Answering compliance requests
A customer asks whether a part contains a substance of very high concern. The question arrives as an email, a spreadsheet or a portal task, and the answer has to be assembled from documents held in several places. Here is what the request looks like, what the regulation obliges a supplier to pass on, what a typical answer contains, and how Pareo answers it end to end.
How the request arrives
There is no standard inbox for this. The requester picks the channel and the template, so the same question reaches you in four or five shapes.
- Email. Free text about one part or a list of them, usually with a deadline in the subject line and the real question two paragraphs in.
- Excel. The customer's own questionnaire, one row per part number, one column per regulation, and a tab of instructions.
- A portal notification. A task in the customer's supplier portal that has to be answered in their fields, in their wording.
- A form. A PDF form, or an IPC-1752A declaration to be completed and returned as a file.
What REACH Article 33 obliges a supplier to communicate
The anchor is Article 33 of REACH, Regulation (EC) No 1907/2006. Where an article contains a substance from the Candidate List above 0.1 % by weight, the supplier of that article has to communicate that to recipients down the supply chain, and to consumers on request.
The Candidate List is maintained by ECHA and updated about twice a year, so a part can become reportable without anything about the part changing.
Where the threshold is crossed, further duties can follow: notification to ECHA under Article 7(2), and a SCIP notification, which has applied since 5 January 2021 to articles placed on the EU market.
EUR-Lex: REACH Art. 7 and 33 ↗ECHA Candidate List ↗Knowledge base: SCIP ↗
What a typical answer contains
Wording differs by customer. The same elements recur.
- Identification. The part number as the customer wrote it, and the part number as you hold it.
- The rule set and its version. Which list, which revision, and the date the statement was made against it.
- The finding. Whether a listed substance is present above the threshold and, where it is, which substance, at what concentration, and in which part of the article.
- Exemptions relied on. For RoHS, the named exemption, where one is claimed.
- The evidence. The supplier declaration or test report the statement rests on, and the person who released it.
Knowledge base: material declaration ↗Knowledge base: SVHC ↗
Why doing this by hand is slow
No single step is hard. There are simply many of them, and they repeat per part, per customer and per revision of the list.
- Find the request. In a shared mailbox, among everything else that landed that morning.
- Resolve the part. The customer's number, your number and the supplier's number are three different strings for one part.
- Find the evidence. The newest supplier declaration, which may be a PDF, an email attachment or a portal download.
- Check it is still current. Against the Candidate List as it stands today, not as it stood when the declaration was written.
- Re-type it. Into the customer's template, in the customer's wording, and then file a copy of what was sent.
How Pareo answers it end to end
- Intake. Requests are collected from the mailbox, the portal or the file drop, in whatever format they arrived.
- Understanding. Agents extract the parts, the rule sets and the required response format from the request itself, including the ones buried in an attachment.
- Grounding. Every question is answered from your own product data and supplier documents. Questions that cannot be resolved are flagged rather than guessed.
- Draft and review. The response is drafted in the customer's format. Nothing leaves before a person releases it.
- Trail. The sent answer keeps a field-level record of which document each figure came from, so the same question a year later is a lookup.
The reference behind these statements
Every regulatory statement on this page traces to the Pareo knowledge base and to the official source it cites.
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Note: general educational information, not legal advice. Check the official source before relying on it.
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