REACH & RoHS
The use of hazardous substances in products is subject to ever-stricter international laws and restrictions.
To process your inquiry, we would therefore like to provide you with the following information: the products we deliver to you do not, to the best of our knowledge, contain any substances in concentrations that would prohibit their placing on the market.
The regulations in question meet the following legal requirements, among others:
- 2011/65/EU: RoHS Directive
- 1907/2006/EC: REACH Regulation
- 2006/122/EC: Directive on the restriction of perfluorooctane sulfonates ("PFOS")
- 1005/2009/EC: Regulation on substances that deplete the ozone layer
- ElektroStoffV: Regulation on electrical and electronic equipment substances
RoHS Directive 2011/65/EU of the European Parliament
Directive 2011/65/EU of the European Parliament European Parliament and the Council dated June 8, 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment
Directive 2011/65/EU (RoHS II) restricts the use of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ether (PBDEs) in certain electrical and electronic equipment (EEE). In July 2011, this directive came into force and completely replaced the old Directive 2006/95/EC (RoHS) as of January 3, 2013.
No new substances have been added to the list of prohibited substances in RoHS II. However, the restrictions are no longer limited to the existing substances, but rather a process has been introduced to add additional substances in the future (similar to REACH). LAPP will continue monitoring the process and respond to possible further restrictions on substances.
Regardless of the scope of the RoHS II Directive, all products in LAPP's main catalog comply with Directive 2011/65/EU (RoHS II) on the restriction of the use of certain hazardous substances in electrical and electronic equipment. These products do not contain any of the prohibited substances specified in the RoHS II Directive or the maximum permissible concentrations specified therein, taking into account the exceptions listed in Annex III of the directive.
REACH – Regulation (EC) No. 1907/2006 of the European Parliament
Regulation (EC) No. 1907/2006 of the European Parliament and the Council dated December 18, 2006 on the Registration, Evaluation, Authorization and Restriction of Chemicals
With the REACH Directive, the EU created a harmonized system for the registration, evaluation, authorization and restriction of chemicals – referred to as REACH for short. The purpose of the directive is to ensure a high level of protection for human health and the environment.
REACH came into force on June 1, 2007 and replaced a number of former specifications relating to the material composition of products, as previously governed, for example, by Directive 76/769/EEC on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations. All LAPP products meet the requirements of REACH.
Toxic Substances Control Act (TSCA)
On February 5, 2021, the U.S. Environmental Protection Agency (EPA) published a new rule under Section 6 of the Toxic Substances Control Act (TSCA), according to which 5 PBT substances should be banned in products in the USA at short notice, subject to various exceptions. The list of substances banned for import, processing (manufacturing) and sale in products in the USA as of March 8, 2021 is as follows:
- decabromodiphenyl ether (DecaBDE) (CAS No. 1163–19–5)
- phenol, isopropylated phosphate (3:1) (PIP (3:1)) (CAS No. 68937–41–7), other names: Tris (4-isopropylphenyl) phosphate; CAS: 68937-41-7]
- 2,4,6-Tris(tert-butyl)phenol (2,4,6-TTBP) (CAS No. 732-26-3)
- hexachlorobutadiene (HCBD) (CAS No.87–68–3)
- pentachlorothiophenol (PCTP) (CAS No.133-49-3)
After inspecting the information available to us, we found that 4 of the 5 substances are also part of the GADSL list and are therefore already subject to declaration by automotive suppliers. Further information about the substances, areas of use and their restriction on the US side can be found under TÜV SÜD - USA: EPA bans five PBT chemicals and EPA: Assessing and Managing Chemicals under TSCA.
Due to the current situation and the upcoming US ban, we are currently actively working on checking our products and materials for the presence of the specified substances. However, as this is a short-term legislative adaptation in the USA, we are not in a position to provide a definitive stance here at this time.
As soon as reliable information is available, we will respond to your inquiry accordingly.