Absence of harmful substances RoHS - REACH - GADSL - Conflict metal

Information about RoHS

Absence of harmful substances acc. to RoHS II - directive 2011/65/EU and commission delegated directive (EU) 2015/863 amending annex II to directive 2011/65/EU as well as GefStoffV annex IV - no. 24

The components of the indicated items are free of harmful substances according to the above mentioned directives as well as hazardous material regulation annex IV no. 24 medium of flame protection. This means that for the following substances based on the guidelines as well as on the requirements of SAB Bröckskes GmbH & Co. KG, the following quantity and content limits were specified, below which a declaration can be dropped:

  • lead < 0,1 %
  • mercury < 0,1 %
  • cadmium < 0,01%
  • hexavalent chromium < 0,1 %
  • polybrominated biphenyl (PBB) < 0,1 %
  • polybrominated diphenyl ether (PBDE) < 0,1 %
  • decabromo diphenyl ether (DecaBDE) < 0,1 %
  • di(2-ethylhexyl)phthalate (DEHP) < 0,1 %
  • benzyl butyl phthalate (BBP) < 0,1 %
  • dibutyl phthalate (DBP) < 0,1 %
  • diisobutyl phthalate (DIBP) < 0,1 %
  • pentabrominated diphenyl ether < 0,1 %
  • octabrominated diphenyl ether < 0,1 %

Information about REACH

Regulation (EC no. 1907/2006) for the registration, evaluation, admission and restriction of chemical substances

With the help of this REACH regulation for chemicals it is controlled how and why manufacturers, importing companies, final users and retailers have to examine, assess, declare and register chemical substances. 

SAB Bröckskes GmbH & Co.KG (subsequently called we) as manufacturer of products - electrical cables and products of temperature measuring technique - has got acc. to REACH the role of a postponed user of chemicals, for example polymers. These products are exempted from any registration according to REACH. The registration acc. to REACH is exclusively applicable to materials and compounds. We only put products on the market. 

Substances can be included in our products, as they are possibly ingredients of materials that we use for the manufacturing of our products. The ECHA (European Chemicals Agency) has published the SVHC list (substances of very high concern) that is subject to a current updating (https://echa.europa.eu/de/candidate-list-table). We are in permanent exchange with our suppliers regarding hazardous materials. As soon as a SVHC substance is identified as a component of our products (concentration ≥ 0,1 weight -%), we introduce a process of substitution in order to exchange the concerned material with the help of an equivalent. If this isn´t possible, we have the duty to provide information by declaring the substances for the concerned product. If a product doesn´t contain such SVHC substances, it is not necessary to declare this explicitly.

REACH appendix XVII – materials subject to restrictions  

Materials that are subject to application restrictions acc. to EC prescription 1907/2006 are listed in appendix XVII. These prescriptions are specific and are explicitly defined for certain applications or for putting them on the market. This is valid for materials themselves, in compounds and/or in products.


Information about GADSL

Global Automotive Declarable Substance List

The Global Automotive Declarable Substance List (GADSL) is a list containing possible substances used in automobile parts that stay in the vehicle for its complete life cycle. It is the result of the worldwide and long lasting efforts of representatives in automobile industry to simplify the communication and information exchange regarding the use of certain pure chemical substances in automotive parts. 

The GADSL contains declarable and forbidden materials. Although the GADSL is not legally binding, it is a tool to implement legal measurements for example the recycling of end-of-life vehicles within the European Community acc. to guideline 2000/53/EG. We at S Bröckskes GmbH & Co. KG are in permanent contact with our material suppliers regarding the content. We dispose of the corresponding material declarations from our suppliers if substances of GADSL are contained which are either declarable or forbidden. On request we are always prepared to send you the necessary information as material declaration.


Furthermore, we would like to point out that the analysis of ingredients are not part of our incoming or outgoing goods inspection. Our material declarations are based on our current state and the best of our knowledge and on the available safety data sheets, material declarations as well as explanations of our suppliers.


Declaration for the application of so-called conflict materials

On the 1st January 2021 the EC prescription on conflict materials (EC conflict material prescription (EC 2017/821) came into force as a reaction on the already known Dodd-Frank-Act of the USA. After that EC importers of so called conflict materials - tin, tantalum, Wolfram their ores and gold (3TG) – are subject to due diligence and inspection within the supply chain. They shall restrict financing of violence and human rights violation in conflict and high risk areas. The prescription requires that European importers of 3TG (tin, tantalum, Wolfram ,their ores and gold) dispose of a risk management with regard to raw material procurement that must be controlled by a third party audit.
The rules of this EC conflict material regulation affect directly companies that import 3TG materials into the European Community (upstream industry) and exceed certain quantity limits.
For the further treatment (downstream industry) that means producing industries and importers of final products – there are no binding regulations.
However, the downstream industry is requested to execute voluntary due diligence and inspection.
We dispose of written declarations of our sub-suppliers that the products delivered do not contain so-called conflict metals (especially no tin) which were dug in the Democratic Republic of the Congo or its neighbouring countries.
The above mentioned indications are based on the information of our wire and strand suppliers.


Information about ELV

Prescriptions 2000/53/EC with regard to end of life vehicles (ELV)

This guideline is valid for vehicles and end of life vehicles including their components and materials. Among others the prohibition for heavy metals is mentioned therein. This concerns Lead, Mercury, Cadmium and Hexavalent chromium. There is an overlapping with RoHS guideline (see section RoHS).


Information about POP

POP regulation (EC) 2019/1021 - persistent organic pollutants

POP is the issue of the Stockholm agreement with regard to POP and the POP protocol acc. to the United Nations Economic Commission for Europe (UNECE) Convention on Long-Range Transboundary Air Pollution (CLRTAP). Both international agreements have the overall aim to reduce or finish the production, application and release of these substances. The Stockholm agreement is implemented in Europe by the (EC) prescription 2019/1021 of 20th June 2019 (EC POP regulation). The prescriptions of the POP regulation are applied to substances that are listed in appendix I and II of the regulation. Appendix I contains the list of prohibited substances and appendix the list of
such substances that are subject to restrictions.


Prohibition of PBT materials acc. to TSCA paragraph 6(h)

In January 2021 the US authority for environmental protection (EPA) announced the prohibition of the production, use and distribution of 5 PBP materials (persistent bio-accumulative and toxic substances ) as well as of such materials that contain these substances. The following substances are concerned:

  • Phenol, Isopropylphosphate (3:1) (PIP (3:1)) CAS 68937-41-7 (completely forbidden)
  • Decabromdiphenylethe (DecaBDE) CAS 1163-19-5 (completely forbidden)
  • 2,4,6 Tris(tert-butyl)phenol (2,4,6-TTBP) CAS 732-26 (limit value = 0,3 % of weight proportion)
  • Hexachlorobutadiene (HCBD) CAS 87-68-3 (completely forbidden)
  • Pentachlorothiophenol (PCTP) CAS 133-49-3 (limit value = 1 % of weight proportion)

The mentioned limit values are valid for all homogeneous materials contained in the product.


California Proposition 65

The California „Safe Drinking Water and Toxic Enforcement Act” from 1986 is often simply called „California Proposition 65” or „CP65”.  The main statement of this regulation is: „Nobody is allowed to expose a person knowingly to chemicals that are known as carcinogen or toxic for reproduction without giving this person a clear and appropriate warning in advance.” Approx. 900 materials are concerned that have been listed by the authority OEHHA which are carcinogen and / or may cause birth defects or are somehow toxic for reproduction. CP65 is only valid for consumer products when there is the risk of exposure of any consumer with the listed substances and is related to the state of the product when it is imported to California.


 

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