Power Supply REACH Compliance: What You Need to Verify
Power supply REACH compliance involves assessing the applicable substance restrictions and information duties for the adapter being supplied to an EU supply chain. For Candidate List communication under Article 33, the concentration threshold applies to the relevant constituent article, including one incorporated into a larger assembly. An OEM buyer therefore needs supplier information that can be traced to the ordered model, its supplied parts and the list revision assessed.
Begin with the purchase specification. A declaration for a product family leaves an unanswered question if your order uses a different output cable, connector, enclosure resin or detachable mains cord. The supplier needs to explain which configuration the evidence covers before the compliance team can assess it.
Define the scope of your power supply REACH compliance file
Ask for the full orderable model and suffix, then reconcile the declaration with the approved bill of materials. Include accessories supplied with the adapter. A statement that covers the adapter body may leave the detachable cord or optional connector unresolved.
Use a small evidence matrix to make those connections visible:
| Purchase item | Information to request | Question the record should answer |
|---|---|---|
| Adapter model and suffix | Model list, drawing and BOM revision | Does the statement include this configuration? |
| Enclosure, cord and output lead | Controlled part references and supplier material information | Which supplied parts were assessed? |
| Substance statement | Issue date, Candidate List revision and identified substances | What list and product information informed the conclusion? |
| Supporting evidence | Linked declarations, material data and relevant reports | Can the reviewer trace each conclusion to its basis? |
| Exceptions or open items | Affected part, substance and unresolved question | What needs resolution before approval? |
These are recommended purchasing fields. Their purpose is to expose missing coverage, whether the supplier uses one declaration or several linked records. Ask the supplier to distinguish information based on its own materials review from information received from a component vendor.
Where a laboratory report is included, check the sample identification, tested substances, methods, reporting limits and report date. Ask how the sample relates to the supplied construction. A report for an unidentified piece of plastic cannot establish coverage of every cord and housing in a model family.
Keep the RoHS assessment identifiable within the wider file. The European Commission explains that REACH and RoHS have different scopes. The existing RoHS power-supply evidence guide addresses that adjacent purchasing task; a RoHS report alone leaves the REACH questions unresolved.
Apply the threshold to the relevant constituent article
For Article 33, a Candidate List substance above 0.1% by weight triggers the relevant communication duty. In a complex product, that assessment follows the constituent articles that retain their article status. The official ECHA guidance record explains this treatment following the European Court of Justice’s judgment in case C-106/14.
For an adapter review, ask the supplier to identify the affected constituent article and explain the concentration basis. Combining its weight with the entire power supply could obscure an above-threshold finding. The article boundary itself needs assessment; a purchasing BOM line does not automatically define it.
RoHS uses the separate concept of homogeneous materials. Avoid accepting a statement that switches between “whole product,” “component” and “homogeneous material” without explaining which obligation each term addresses. Material-level data can help the reviewer, but the final concentration assessment must use the appropriate denominator.
If the supplier reports an SVHC, request its identity, the affected article and enough supporting information to understand the result. Keep an unresolved boundary visible in the approval file. A percentage with no identified article gives the next person too little information to check the conclusion.
Separate communication, restrictions and notification duties
Several duties can depend on the same substance information. Review each one against the responsible company’s role and the destination market.
Under Article 33, an above-threshold Candidate List substance requires information for the article recipient, including at least the substance name. Consumers have a separate request route; the Commission states that the consumer response period is 45 days. That period should not be used as a B2B delivery grace period.
Annex XVII restrictions require a separate check of the relevant substance, use and conditions. The Commission’s REACH explanation distinguishes restrictions from other REACH processes. A Candidate List finding therefore needs interpretation: it does not, by itself, establish either a universal ban or permission to supply the product.
Article 7(2) notification has its own concentration and annual substance-quantity conditions, together with exemptions. Ireland’s Health and Safety Authority describes the combination of above 0.1% by weight and more than one tonne per year for the relevant producer or importer. Do not carry that tonnage condition into an Article 33 decision.
SCIP reporting derives from waste legislation. Treat its current applicability, responsible operator and submission evidence as a separate review item. The Swedish Chemicals Agency’s SCIP guidance describes its market and supplier scope. A database reference should be checked against the supplied article and the duty it is intended to address.
For a supply chain involving a manufacturer outside the EU, an importer and several distributors, record who will assess each applicable duty and who must provide the supporting information. The factory’s declaration supplies evidence; the approval file should also identify the operator’s resulting decisions.
Keep the approved evidence connected to production orders
Agree on change-notification rules before the first production order. Include changes to enclosure material, cable jacket, connector, cord vendor, component source and BOM revision in the review process. A substitution with the same electrical rating still deserves a materials-evidence check.
Set a review trigger for changes to the relevant Candidate List or restriction scope as well. Record the date, reviewer, affected model and conclusion each time the file is revisited. Choose additional evidence or testing to answer the identified gap, with a documented rationale for the selected substances and samples.
Incoming inspection can compare model markings, supplied accessories, part references and lot traceability with the approved record. It cannot determine chemical composition from appearance. When an unexplained suffix or material-source change appears, hold the evidence decision open until the supplier establishes coverage.
Store this record alongside the broader power adapter qualification test plan, with a named owner for future updates. Keep previous evidence identifiable so a later reviewer can reconstruct which configuration was approved.
For a Merryking sourcing discussion, provide the exact model or proposed configuration, target EU markets, supplied cords and connectors, and the REACH documents your compliance team needs to review. Ask for the applicable evidence and any open coverage questions before approving the production configuration.