Waste Electrical and Electronic Equipment Regulations 2013
Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012, Directive (EU) 2015/863 of 31 March 2015 (also known as “RoHS 3”).
These directives implement environmental legislation which seeks, via the RoHS, to reduce the quantity of hazardous material in electrical and electronic products and, via the WEEE Directive, to promote more environmentally friendly design and greater recycling of material in similar products.
The EU Government have added four additional substances in the RoHS 3 directive (2015/863), the additional four substances shall be applied by 22 July 2019 except where exemptions permit.
RoHS specifies maximum levels for the following 10 restricted substances. The first six applied to the original RoHS while the last four were added under RoHS3:
- Lead (Pb): < 1000 ppm
- Mercury (Hg): < 1000 ppm
- Cadmium (Cd): < 100 ppm
- Hexavalent Chromium: (Cr VI) < 1000 ppm
- Polybrominated Biphenyls (PBB): < 1000 ppm
- Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm
- Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
- Benzyl butyl phthalate (BBP): < 1000 ppm
- Dibutyl phthalate (DBP): < 1000 ppm
- Diisobutyl phthalate (DIBP): < 1000 ppm
The Company as Stockholder and Distributor does not manufacture anything, and does not have visibility of where the final customer will use the procured product.
Where required by its customers, The Company may carryout out surface finishing, such as polishing (grit belts / silicon belts) or cutting it to length. These surface finishes do not affect the structure of the metals. These critical substances are not added during the surface finishing processes and are consequently only present as technically unavoidable trace impurities in concentrations well below the specified limits.
The Company has determined that it has no compliance obligations under RoHS which deals with heavy metals in electrical equipment.
As part of its due diligence, The Company has contacted its current supplier base to verify their continued compliance with the regulations.
The only exception to compliance is where a grade of material is ordered by a customer where the British, European or International Standard covering the grade requires a deliberate addition of one or more of the substances in order to comply with the standard/grade requirements. In this case, the material will contain a value of each substance in line with the standard requirements.
The situation will be reviewed annually and this statement up-dated accordingly.