SVHC-substances in manufactures – REACH

The latest update of the SVHC Candidate List dated 16-01-2020 does not mention additional substances contained in our product, meaning that the below-mentioned declaration of 15-01-2019 is still valid.

On June 27, 2018, lead was taken up into the SVHC candidate list („Substances of Very High Concern”). Substances that are classified as SVHC and are subject to admission are listed in annex XIV of the REACH-regulation.

Lead is included as an alloying element in certain articles from our product range. We inform the affected customers in accordance with the information obligations under Article 33 of the REACH Regulation.

We herewith inform you that articles from our product range, which possess more than 0,1%  lead, contain following as SVHC identified materials:

Material CAS/EINECS List Starting date Remarks
Lead (Pb) CAS: 7439-92-1
EINECS: 231-100-4
Candidate list/SVHC 27.06.2018 The recording of load as  SVHC on the candidate list puts an obligation to provide information in the delivery chain into action.

Unchanged stays the legal classification of dangerous materials with regard to the rules for safe contact with lead, just as the user spectrum of our products with lead as components of alloys.

Products from Copper and Copper alloys do not belong to the range of application of the regulation (EG) No. 1272/2008 of the European Parliament and the Board of classification, indication and packaging of materials and mixtures (CLP-regulation) and do not belong to the classification- and indication obligation.

The question as to whether additional restrictions will come into force for applications of leaded brass alloys during the course of the REACH process, for instance authorizations for certain uses, requires extensive consultations and probably cannot be answered before 2020. There are good arguments against the necessity of authorizations – one argument being that the risks when dealing with leaded materials are controlled. In the event that lead nevertheless becomes subject to authorization, there will be a transition period until 2024. Authorizations for certain uses would have to be applied for 18 months prior to the end of the transition period at the latest. It is to be expected that relevant authorizations will be issued by the Chemicals Agency, particularly in view of the fact that substituting leaded machining brasses is not yet feasible according to the state f the art. Leaded brass alloys will thus not lose their out standing significance in future.

For further information about the realization of the REACH-regulation in our company, please contact Mr. Paul Stoffers.