REACH Optimization

January 23, 2018

Sandra Moran

Advocate
EcoAdvisor Group LLC

LEEDuser Basic Member

January 23, 2018

Project is N America (outside USA). Manufacturer is Europe HQ with global operations; uses European standards for global manufacturing. Materials will be produced in USA/ shipped to project outside of USA. Would they be able to qualify for International Alternative Compliance Path: REACH Optimization? Guidance requested on how manufacturer document?

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Paula Melton

Editorial Director
BuildingGreen, Inc.

LEEDuser Moderator

180 thumbs up

January 26, 2018 - 9:46 am

REACH optimization should be available; the important thing is that the project is outside the U.S. A European manufacturer should be familiar with how to document REACH compliance.

Sandra Moran

Advocate
EcoAdvisor Group LLC

LEEDuser Basic Member

January 26, 2018 - 12:16 pm

Thanks for your reply Paula. Confirming: project is outside USA; but materials will be manufactured in USA and shipped to project outside USA. Since this is first project attempting this credit the manufacturer has concerns about documentation for LEED v4. Do they submit dossier for all substances in finished good or other form/documentation?

Paula Melton

Editorial Director
BuildingGreen, Inc.

LEEDuser Moderator

180 thumbs up

January 26, 2018 - 12:34 pm

They do not have to disclose everything in the product; they must give you documentation of what it does NOT contain. The reference guide calls for:

clear documentation from the supplier that they do not contain any substances on the “Authorization List” (chemicals that can only be used with special authorization) nor on the “Candidate List” (chemicals being considered for the Authorization List)

Sandra Moran

Advocate
EcoAdvisor Group LLC

LEEDuser Basic Member

January 26, 2018 - 12:53 pm

That said, we'd assume that a self-declaration REACH Compliance Certificate or REACH Declaration Letter will meet the needs. Please if you advise if you agree or have identified other language that requires third-party certification.