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European Directives REACH, RoHS and others

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.

Below you will find an overview of the main European Regulations concerning our products: REACH, RoHS and ELV, CMD Directives, Conflict Minerals as well. At the bottom of this page, you can download a letter attesting the compliance of our products. Do not hesitate to contact us for any question.

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.

RoHS Compliance

REACH Compliance

REACH stands for ‘Registration, Evaluation Authorisation and restriction of Chemicals’. It is the main Euroepan Regulation for chemicals which entered 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 in the CLP Regulation (Classification, Labelling & Packaging) 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). For all articles 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 - and will not be - 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 published in November 2016.

> ECHA Beryllium RMOA

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 articles in free-cutting alloy Berylco 33/25, proposed 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.

> ECHA Candidate List

About NGK

Information Letter - Compliance REACH, RoHS & ELV

For more information regarding the compliance of our products with the European regulations (REACH Regulation, RoHS, ELV, CMD Directives, Conflict Metals), please download our environmental information letter below, updated following the last publication of the SVHC list by ECHA on 23 January 2024. We remain at your disposal for any other information.

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. Since its adoption, the RoHS Directive has been revised in 2011 (2011/65/EU, RoHS 2) and in 2015 (2015/863/EU, RoHS 3, entry into force on 22 July 2019) and does not concern beryllium.

The latest assessment (RoHS Pack 15 Report, November 2020) does not recommend to restrict beryllium. Consequently, there is no restriction on the use of copper-beryllium alloys 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). Renewal in February 2022 (RoHS Pack 22 Report).

 All our products comply with the RoHS European Directive 2015/863/EU (RoHS 3).

Good Practices Program ‘Be Responsible’

The beryllium industry has developed a Product Stewardship Program for beryllium-containing materials called ‘Be Responsible’ (Be for Beryllium). This program is based on good practices at the workplace and on the European Occupational Exposure Limit of 0.6 µg/m3 . The detailed program is available for free at www.berylliumsafety.eu. Short website in English: www.berylliumsafety.co.uk. Simplified guidances are available in the main European languages.

Recent epidemiological studies have shown that Beryllium in its metallic form is not carcinogenic. The beryllium industry is currently working with European institutions to update the current classification of beryllium metal in the EU CLP Regulation. As many other metals, Beryllium-containing alloys are safe when used correctly.  

ELV  Compliance

ELV stands for ‘End of Life Vehicles’. The ELV Directive (2000/53/EC) aims to reduce the hazardous substances in the recovery, recycling and transformation of cars wrecks. 4 substances are restricted including lead (Pb).

As stated for the RoHS Directive, our Berylco 33/25 alloy contains lead but at a content of less than 4% and therefore complies with ELV Directive due to the exemption 3 for lead-containing copper alloys. See Directive 2013/28/EU amending annex II to Directive 2000/53/EC.

 All our products comply with the ELV European Directive 2000/53/EC.

CMD Directive

CMD stands for ‘Carcinigen and Mutagen Directive’. The 2004/37/EC Directive concerns the protection of workers from the risks related to exposure to carcinogens or mutagens at work. Beryllium may pose a risk in the workplace in case of inhalation of fine particles by sensitized persons (chronic respiratory disease called Chronic Beryllium Disease CBD or Berylliosis) and has been included as such in the CMD Directive (entry into force on 11 July 2019 of the 2019/983 Directive amending Annex III to Directive 2004/37/EC).

This 2019/983 Directive features a Binding Occupational Exposure Limit (OEL) for beryllium of 0.6 µg/m3 (micrograms per cubic meter of air - inhalable fraction - 8 hours Time Weighted Average), to be followed by 0.2 from 12 July 2026. Member States had 2 years to transpose the Directive at national level, i.e. no later than 11 July 2021. This Directive ensures compliance with an harmonized limit value in all the European Union.

Conflict Minerals

The European Regulation (EU) 2017/821 adopted on 17th May 2017 sets a duty of care on the supply chain for EU importers that import Tantalum, Tin, Tungsten and Gold coming from conflict or high-risk  areas. Its implementation will start on 1st January 2021. This Regulation  is based on OECD rules and on US law (1502 article of the 2010 law “Dodd-Frank Wall Street Reform and Consumer Act”). The overall goal of these regulatory measures is to ensure the responsible supply in the Union of minerals and metals known as “Conflict” or “3TG” (Tantalum, Tin, Tungsten, Gold), particularly from the Democratic Republic of Congo (DRC) and neighboring countries, without contributing to armed conflicts or human rights abuses.

 Copper Beryllium alloys Berylco do not contain 3TG conflict metals (no Tantalum, no Tin, no Tungsten, no Gold).

To note that our copper-nickel-tin alloys GMX contain some Tin, conflict metal.

We have at your disposal our CMRT (Conflict Metals Reporting Template), CRT (Cobalt Reporting Template) and EMRT (Extended Mineral Rporting Template) for all our alloys. Do not hesitate to consult us.