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European Directives REACh and RoHS
Our NGK Insulators group is a world leader in the manufacture of beryllium-copper alloys. We actively participate in all environmental studies made on all substances used in our products. Our priority is to comply with all legal regulations in force to ensure the continued existence of our products to our clients.
RoHS Directive stands for ‘Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment (EEE)’. The aims of the RoHS Directive (2002/95/CE) is to regulate the use of certain dangerous substances.
REACH stands for ‘Registration, Evaluation Authorisation and restriction of Chemicals’ which enter into force on 1st June 2007. The main REACH objective is to improve the protection of human health and the environment. Even if our copper-beryllium products are considered as being ‘articles’ under REACH, as one of the main actors of the beryllium industry, NGK Berylco registered beryllium metal in November 2010 (No. 01-2119487146-32-0003). This registration procedure gave us the opportunity to make new scientific studies which concluded that the current beryllium metal classification as carcinogen should be revised.
Candidate List of substances of very high concern SVHC
The European Chemicals Agency (ECHA) regulary publishes updates of the list of substances of very high concern SVHC, potentially subject to authorisation (Annex XIV of the REACH Regulation) or to restriction (Annex XVII). For all products containing any substance from that list, the manufacturer or importer has the obligation to inform the end user of the presence of the substance and of its conditions of use.
All our products comply with the REACH regulation. Only the Berylco 33/25 (CuBe2Pb) free-cutting alloy contains lead, included in the ECHA candidate list on 27 June 2018, i.e. considered as a Substance of Very High Concern (SVHC) under the REACH Regulation.
Beryllium metal is not included in the REACH Candidate SVHC List.
To note that, following an evaluation (RMOA: Risk Management Option Analysis) conducted in Germany, the German Institute for occupational health and safety (BAuA) decided not to include beryllium in the SVHC candidate list. BAuA conclusions have been presented in February 2016 and then published in November 2016.
According to article 33 of the REACH regulation 1907/2006 dated 18th December 2006, we have the obligation to inform our customers about the eventual presence of more than 0.1% w/w of Substances of Very High Concern in our products. We declare the presence of lead in our free-cutting alloy Berylco 33/25, in rods and wires only. The low addition of lead (0.4%) in our Berylco 33/25 alloy is essential and not substituable to provide it an excellent machinability. Please refer to our letter below and/or contact us for further information. We have also at your disposal our Safety Information Sheet.
Information Letter - Compliance REACH, RoHS & ELV
For more information regarding the compliance of our products with the European REACH regulation and the RoHS & ELV directives, please download our environmental information letter below, updated on 15 January 2019 (last ECHA SVHC list). We remain at your disposal for any other information.
All our products are in compliance with REACH Regulation, RoHS and ELV Directives.
Only the Berylco 33/25 alloy contains lead, SVHC since 27 june 2018, at a low level.
All our products comply with European Directives 2011/65/EC (RoHS) and 2002/96/EC (WEEE)
Since 1st July 2006, all EEE, imported or manufactured in the EU, placed on the EU market should comply with the requirements of this directive. RoHS recast in 2001 (2011/65/CE, RoHS 2) does not include any restriction on beryllium and consequently on the use of copper-beryllium as indicated by our ‘RoHS Ready’ logo.
It should be noted that only our Berylco 33/25 alloy contains a low quantity of lead (Pb < 1%), unavailable to provide it an excellent machinability, and that Lead metal is among the 10 substances subject to restriction. The Berylco 33/25 alloy is however compliant with the RoHS Directive according to the 6-c exemption (copper alloys containing lead up to 4% by weight).
The beryllium industry is currently working with the European Institutions and Member States to update the classification of beryllium metal, as well as to demonstrate that beryllium containing alloys are, as many other metals, safe when used correctly. The health risk of beryllium metal is limited to the workplace in case of inhalation of fine particles (dust, mist or fume) which can cause a lungs chronic disease (Chronic Beryllium Disease CBD or Berylliosis). The beryllium industry has developed a Product Stewardship Program for beryllium containing materials ‘Be Responsible’ (Be like Beryllium), based on good practices in the workplace and on an Occupational Exposure Limit. This program is free available on line at www.berylliumsafety.eu. In the ‘resources’ section of the website, simplified guides in the main European languages are available.
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