Introduction
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)
The ECHA (European Chemicals Agency) enforces regulations such as REACH (EC 1907/2006), which has been in effect in the EEA (European Economic Area) since 1st June 2007. REACH is a European Union regulation that aims to protect people and the environment from the risks posed by potentially harmful chemicals. REACH applies to all suppliers who manufacture or sell into the EU.
Please read more: ECHA homepage.
Explanations
What is the REACH regulation, and what is an SVHC?
Source: UK REACH substances of very high concern (SVHCs) - HSE
“SVHCs are substances that have hazards with serious consequences. For example, they cause cancer, or they have other hazardous properties and/or remain in the environment for a long time, with their amounts in animals gradually building up.”
In accordance with Article 57 of UK REACH, substances with the following properties may be identified as SVHCs:
- Substances meeting the criteria for classification as carcinogenic, mutagenic or toxic for reproduction (CMR) category 1A or 1B in accordance with the GB CLP regulation.
- Substances which are persistent, bio-accumulative and toxic (PBT) in accordance with the criteria in Annex 13 of UK REACH.
- Substances which are very persistent and very bio-accumulative (vPvB) in accordance with the criteria in Annex 13 of UK REACH.
- Substances giving rise to an equivalent level of concern to substances meeting the above criteria. Such substances may have endocrine-disrupting properties or have properties that, although not meeting the criteria for being a CMR, PBT or vPvB, have scientific evidence of probable serious effects to human health or the environment. Such substances will be identified on a case-by-case basis.
Substances meeting these criteria may be added to one or both of these lists:
Niftylift’s reporting obligations
Manufacturers, assemblers, distributors and importers of substances have a general obligation to submit a registration to the ECHA (European Chemicals Agency) for each substance manufactured or imported in quantities of 1 tonne or more per year per company.
Niftylift also has a duty to inform our customers of all our products that contain greater than 0.1% SVHC, to help ensure the safe use of related parts.
Based on current assessments and supplier information, our machines and parts comply with applicable REACH requirements. We remain committed to ongoing compliance, transparency, and continuous monitoring of regulatory developments to minimise risk to customers and downstream users.
We are currently working with our supply partners to establish a full list of all products containing greater than 0.1% SVHC and operate a risk-based approach to REACH compliance by:
- Requesting REACH and SVHC declarations from suppliers.
- Monitoring updates to the Candidate List and assessing potential impacts on supplied products.
- Updating customer communications where regulatory status changes.
In general, we do not manufacture or import chemical substances as such, or in mixtures, and based on information received from our supply chain and current assessments, we do not intentionally add SVHCs to our products.
Our reporting obligations primarily relate to the presence of Substances of Very High Concern (SVHCs) in articles, as listed on the ECHA Candidate List.
Where we find that an SVHC is present in an article at a concentration greater than 0.1% w/w, we intend to provide sufficient information to allow safe use of the article, including the name of the SVHC, in accordance with Article 33 of REACH.
Potential REACH-related risks in reporting
While we maintain robust controls, the following potential risks are recognised:
- Supply chain dependency: Reliance on supplier declarations means that inaccurate or incomplete information could impact compliance.
- Regulatory change risk: The Candidate List is updated regularly, and newly listed SVHCs may affect previously compliant components.
- Legacy components: Older or long-life components may contain substances that become restricted over time.
- Customer use and modification: Changes to intended use, or modification of supplied machines or parts, may alter REACH obligations.
Typically, articles at risk of containing more than 0.1% SVHC are not widely accessible on finished machines. However, from time to time, it may be necessary to replace or service parts containing more than 0.1% SVHC.
It is highly recommended that correct PPE (Personal Protective Equipment) is always used when performing such service or maintenance activity, and that guidance from Service Manuals is always observed.
Our approach
The Code of Conduct and Trade Compliance are included in Niftylift’s Supplier Partnership Manual.
Code of Conduct
Niftylift Ltd is a privately owned UK company dedicated to the design, development, manufacture, and service of state-of-the-art Mobile Elevating Work Platforms, supplied into a global marketplace. Niftylift Ltd recognises its responsibility to ensure that our supply chain adheres to all applicable laws governing the welfare and sustainability of people and the environment. Our values and principles are incorporated into this code, and suppliers are required to comply with these to provide us with products or services.
Legal compliance
Suppliers must comply with all applicable laws and legal regulations within the countries in which they operate.
Trade compliance
Niftylift requires suppliers to support trade compliance efforts by providing accurate information and declarations as requested. This includes, but is not limited to, REACH, PFAS, CBAM and HS classification/Country of Origin. Maintaining compliance is essential to ensure product safety, legal adherence, and ethical sourcing. Niftylift will engage the supply chain to collect information on various global trade regulations and requirements as they arise.
Third-party support
To streamline compliance processes, Niftylift may engage third-party companies to assist in collecting, verifying, and managing supplier-submitted information. Suppliers are expected to cooperate fully with these third-party partners to provide requested data promptly.
Non-compliance or exceptions
If a supplier is unable to provide the requested declarations or does not plan to do so, an official notification must be submitted stating the reason for non-compliance. This ensures transparency and allows for risk assessment and mitigation.
These measures help protect our supply chain, ensure legal compliance, and maintain trust with customers and regulatory authorities.