST) consortium, the Chromium Trioxide Authorisation Committee (CTAC) consortium, and the Global Chromates Consortium for Aerospace (GCCA). Efforts to obtain Re-authorisation to continue using chromates (where necessary) beyond the expiration of existing Authorisations are being coordinated by the Aerospace & Defence Chromate Re-authorisation (ADCR) consortium . More details on Renewal and New applications submitted by ADCR can be seen (here).

Boeing's EU suppliers and processors who use chemical formulations containing Annex XIV listed substances are encouraged to contact their upstream supply chain (e.g., chemical manufacturers, formulators, distributors) to ensure that formulations containing Annex XIV restricted substances will be authorized and available for their specific required uses. (Refer to Q22 for more details on specific applications for Authorisation, including those filed by Boeing Distribution Germany GmbH (formerly BDI/Aviall Services Inc.), a Boeing subsidiary that distributes aircraft parts and supplies, including chemicals in the EU.) Suppliers are also encouraged to contact Boeing for coordination or assistance.

Q18.1: What is the status of Authorisation for chromates?
A: Many applications for Authorisation were filed in attempts to allow continued, specific uses of chromates beyond the original sunset dates of September 21, 2017 (metal finishing) and January 22, 2019 (primers). Those applications were approved with a review period of seven years. Those Authorisations are set to expire on September 21, 2024 and January 22, 2026. Efforts have been taken to obtain Reauthorisation for the continued use of chromates (where needed) beyond those dates (see discussion of ADCR above and below).

  • Chromium trioxide. The CTAC Consortium developed applications for Authorisation for several uses of chromium trioxide (primarily for surface treatment). Applications were submitted and approved for several uses of chromium trioxide, with a review period of seven years, expiring September 21, 2024. Details on the applications and their status, as well as a Q&A from the consortium, Good Practice Sheets, and Key Functionalities Notification Templates can be seen on the Jones Day website here. Note: On April 20, 2023 the Court of Justice of the European Union annulled the Authorisation decision, details here. The effects of Authorisation are to remain in place for one year, allowing the relevant continued uses of chromium trioxide until April 20, 2024 (previously September 21, 2024). Meanwhile, ADCR has submitted applications for Reauthorisation for the uses of chromium trioxide (where necessary) in certain Aerospace processes (see below) . It is expected that if a new decision has not been made on the original CTAC application for Authorisation by April 20, 2024, then downstream users can benefit from “transitional arrangements” that allow the continued use of chromium trioxide until a new decision has been made, or until decisions are made on the ADCR applications. See more details in Question 4 of the European Commission Q&A on REACH and chromium (VI) substances (here).
  • Other chromates used in Aerospace surface treatment processes. The Chromium Compounds for Surface Treatment (CCST) Consortium developed applications for Authorisation for several other Annex XIV listed chromates, primarily for aerospace uses (including surface treatment, application of coatings, and other uses). Applications were submitted and approved.
  • Chromates used in additional Aerospace processes. The Global Chromates Consortium for Aerospace (GCCA) was formed to facilitate the Authorisation of several additional Aerospace uses of chromates. Applications were submitted and approved.

Prior to the March 21, 2023 deadline, the (ADCR) consortium submitted the last of its Review Reports in both the EU and UK to obtain Reauthorisation for five hex chrome compounds in relevant metal finishing operations. ADCR also submitted new Applications for Authorisation to to cover the shifting needs of the Aerospace supply chain. These Review Reports and new applications support the original Authorisations (CTAC, CCST, GCCA – see above) and are requesting additional time for using chromates beyond September 21, 2024 where substitutes remain unavailable for implementation.Decisions on those applications are expected around that date; the official status of all applications for Authorisation can be checked in the table of "Adopted opinions and previous consultations on applications for Authorisation" on the ECHA website here.

Q18.2: What do companies need to do to utilize chromate Authorisations?
A: Conditions of Authorisation need to be met, including:

  • Companies using formulations containing Annex XIV chromates will need to procure those formulations from an EU entity that holds or is covered by a valid Authorisation for relevant uses of the formulation. Companies will not be able to import formulations containing impacted chromates unless they hold a valid Authorisation or procure the formulation from a foreign manufacturer who has appointed an OR who holds a valid Authorisation.
  • Companies will need to inform the European Chemicals Agency in the EU (via REACHIT) and the Health and Safety Executive (HSE) in the UK (via email) that they are making use of the Authorisation to continue using the Annex XIV substances that have been sunset.
  • Operating Conditions (OCs) and Risk Management Measures (RMMs) will need to be implemented/documented/followed. As examples, this could include facilities changes (e.g., controlling access to areas where the substances are used), and the use of prescribed personal protective equipment. RMMs and OCs can be found on the ECHA website for each Authorisation application. Guidance can typically be found on consortia website.
  • Annual employee exposure testing and bio-monitoring is required, and acceptable exposures may need to be reduced to "as low a level as technically and practically possible". Similarly, releases to the environment (wastewater and air) must be measured and improved. Employee exposure and environmental monitoring data may need to be provided to ECHA and HSE using the same methods described above .

Q19: How are Boeing's sub-tier "D1-4426" approved processors impacted by REACH?
A: Qualified processors in the EU are subject to the REACH regulation and may be impacted as importers, downstream users, and/or manufacturers. Many critical chemical processing substances (e.g., chromates) are listed or proposed to be listed on Annex XIV. Unless authorized, those substances will be banned from use in the EU on their listed sunset dates. Boeing's EU chemical processors who use chemical mixtures containing Annex XIV listed substances are encouraged to consider implementing qualified substitute chemicals where possible. Processors may otherwise need to ensure that their use of Annex XIV listed substances will be authorized (refer to Q18) and that the chemicals containing those substances will remain available on the market. Boeing's approved processors are encouraged to contact Boeing or their material suppliers with questions or concerns.

Q20: I process parts according to Boeing specifications. Are there chromate-free metal finishing operations I can or need to switch to? What about Boric Sulfuric Acid Anodizing?
A: Metal finishing processors need to continue working to the drawings and process/material specifications associated with the Boeing hardware being processed. If unsure whether specification materials contain chromates, processors are encouraged to contact Boeing or their material suppliers for more information. In cases where Annex XIV listed chromates are being used, processors are encouraged to contact Boeing (or their direct customers for the Boeing hardware) to determine if alternative qualified materials and processes (without chromates and/or other Annex XIV substances) are available for specific hardware. If not available, processors are encouraged to determine if Authorisation is being obtained for continued use of formulations containing Annex XIV substances (refer to Q18).

Boeing has alternative processes, such as boric sulfuric acid anodizing, which are qualified for specific applications. Please contact Boeing for more details to determine if there is Engineering coverage to implement these alternative processes. Furthermore, Boeing continues to research and test additional alternative materials and processes for chromic acid anodizing, and for other metal finishing processes.

Q21: Boeing is a supplier to our company -- who do we contact for REACH inquiries?
A: Boeing has several sites around the world that supply parts to other companies. If your company buys parts from a Boeing site, and you need to inquire about the composition of those parts and/or the REACH-readiness of that site, please direct those inquiries to the appropriate Boeing contact.

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Q22: What is Boeing doing to support its customers
A: Boeing has defined a strategy to comply with REACH (refer to Q5) and is actively involved in REACH industry working groups (refer to Q11).

In certain cases where Annex XIV substances are used to maintain and repair Boeing hardware, and there are no qualified alternatives, Boeing has participated in consortia and industry groups that developed technical dossiers. Boeing's subsidiary Boeing Distribution Germany GmbH (formerly Boeing Distribution Inc. (BDI)/Aviall Services Inc.), through its facility in Germany, holds several upstream Authorisations that can be utilized by Boeing suppliers and customers who may choose to procure chemical formulations through Boeing Distribution Germany GmbH (refer to Q18).

Boeing Distribution Germany GmbH (formerly Boeing Distribution Inc. (BDI)/Aviall Services Inc.), has applied for and been granted the upstream chromate Authorisation uses listed below.

  • Chromium trioxide (chromic acid). Approved uses (see Q18.1 for details on applicable dates):
    • Formulation of mixtures
    • Functional chrome plating (non-decorative)
    • Surface treatment for applications in the aeronautics and aerospace industries
    • Surface treatment (except passivation of tin-plated steel (ETP)) for applications in various industry sectors namely architectural, automotive, metal manufacturing and finishing, and general engineering
  • Strontium chromate. Approved uses:
    • Formulation of mixtures – Expires January 22, 2026
    • Application of paints, primers, and specialty coatings in the construction of aerospace and aeronautical parts, including maintenance of such constructions, as well as for such aerospace and aeronautical parts used elsewhere, where the supply chain and exposure scenarios are identical - Expires January 22, 2026
  • Pentazinc chromate octahydroxide. Approved uses:
    • Formulation of mixtures – Expires January 22, 2026
    • Wash primer, fuel tank primer and aluminized primer for the purpose of corrosion protection in aeronautic applications - Expires January 22, 2026
  • Sodium chromate. Approved uses:
    • Formulation of Mixtures for sealing after anodizing, chemical conversion coating, pickling and etching applications by aerospace companies and their suppliers - Expires September 21, 2024
    • Use for sealing after anodizing, chemical conversion coating, pickling and etching applications by aerospace companies and their suppliers - Expires September 21, 2024
  • Potassium hydroxyoctaoxodizincatedichromate. Approved uses:
    • Formulation of Mixtures - Expires January 22, 2026
    • Use in paints, in primer, sealants, and coatings (including as wash primers) - Expires January 22, 2026

Applications filed by other entities for upstream chromate Authorisation uses include (but are not limited to):

  • Dichromium tris(chromate). Approved uses:
    • Formulation of mixtures
    • Surface treatment of metals
  • Sodium dichromate. Approved uses:
    • Formulation of mixtures
    • Surface treatment of metals
  • Potassium dichromate. Approved uses:
    • Formulation of mixtures
    • Surface treatment of metals

The official status of all applications for Authorisation for the continued use of chromates and other Annex XIV substances can be checked in the table of "Adopted opinions and previous consultations on applications for Authorisation" on the ECHA website.

Q23: What is Boeing doing to support its customers on communication requirements?
A: Boeing's EU customers may need to provide safe-use information for articles (e.g., spare parts) containing SVHCs to users or consumers of those articles. Where applicable, Boeing is prepared to help customers comply with these communication requirements by identifying SVHC content in parts and products and providing safe-use information. For more information on Boeing designed parts for commercial aircraft, visit the Boeing PART Page which may be accessed through MyBoeingFleet (The Boeing Part Page -> Support -> Help / Info Desk -> Other Topics -> REACH).

Q24: Will Boeing need to report the SVHC content of delivered products to customers?
A: If requested, Boeing will provide reasonably available information. Boeing operations that are EU entities will comply with all applicable REACH obligations.

Q25: How is Boeing helping customers who need to use maintenance materials that contain substances that require Authorisation?
A: Boeing provides an assessment of maintenance consumable materials that may contain Substances of Very High Concern (SVHC) included in Annex XIV of REACH through Fleet Team Digest (FTD) articles which may be accessed through MyBoeingFleet. In certain cases where Annex XIV substances are used to maintain and repair Boeing hardware, and there are no qualified alternatives, Boeing is supporting the development of applications for Authorisations for continued use past the sunset date (refer to Q22).

Q26: If asked by customers, will Boeing provide information about the composition of Buyer Furnished Equipment (BFE)? What about Customer variations?
A: Boeing will focus on providing composition data for delivered products and work with our customers to support their compliance needs as necessary.

Q27: What could happen if Boeing customers in the EU fail to comply with REACH requirements that may apply to Boeing articles they import?
A: Failure to comply with the applicable REACH requirements (e.g., Notification, Communication, etc.) could lead to civil and/or criminal enforcement action by EU member state authorities against the parties responsible for meeting those requirements.

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Q28: Who do I go to for additional REACH information?
A: For general REACH questions:BoeingREACH@exchange.boeing.com

Supply chain issues:paul.r.hogben@boeing.com

BCA customer airline and Boeing Global Services (BGS) issues:robert.s.beauchamp@boeing.com

BDS technical and other REACH issues:john.d.patterson4@boeing.com

Boeing Distribution Germany GmbH (formerly BDI/Aviall Services Inc.), distribution and sales of chemicals (including formulations containing authorized substances within the EEA): REACHBDI@boeing.com

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