REACH SVHC New - Webinar

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info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044

REACH
December 2012’s New SVHCs
Assent Compliance
Krystal Noseworthy-Baker
Regulatory Manager – Key Accounts
613.882.1429
krystal.baker@assentcompliance.com

C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]

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Agenda

• Assent Compliance Corporate Overview
• Brief recap of REACH and SVHCs
• Requirements for SVHCs
• Communication
• Notification
• Authorization

• Latest Additions to the SVHC Candidate List
• Industries affected by the Dec 2012 SVHCs

• Registry of Intentions and Authorization List
• What are they and where can I find them?
• Update

• Assent Compliance Services
• Q&A

C u s t o m s o l u t i o n s f o r c o m p l i a n c y [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]

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About Assent
Assent Compliance delivers SaaS Environmental Compliance Services to
companies who must comply with local, national and global environmental
regulations. Assent also supports its software division with a team of highly
experienced industry consultants to provide our clients with turnkey
compliance solutions. Industry experts at Tier 1 companies rank Assent
Compliance amongst the top environmental compliance solutions in the
world and one of the only global solution providers to offer a full service
solution from end to end.

Our Mission
Is to help our clients comply with environmental regulations in the
most efficient and cost effective manner possible. This is achieved
through SaaS automation of processes and working with clients
to build efficient internal compliance programs that meet global
compliance requirements.


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How The Assent Compliance
Management System Works
Integrates with
Pulls Bill of Material (BOM) Communicates with Supply
Major ERP/PLM
into a centralized compliance Chain in bi-directional fashion
Systems
data base or operates as a to procure environmental
stand-alone system. information from suppliers

Modules to Comply with
All Major Environmental Build IPC 1752-A FORMS.
Regulations Import/Export via XML

Built-in CRM for compliance
Homogenize proprietary
tasks, due diligence reporting
supplier DOC formats in xml
and audit trails

Allows internal Staff to Acts as a repository for any
Make Engineering Override compliance related material
assessments


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Consulting Services
 Compliance Assessment Services For Environmental Regulations

 Internal Standard Operating Procedure Consulting

 Compliance Plan Development

 Compliance Strategy Consulting

 Conflict Mineral Compliance

 IT System Integration


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our offices
Munich, Germany
london, UK

Ottawa, Ontario Can-
ada (HQ)

Taipei,
Taiwan

Bangalore, India
New York,
New York

Kenya
(Conflict Minerals)


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 How do SVHCs get added
to the Candidate List?
Review of the Authorisation Process – Annex 15 Dossiers:
1. Registry of intentions – Intention to submit dossier
• 18 Registered: 5 since 2008, 3 since 2011, 10 from 2012
• 13 dossiers (2011 and 2012 substances) expected to be submitted in February 2013

2. Submission of Annex XV dossier (SVHC Dossier) to ECHA for Compliance Check
3. Publication of Annex XV dossier (once it has passed compliance check)
• No Current Consultations
4. After Commenting periods – Candidate List (Article 33 Requirements kick in)
• 54 Added December 19th 2012
5. Prioritisation list – Order in which substances will be reviewed for Authorisation
6. Authorisation List – Restrictions and Authorisations handed out
• Currently 14 substances on list


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 Requirements
What do new SVHCs mean for your company?
Companies will need to assess whether they have legal obligations resulting from the inclusion of
the new substances in the Candidate List.
The legal obligations related to SVHCs include Communication and Notification.

Communication
Any producers or importers of articles placed on the market1 in the EU must declare the presence
of any of these substances in an article in a concentration exceeding 0.1% w/w.


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Article 33 – Source of compliance requirement:
Duty to communicate information on substances in articles:
1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identi-
fied in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w)
shall provide the recipient of the article with sufficient information, available to the supplier,
to allow safe use of the article including, as a minimum, the name of that substance.
2. On request by a consumer any supplier of an article containing a substance meeting the cri-
teria in Article 57 and identified in accordance with Article 59(1) in a concentration above
0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, avail-
able to the supplier, to allow safe use of the article including, as a minimum, the name of that
substance.
The relevant information shall be provided, free of charge, within 45 days of receipt of the request.

1
Article 3.12 of the REACH Regulation specifies:
• Placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall
be deemed to be placing on the market;


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 Requirements
• What does this mean?
• Once a substance has been added to the SVHC List, you must declare its presence to your
downstream users if the concentration is above 0.1% of your products weight.
• This is to be done upon immediately for professional customers and within 45 days from request
for consumers.


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 Requirements (Continued)
Notification
Furthermore, these same producers and importers have six months from the date the new SVHCs
were included (18 June 2012) to notify the ECHA if
(a) The (SVHC) is present in those articles in quantities totalling over 1 tonne per producer or
importer per year
(and)
(b) The (SVHC) is present in those articles above a concentration of 0,1 % weight by weight (w/w)

• A notification is created using the same software as a REACH registration – IUCLID.
• It is a much less intense dossier than a registration dossier.
• To facilitate the task of notification, ECHA has made available pre-filled substance datasets,
which can be downloaded from the Candidate List webpage.
• These datasets contain:
»» The identity (substance name, EC and/or CAS number)
»» The classification and labelling of the substance.


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• The following information must be entered by the notifier:
»» identity and contact details,
»» registration number (if available),
»» the tonnage range of the substance,
»» a brief description of the uses of the substance in the article itself and the uses of
the article.

• REACH-IT is the submission tool that must be used.


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 Requirements (Continued)
Authorisation
Any chemicals placed on the Candidate List can also eventually be approved for an authorization
list where they will then be banned from use unless an authorization is submitted and approved
before the applicable sunset date.
• Most, if not all, substances on the current SVHC List will eventually move onto the Authorisation
list and therefore require an Authorisation for their use.

• Authorisations are required on a per substance, per use, per supply chain (you or an actor up your
supply chain must have been granted an authorisation) basis.


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SVHC Candidate List
December 19th, 2012
• 54 Added, Total is 138 SVHCs
• Largest Group ever added to the SVHC Candidate List

Substance name EC Number CAS Number

Bis(pentabromophenyl) ether (DecaBDE) 214-604-9 1163-19-5

Pentacosafluorotridecanoic acid 276-745-2 72629-94-8

Tricosafluorododecanoic acid 206-203-2 307-55-1

Henicosafluoroundecanoic acid 218-165-4 2058-94-8

Heptacosafluorotetradecanoic acid 206-803-4 376-06-7


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None Given in Candidate

4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylated - List, Research Provided:
None Given in
covering well-defined substances and UVCB substances, polymers and Candidate List, 2497-59-8

homologues Research Provided: 2315-67-5

Annex XV Dossier - 4-TERT-OCTYLPHENOL ETHOXYLATES 219-682-8 2315-61-9

9002-93-1

None Given in
None Given in Candidate
Candidate List,
List, Research Provided:
Research Provided:
4-Nonylphenol, branched and linear - nonylphenol CAS:
nonylphenol EC:
substances with a linear and/or branched alkyl chain with a carbon number 25154-52-3
246-672-0
of 9 covalently bound in position 4 to phenol, covering also UVCB- and Phenol, 4-nonyl- CAS:
Phenol, 4-nonyl-
well-defined substances which include any of the individual isomers or a 84852-15-3
EC: 284-325-5
combination thereof ethoxylates CAS:
ethoxylates EC:
9016-45-9, 68412-54-4,
500-024-6, 500-209-
127087-87-0
1, 500-315-8


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Diazene-1,2-dicarboxamide (C,C'-azodi(formamide)) 204-650-8 123-77-3

Cyclohexane-1,2-dicarboxylic anhydride (Hexahydrophthalic anhy-
201-604-9 85-42-7
dride - HHPA)

Hexahydromethylphathalic anhydride, Hexahydro-4-
247-094-1, 243-072-0, 25550-51-0, 19438-60-9,
methylphathalic anhydride, Hexahydro-1-methylphathalic anhy-
256-356-4, 260-566-1 48122-14-1, 57110-29-9
dride, Hexahydro-3-methylphathalic anhydride

Methoxy acetic acid 210-894-6 625-45-6

1,2-Benzenedicarboxylic acid, dipentylester, branched and linear 284-032-2 84777-06-0

Diisopentylphthalate (DIPP) 210-088-4 605-50-5

N-pentyl-isopentylphtalate — 776297-69-9


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1,2-Diethoxyethane 211-076-1 629-14-1

N,N-dimethylformamide; dimethyl formamide 200-679-5 68-12-2

Dibutyltin dichloride (DBT) 211-670-0 683-18-1

Acetic acid, lead salt, basic 257-175-3 51404-69-4

Basic lead carbonate (trilead bis(carbonate)dihydroxide) 215-290-6 1319-46-6

Lead oxide sulfate (basic lead sulfate) 234-853-7 12036-76-9

[Phthalato(2-)]dioxotrilead (dibasic lead phthalate) 273-688-5 69011-06-9


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Dioxobis(stearato)trilead 235-702-8 12578-12-0

Fatty acids, C16-18, lead salts 292-966-7 91031-62-8

Lead bis(tetrafluoroborate) 237-486-0 13814-96-5

Lead cyanamidate 244-073-9 20837-86-9


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Lead dinitrate 233-245-9 10099-74-8

Lead oxide (lead monoxide) 215-267-0 1317-36-8

Lead tetroxide (orange lead) 215-235-6 1314-41-6

Lead titanium trioxide 235-038-9 12060-00-3

Lead Titanium Zirconium Oxide 235-727-4 12626-81-2

Pentalead tetraoxide sulphate 235-067-7 12065-90-6

Pyrochlore, antimony lead yellow 232-382-1 8012-00-8


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Silicic acid, barium salt, lead-doped 272-271-5 68784-75-8

Silicic acid, lead salt 234-363-3 11120-22-2

Sulfurous acid, lead salt, dibasic 263-467-1 62229-08-7

Tetraethyllead 201-075-4 78-00-2

Tetralead trioxide sulphate 235-380-9 12202-17-4

Trilead dioxide phosphonate 235-252-2 12141-20-7

Furan 203-727-3 110-00-9


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Propylene oxide; 1,2-epoxypropane; methyloxirane 200-879-2 75-56-9

Diethyl sulphate 200-589-6 64-67-5

Dimethyl sulphate 201-058-1 77-78-1

3-ethyl-2-methyl-2-(3-methylbutyl)-1,3-oxazolidine 421-150-7 143860-04-2

Dinoseb 201-861-7 88-85-7

4,4'-methylenedi-o-toluidine 212-658-8 838-88-0

4,4'-oxydianiline and its salts 202-977-0 101-80-4


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4-Aminoazobenzene; 4-Phenylazoaniline 200-453-6 60-09-3

4-methyl-m-phenylenediamine (2,4-toluene-diamine) 202-453-1 95-80-7

6-methoxy-m-toluidine (p-cresidine) 204-419-1 120-71-8

Biphenyl-4-ylamine 202-177-1 92-67-1

o-aminoazotoluene 202-591-2 97-56-3

o-Toluidine; 2-Aminotoluene 202-429-0 95-53-4

N-methylacetamide 201-182-6 79-16-3

1-bromopropane; n-propyl bromide 203-445-0 106-94-5


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Industries Affected
Most Common Uses for the December 2012 SVHCs
• Because this most recent revision of the SVHC Candidate List was so large, there is a slight
change to the format normally used for the new SVHC presentations

√√All the uses of every newly-added substance will not be covered
√√Focus on major groupings and the more popular substances
√√Highlight some substance uses that may not be touched on in other major groupings
√√Summary of the most affected industries/most common uses at the end of this section
√√A full worksheet of all 54 new SVHCs and uses will be available on the Assent website –
webinars page – along with this slide deck.


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Industries Affected (Continued)
INTERMEDIATES
hh 4-Aminoazobenzene; 4-Phenylazoaniline
• Pigments Production

hh Chemicals, Polymers (reactant in synthesis)
• Diethyl sulphate
• Dimethyl sulphate

hh o-Toluidine; 2-Aminotoluene
• synthesis under strictly controlled conditions, Laboratory reagent

hh 4-methyl-m-phenylenediamine (2,4-toluene-diamine)
• Chemical Synthesis, Production of sulfur dyes

hh 4,4’-oxydianiline and its salts
• Monomer in imported polymer


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hh 1-bromopropane; n-propyl bromide
• Surface cleaning, surface degreasing: General manufacturing, e.g. machinery, equip-
ment, vehicles, other transport equipment. Metal surface treatment products, includ-
ing galvanic and electroplating products.
• Manufacture of substance
• Manufacture of a solvent mixture for industrial/professional cleaning purposes
• Use as an industrial solvent for vapour degreasing - washing and cleaning products

hh 6-methoxy-m-toluidine (p-cresidine)
• strictly controlled intermediate consumed in a chemical synthesis
• raw material for manufacturing of pigments

hh 4,4’-methylenedi-o-toluidine

Industries:
• Multi-Industry Impact!
»» Polymers and pigments
• Cleaning Industry
• Manufacturing


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Bis(pentabromophenyl) ether (DecaBDE)
hh DecaBDE is a general purpose flame retardant which is compatible with a wide variety of plas-
tics/polymers and textiles. This versatility has resulted in a range of end uses, leading to a com-
plex life cycle for this substance.
• Polyolefins - polypropylene (PP), polyethylene (PE), polypropylene ether (PPE) and eth-
ylene vinyl acetate (EVA) polymers.
»» power cables, conduits, stadium seating, electrical connectors, electrical boxes,
wire and cable insulation, heat shrinkable material, shipping pallets and roofing
membranes.
»» DecaBDE may also be used in polyethylene wood composites used in construction.

• Styrenics
»» high-impact polystyrene (HIPS), acrylonitrile butadiene styrene (ABS) and poly-
phenylene oxide/polystyrene blends (PPO/PS).
»» NOTE: RoHS restricts the use of decaBDE for end uses of these polymers in consumer
electrical and electronic goods.


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Industries Affected
Bis(pentabromophenyl) ether (DecaBDE) CONTINUED
• Engineering thermoplastics:
• polyesters - polybutylene terephthalate
»»examples include circuit breakers, sockets and electrical connectors and polyethylene tere-
phthalate (PET)
• polyamides – nylon
»»used for injection moulding applications in transport e.g. wheel covers and handles, chair
and seat belt mechanisms, under hood applications
• polycarbonate (PC)
»»used to make window housings in trains and aircraft and automotive components such as
headlamps and bumpers - and polycarbonate blends (PC/ABS)
• polyimides
»»bearings in aircraft, seals and gaskets
• melamine
»»textile finishing applications


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• Thermosets
»»unsaturated polyester resins (UPS)
• used to make a variety of articles for construction including modular building
parts, roofing materials, porch canopies and decorative mouldings
• epoxy resins
»»these have applications in electronics, construction and aerospace.
»»Elastomers
»»ethylene propylene diene monomer (EPDM) rubber
»»automotive radiator hoses and seals, roofing membranes, cable and wire
insulation
»»styrene-butadiene rubber (SBR)
»»thermoplastic polyurethanes (TPUs)
• automotive and wire and cable applications
• ethylene vinyl acetate (EVA) elastomers
»» often used for wire and cable insulation.
»» Waterborne emulsions and coatings
»» acrylic emulsions, polyvinyl chloride emulsions, ethylene vinyl chlo-
ride emulsions and urethane emulsions.
»» These are used for coating, impregnation and saturation of fibrous
materials such as paper, nonwovens (e.g. felt) and woven textiles.


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Cyclic Acid Anhydrides
Hexahydromethylphathalic anhydride, Hexahydro-4-methylphathalic anhydride,
Hexahydro-1-methylphathalic anhydride, Hexahydro-3-methylphathalic anhydride

Cyclohexane-1,2-dicarboxylic anhydride (Hexahydrophthalic anhydride - HHPA)

hh Cyclic acid anhydrides are widely used in the chemical industry, especially in the manufacture
of polyester and alkyd resins and plasticizers for thermoplastic polymers.

hh The anhydrides are also used as hardeners for epoxy resins and chain cross-linkers for thermo-
plastic polymers. For HHPA specific the following uses are identified: Manufacture of alkyd
resins, plasticizers, insect repellents, rust inhibitors and as hardener in epoxy resins.

hh The following uses are identified in the registration dossiers: industrial use as hardener for
epoxy resins, industrial use as intermediate in chemical synthesis or process and industrial use
as monomer in the manufacture of resins.

hh Multi-Industry Impact!
• Polymers and Resins used in a variety of industries.


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Most Common Uses for the June 2012 SVHCs
Tricosafluorododecanoic acid
Heptacosafluorotetradecanoic acid
Henicosafluoroundecanoic acid
Pentacosafluorotridecanoic acid
hh Included below is a table of known C8-PFCA alternatives. It is assumed that some substitutes
for C8-PFCA might also be usable for C11-14-PFCAs.

Alternative
Product name company Used for /Used in
compound
Paint and coatings industry. Electronic coating,
PFBS or based on different
Novec® 3M industrial and commercial cleaning, cleaner for
C4- perfluorocompounds
solder flux residue, degreasing applications
Dodecafluoro- 2-methylpentan-
Novec® 3M Fire-fighting fluid
3-one(CF3-CF2- C(O)-CF(CF3)2)

C6-fluorocompounds Forafac® DuPont Fire-fighting foam

Surfactant and flow, level and wetting addi-
CF3 or C2F5 pendant fluoroalkyl OMNOVA Solutions
PolyFox® tive for coating formulations. Also used in floor
polyethers Inc.
polish
Propylated aromatics (naphtha- Rütgers Kurehe Water repelling agents for rust protection sys-
Ruetasolv®
lenes or biphenyls) Solvents GmbH tems, marine paints, coatings, etc.
Aliphatic alcohols (sulphosucci-
Emulphor®, Lutensit® BASF Levelling and wetting agents
nate and fatty Alcohol ethoxylates)


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CONTINUED
Tricosafluorododecanoic acid
Heptacosafluorotetradecanoic acid
Henicosafluoroundecanoic acid
Pentacosafluorotridecanoic acid

Alternative
Product name company Used for /Used in
compound
Paint and coatings industry: Wetting agents for
Sulfosuccinates EDAPLA N® LA45 Münzing Chemie
water based applications, e.g. wood primers
Paint and coating industry: Weting and dispers-
Sulfosuccinate Hydropalat ®875 Cognis
ing agents
Silicone
WorléeAdd® Welrée-Chemie Wetting agents in paint and ink industry
Polymers

Branched fluoroethers Can be applied for all products

Short-chain fluorinated Commercially available in home furnishings, fire
Technologies (six or less Capstone DuPont fighting foam, fluorosurfactants, paper packag-
carbons) ing, textiles, stone and tile, and leather end uses
Emulsifier used in the aqueous emulsion
Ammonium
ADONA 3M polymerization of fluoropolymers made from
4,8-dioxa-Hperfluorononanoate
Tetrafluoroethylene (TFE)


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N,N-dimethylformamide; dimethyl formamide (DMF)
hh The use of DMF in electronics, mainly in the manufacture of printed circuit boards, is a large market in Asia.
hh Also widely used as a reagent and catalyst for syntheses in organic chemistry.
hh Pharmaceutical industry
hh Petrochemical industry.
hh DMF can also be used as a cleaning solvent in the leather or artificial leather industry, and more generally in
the textile industry, and in the manufacturing of electrical allocation equipment and circuitry metal industry.
hh As a solvent used in synthesis, DMF is not supposed to be a component of the final product although some
traces may still remain.
• Consequently, DMF in articles for example from the textile or plastic industry cannot entirely be excluded.

hh Only the uses as solvent in the production of chemicals, cleaning solvent, intermediate for the synthesis of
other substances, formulation in industrial settings, or as a laboratory chemical are intended in the EU accord-
ing to information from registrations in ECHA’s dissemination database.
hh Other uses of DMF should therefore not exist anymore in the EU. The theoretically obsolete uses include any
professional uses in non-industrial settings except laboratories exceeding 0.5% in preparations (e.g. in paints,
adhesives, coatings, pesticides), and in particular any uses by the general public.
• Moreover, no article containing DMF is assumed to be produced in the EU. The presence of small
amounts of DMF in some articles cannot be completely ruled out.


AS SENTCOM PLIANCE

Propylene oxide; 1,2-epoxypropane; methyloxirane
hh Intermediate
hh Polymer production
• The substance is a monomer in polymer which is manufactured outside of the EU. The
polymer is imported into the EU, and the neat substance is not available outside of the
polymer form.
hh Manufacture of bulk, large scale chemicals (including petroleum products)
hh Amine based curing agent product:
hh Manufacture of plastics products, including compounding and conversion
hh Water and oil Repellents
hh Cellulose modifier = Intermediate
hh Laboratory use - Reagent, Processing aid in open system


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hh Consumer Use - Coatings, Lubricants, Fuel, Agrochemical, Cleaning Agents, Functional Fluids,
De-icing and anti-icing applications, water treatment chemicals:
• Adhesives, sealants
• Anti-freeze and de-icing products
• Coatings and paints, thinners, paint removes
• Fillers, putties, plasters, modelling clay
• Finger paints
• Lubricants, greases, release products
• Polishes and wax blends
• Fuels
• Fertilisers, plant protection products
• Air care products
• Washing and cleaning products (including solvent based products)
• Heat transfer fluids
• Hydraulic fluids
• Perfumes, fragrances
• Cosmetics, personal care products
• Water softeners
• Water treatment chemicals


AS SENTCOM PLIANCE

Dinoseb
hh Polymers - formulation step, manufacture
hh Plastic products

N-pentyl-isopentylphthalate, 1,2-Benzenedicarboxylic acid,
dipentylester, branched and linear
hh Phthalates = Plasticizers


AS SENTCOM PLIANCE

Lead Oxides
Lead tetroxide (orange lead), Lead oxide (lead monoxide)
hh Manufacture of plastics products, including compounding and conversion
hh Industrial Use
hh Professional use of adsorbents
hh Manufacture of computer, electronic and optical products, electrical equipment
hh General manufacturing, e.g. machinery, equipment, vehicles, other transport equipment
hh Metal articles
hh Electrical batteries and accumulators
hh Lead crystal glass
hh Manufacture of other non-metallic mineral products, e.g. plasters, cement
• Stone, plaster, cement, glass and ceramic articles
hh Production of ceramic ware


AS SENTCOM PLIANCE

hh Rubber Articles
hh Explosive manufacture
hh Intermediate
hh Catalyst Manufacturing, Catalyst Use
hh Repair of television sets, computer monitors and other devices containing cathode ray tubes
hh Professional use of paints and pigments
hh Consumer use of paints and pigments
hh Professional use of lead monoxide as laboratory reagents and in chemical analysis


AS SENTCOM PLIANCE

Lead dinitrate
hh Industrial Use:
• Coatings and paints, thinners, paint removers
• Finger paints
• Intermediate
• Laboratory chemicals
• Manufacture of computer, electronic and optical products, electrical equipment
hh Manufacturing of explosives
hh Manufacture of weapons and ammunition
hh Production of pigment
hh SCC Use (Strictly Controlled Conditions)
hh Intermediate


AS SENTCOM PLIANCE

Lead Compounds involved in PVC Processing
and Battery production
Lead oxide sulfate (basic lead sulphate); Pentalead tetraoxide sulphate; Trilead dioxide phosphonate;
Tetralead trioxide sulphate; Dioxobis(stearato)trilead; Sulfurous acid, lead salt, dibasic; Fatty acids,
C16-18, lead salts
hh PVC Processing
hh Manufacture of plastic articles
hh Electrical batteries and accumulators
hh Lead-stabilised plastic materials - internal structural component of buildings
hh Lead Battery Production – electrical batteries and accumulators
hh Manufacture of computer, electronic and optical products, electrical equipment
hh Industrial:
• General manufacturing, e.g. machinery, equipment, vehicles, other transport equipment


AS SENTCOM PLIANCE

Further Lead Compounds (and salts)
Lead Titanium Zirconium Oxide
hh Manufacture of LTZ and Processing into electro-ceramic components
• Machinery, mechanical appliances, electrical/electronic articles
hh Manufacture of piezoceramic:
• Intermediate

Lead bis(tetrafluoroborate)
hh Substance Manufacture:
• Metal surface treatment products, including galvanic and electroplating products
hh Electrolytic Lead Plating
• Manufacture of fabricated metal products (excluding machinery and equipment)
hh Non-metal-surface treatment products
hh Laboratory chemicals
Lead cyanamidate
hh No use information in registration dossiers.
• Internet sources state some previous use as an anti-fouling paint on the bottoms of boats
and some past use in electro-coating.


AS SENTCOM PLIANCE

Further Lead compounds (and salts) CONTINUED
Lead titanium trioxide
hh Industrial Use:
• Semiconductors
• Machinery, mechanical appliances, electrical/electronic articles

Acetic acid, lead salt, basic
hh Registered Uses:
• Intermediate - manufacture of chemicals and chemical products
• Industrial use
• Manufacture of substances
• Laboratory chemicals
• Coatings and paints, thinners, paint removers
• Products such as ph-regulators, flocculants, precipitants, neutralisation agents.
• Manufacture of computer, electronic and optical products, electrical equipment.


AS SENTCOM PLIANCE

Tetraethyllead
hh Industrial manufacture and formulation of fuel additives and fuel blends,
hh Industrial use of fuel blend containing fuel additive
hh Fuels
• Professional use
• Consumer use


AS SENTCOM PLIANCE

Diazene-1,2-dicarboxamide (C,C’-azodi(formamide))
hh The main use of ADCA is as a blowing agent in the rubber and plastics industry.
hh Aging and bleaching ingredient
• Further possible uses of ADCA may be as a bleaching agent in photography.
hh Foaming agent
hh Catalyst
hh Insulating material
hh Construction material and chemicals
hh Cement filler
hh Colouring agent
hh Air fresheners
hh Additive


AS SENTCOM PLIANCE

1,2-Diethoxyethane
hh Inert reaction medium
hh Solvent for ester gum
hh Shellac and some resins and oils
hh Organic synthesis (reaction medium)
hh Solvent and diluents for detergents
hh Dye solvents in non-grain raising stains.

1,2-diethoxyethane belongs to the glyme family of chemicals, of which monoglyme, diglyme and
triglyme (TEGDME, EGDME) have been already identified as SVHC.


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Dibutyltin dichloride (DBT)
Technical functions of DBTC:
hh additive in rubber
hh stabiliser in PVC plastics
hh catalyser in the production of polyurethanes and silicones
hh use in insulations and coatings
Organotins (mono and di-substituted) use as PVC stabilisers is the largest of all of their uses. Of
all the organotins, mercaptides (tin-sulphur bond) and carboxylates (tin-oxygen bond) have the
best stabilising performance. DBTC is mainly used as an intermediate in the production of other
dibutyltin compounds.


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hh PVC plastics:
• water pipes, packing materials, textile products
• silicone rubber (sealants, dental products, paper coatings)
• polyurethanes (foam plastics, glue/sealants), glass (coatings)
• insulators in electronics and cables, deworming agent for poultry,
• Food wraps and food packaging
• T-shirts
• Sanitary napkins
• Medical equipment
• Soft toys

The uses for DBTC mentioned in the registration dossier are as an intermediate and as an additive
in the production of tyre rubber.


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♦ 2 “Groups” were added to the SVHC List:

4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylated (4-tert-octylphenol ethoxylates)
4-Nonylphenol, branched and linear

hh The 4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylated entry covers well-defined substances,
UVCB substances, polymers and homologues
• The ECHA does not call out specific CAS and EC numbers in the Candidate List
however research provides:
»» EC/CAS: 219-682-8, 2497-59-8
»» CAS: 2315-67-5, 2315-61-9, 9002-93-1


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hh The 4-Nonylphenol, branched and linear entry covers:
• substances with a linear and/or branched alkyl chain with a carbon number of 9 cova-
lently bound in position 4 to phenol,
• UVCB- and well-defined substances which include any of the individual isomers or a
combination thereof
• The ECHA does not call out specific CAS and EC numbers in the Candidate List
however research provides:
»» nonylphenol: EC:246-672-0, 25154-52-3
»» phenol, 4-nonyl-: EC:284-325-5, 84852-15-3
»» ethoxylates:
• EC: 500-024-6, 500-209-1, 500-315-8
• CAS: 9016-45-9, 68412-54-4, 127087-87-0


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4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylated
(4-tert-octylphenol ethoxylates)
The ethoxylate uses in the registration dossiers of 4-tert-octylphenol are:
hh Formulation of paints and Industrial end-use of paints
hh Use of ethoxylates in emulsion polymerisation
hh Use as intermediate for the production of ether sulphates
hh Consumer and professional end-use of products (e.g. paints)

Queries in different product registers confirm further types of uses of 4-tert-octylphenol ethoxylates:
hh Emulsifiers for emulsion polymerisation End application for polymer dispersions in-
cluded in paints, paper, inks, adhesives and carpet backings.
hh Textile and leather auxiliaries Emulsifier in finishing agents for covering leather and tex-
tiles with a thin polymer film for improved surface properties
hh Pesticide formulations Emulsifier to aid dispersion of the products over leaf surfaces
hh Veterinary medicine products
hh Water based paints Act as emulsifiers and dispersants
hh Intermediate for production of octylphenol ether sulphates Mainly used as emulsifiers in
water based paints or dispersants in pesticide or herbicide formulations


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4-Nonylphenol, branched and linear
hh Textile Production
hh Paints and Printing Inks, Lacquers, Varnishes
hh Pulp, paper and board industry: component of phenolic resins used in coatings, e.g. for carbon-
less copy paper, and other NP-resins used for printing inks.
hh Adhesive: water-based adhesives in the textile industry, pulp and paper industry, printing-works,
construction industry, and in the plastic products industry.
hh Agriculture: wetting agents in pesticide formulation to improve the efficiency of spraying and re-
duce the amount of active ingredient and as additive in veterinary medical products like teat dips.
hh Metal working fluids and lubricating oils
hh May be used as antioxidants and plasticizers in plastic products
hh Accelerator or cutting agent in the hardening components in some epoxy resins and it has been
detected in plastic products used in the building industry, in food contact plastics and baby toys.


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Industries Affected
High-Risk Materials
hh The high risk materials have not changed drastically with each SVHC Candidate List expansion
and this is no exception
hh Some of the materials and products that are most likely to include SVHCs are listed below:
• Resins
• Adhesives
• Inks, Coatings and Paints
• Plastics, Rubbers, Silicones, Polyolefins, Polymers
• Cables
• High Impact Polystyrene (HIPS)
• Polyvinyl Chloride (PVC)
• Capacitors and Semiconductors
• Printed circuit boards (PCBs)


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Registry of Intentions and Authorization List
What are they and where can I find them?
Registry of Intentions
hh In the authorization process, Member States and the ECHA must register their intention to sub-
mit SVHC dossiers (Annex XV) for review and comment
• Once these dossiers are submitted and pass a compliance check, the substances are moved to
the “consultation list” (Proposed SVHCs)
• The substances and their dossiers then go through the comment period (with subsequent ap-
proval by the ECHA) before they are added to the SVHC Candidate List

Registry of Intentions Site:
http://echa.europa.eu/addressing-chemicals-of-concern/registry-of-intentions


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Authorization List
hh Once a substance is on the SVHC Candidate List, the ECHA then must regularly submit rec-
ommendations of substances that should be subject to authorization
• Once a substance is on the authorization list, it can now be considered, in layman’s terms,
a restricted or prohibited substance rather than simply a declarable substance
»» Authorized substances cannot be used in the EC beyond the hazard thresholds
established by the DSD/DPD/CLP
»» Substances already an integral part of articles are not subject to authorization

• Therefore the ECHA prioritizes which substances should be on the Authorisation List
• Further information on these steps can be found at:
http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/authorisation/
recommendation-for-inclusion-in-the-authorisation-list

The Authorization List itself can be found at:
http://echa.europa.eu/addressing-chemicals-of-concern/authorisation/
recommendation-for-inclusion-in-the-authorisation-list/authorisation-list


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Authorization List
Latest Update
hh At same time as SVHC Candidate List Update:
• 10 more SVHCs are moving to the next step in the Authorization process.
• The SVHCs below are being finalised for recommendation for inclusion to the Authorisation
list. Should they be included in the recommendation to the European Commission and the
Commission approve the recommendation, the substances will require an authorisation for
continued use (above the hazard thresholds found in the DPD and CLP) in the EC:
»» bis(2-methoxyethyl) ether (diglyme)
»» dichromium tris(chromate)
»» pentazinc chromate octahydroxide
»» strontium chromate
»» arsenic acid
»» potassium hydroxyoctaoxodizincate dichromate
»» formaldehyde, oligomeric reaction products with aniline (technical MDA)
»» N,N-dimethylacetamide (DMAC)
»» 1,2-dichloroethane (EDC)
»» 2,2’-dichloro-4,4’-methylenedianiline (MOCA)


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How can Assent Help?
Consulting Services
• Manage compliance to ROHS, REACH, CLP and other Environmental standards
• Ensure compliance with regulatory agencies and compliance regulations
• Review and evaluate environmental requirements and changes as published by regulating bodies
• Support sourcing and selection of electronic and mechanical components
• Serve as subject matter expert on regulatory matters
• Specification and drawing review for compliance
• Obsolescence management and part substitution
• Work with suppliers on corrective actions


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 How Can Assent Help?
REACH Specifications

P.O. Box 1980 Phone: 765.983.5200
Richmond, IN 47375-1980 Fax: 765.983.5257



Belden Supplier Environmental Specification ENV001
Rev. 2/10/10

This specification outlines the environmental requirements for all purchased materials to be used in cable
products and all finished goods for the Belden Americas Division, Effective April 1, 2005. Belden Spec ENV001
• Insert appropriate regulatory reference for REACH – Regulation
Belden Americas Division’s Policy is to comply with all known environmental regulations worldwide. We will
endeavor to market and manufacture products that are compliant, rather than label or otherwise identify non-
compliant products. Therefore, all materials and finished goods supplied to Belden Americas Division shall

EC No 1907/2006
also comply with known environmental regulation, including but not limited to:

- California Proposition 65 Consent Judgment for Wire & Cable Mfgs. (San Francisco Superior Court Nos.
31262 and 320342)
- EU ROHS (Directive 2002/95/EC, 27-Jan-2003)
- EU ELV (Directive 2000/53/EC, 18-Sept-2000) - Anthracene Oil
• This is also outdated at this point, the chemical requirements
- EU WEEE (Directive 2002/96/EC, 27-Jan-2003) - Diisobutyl Phthalate
- Aluminosilicate
- EU Brominated Flame Retardants (Directive 2003/11/EC, 6-Feb-2003)
- Zirconia Aluminosilicate
(based solely on the REACH SVHC list) is not current
- China ROHS (Ministry of Information Industry OrderLead Chromate
- #39 )
- Lead Chromate Molybdate Sulfate Red

• Insert the link to the current SVHC Candidate List along
- EU REACH - Lead Sulfochromate Yellow
- Acrylamide
In addition to these regulations, Belden Americas Division (2-Chloroethyl Phosphate) use of the following
- Tris has also restricted the

with wording ensuring the supplier is given the responsibil-
- Coal Tar Pitch
substances. These substances must not be present as intentionally added to any material for finished good
(other than trace amounts). - Perflurooctanyl sulfonate (PFOS)
- Bisphenol A (BPA)
- Asbestos and its compounds
- Cadmium and its compounds
- Chromium VI and its compounds
The following substances may be present, but their quantity by weight per homogeneous material must be
reported to Belden Americas Division. ity to stay aware and compliant to the most current list
- Lead and its compounds
- Mercury and its compounds
- Other brominated flame retardants compounds
- Antimony and its compounds
- Polybrominated biphenyls (PBBs) and their ethers/oxides (PBDEs PBBEs)
- Arsenic
• Can continue to also list the SVHC Candidate List, this is
added clarification to suppliers
- Di-(2-ethylhexyl) phthalate (DEHP)[Dioctylphthalate Beryllium and its compounds
- (DOP)]
- Ethylene glycol ethers
- Penta-,Octa-, and Deca- BDE compounds - Organic tin compounds
- Organophosphate compounds
- Antracene - Other phthalates

• CAS Numbers should be included
- Perflurooctanoic acid (PFOA)
- 4,4’- Diaminodiphylmentane - Polyaromatic Hydrocarbons (PAH)
- Dibutyl phthalate (DBP)
- Cyclododecane Suppliers of materials and finished goods shall report to Belden Americas Division their compliance to the
above requirements beginning with the first shipment on/after April 1, 2005 and with the first annual shipment
- Cobalt dichloride

• Trace amounts should be defined
thereafter. In addition, notification shall be sent if a materials or finished good status changes for any reason.
- Diarsenic pentaoxide The report shall be sent to:
- Diarsenic trioxide -
Belden Americas Division
- Sodium dichromate, dehydrate ATTN: Purchasing- Materials Environmental Compliance Report

• Advise to create and send-out a reporting tool to record the
- 5-Tert-butyl-2,4,6-trinito-m-xylene 2200 US Hwy 27 South
- Hexabromocyclododecane (HBCDD) Richmond, IN 47374-7279
- Alkanes, C10-13, Chloro(Short chain chlorinated paraffins)

information requested
- Bis (tributyltin)oxide
- Lead hydrogen arsenate
- Triethyl arsenate
- Benzyl butyl phthalate (BBP)
- 2,4-Dinitrotoluene
• As a separate note, the RoHS recast (Directive 2011/65/EU)
should be added to the list of regulations


AS SENTCOM PLIANCE

REACH Specifications
Company X requires suppliers to identify any Substances of Very High Concern (SVHC) present
in an Article (or Deliverable*) at or above the 0.1% weight by weight (w/w) concentration and
report the name and CAS number of the SVHC candidate and the weight of the deliverable.
The current candidate list of SVHCs, as published by the European Chemicals Agency (ECHA), is
located at: http://echa.europa.eu/web/guest/candidate-list-table. This list is subject to change
at any time and changes at least twice per year.
Suppliers must provide a dated declaration to Company X concerning the SVHC content of their
Deliverables upon receipt of the Deliverables by Company X. This SVHC information is to be
updated to the best of the supplier’s ability as SVHCs are added to the SVHC Candidate list.
These updates will include Deliverables already shipped to Company X.
The declarations and updates above shall be submitted via Assent’s web portal as part of Company
X’s REACH compliance program.
If an SVHC is present in a Deliverable at or above the reporting concentrations, the Supplier
must provide a communication to Company X meeting the requirements of Article 33 of the EU
REACH Regulation.
*Deliverables include any tangible item(s) delivered by or for a Supplier to COMPANY X in accor-
dance with a purchase contract or other agreement with COMPANY X. Deliverables include, but are
not limited to, components, materials, parts, and products.


AS SENTCOM PLIANCE

Creating Terms and Conditions

Company X Terms and Conditions
EU REACH/RoHS
China RoHS
Non-Company X brand (i.e., third-party/Supplier logo) products must
comply with applicable legal requirements.
This Specification communicates Company X’s requirements for Company
X brand products and materials, parts and assemblies incorporated into
Company X Brand products worldwide, in accordance with theRoHS requirements do not apply to spare requirementsrepair, or reuse, provide REACH-compliant safety data sheets,
The European parts for the
as applicable and
of electrical and electronic equipment put on the market before July 1, 2006,
Union directive for the Restriction of Hazardous Substances (RoHS), the including requirements associated with the CLP Regulation2.
European Union regulation Registration, Evaluation, Authorisation and process chemicals.
batteries or
Restriction of Chemicals (REACH) as well as China RoHS. The current candidate list of SVHC as published by the EU is located at:
Table 1 – RoHS Substance Restrictions
http://echa.europa.eu/web/guest/candidate-list-table
1.0 Regulatory Requirements Substance Threshold
Company X brand products and materials, parts and assemblies in Level
weight % (ppm) Additional information on Substances of Very High Concern under REACH can
Company X brand electrical and electronic products must Cadmium(Cd)andits compounds
meet the 0.01% (100 be found at:
following requirements: ppm) http://echa.europa.eu/web/guest/addressing-chemicals-of-
Hxvle Crmu ( r )a its c m o n s
e a a nt ho i mC6 nd o p u d 0.1% (1000 concern/authorisation/substances-of-very-high-concern-
1. DIRECTIVE 2011/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE identification/candidate-list-of-substances-of-very-high-concern-for-
ppm)
COUNCIL of 8 June 2011 on the restriction of the use of (Pb) and its compounds
Lead certain authorisation
0.1% (1000
hazardous substances in electrical and electronic equipment (recast)
1 ppm)
(RoHS II) ; Additional information on REACH can be found at the European Chemicals
Merc ( ga its c m o n s
ury H) nd o p u d 0.1% (1000
2. REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT Agency web site at:
ppm)
AND OF THE COUNCIL of 18 December 2006 concerningatethe (PBB) http://echa.europa.eu/web/guest/regulations/reach/understanding-reach
Polybromin dbpi henyl 0.1% (1000
Registration, Evaluation, Authorisation and Restriction of Chemicals 4.0 Products for People’s Republic of China: Company X brand
ppm)
(REACH); products and parts and assemblies for “independent commercial sale” in
Polybrominaeddiphe ether (B EincludingDcB E
t nyl P D) , ea D 0.1% (1000
3. Administrative Measure on the Control of Pollution Caused by China must meet the requirements of “The Management Methods for
ppm)
Electronic Information Products (China RoHS) Controlling Pollution by Electronic Information Products (EIP)” (“China
4. All other applicable laws and regulations; RoHS”).
Additional information on RoHS and RoHS II can be found at:
Should the requirements of this Specification conflict with applicable China RoHS includes the same restricted substances as EU RoHS, listed in
http://www.bis.gov.uk/nmo/enforcement/rohs-home
governmental regulations or legislation the more stringent requirements Table 1.Company X suppliers are required to report the presence of the
shall take precedence. The RoHS recast legislation, including exemptions, can be found at: in Table 1 at the homogeneous level in amounts
restricted substances
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do? thresholds listed in Table 1.
exceeding the
2.0 RoHS Requirements uri=OJ:L:2011:174:0088:0110:EN:PDF
Homogeneous materials within new Company X brand products and parts English summary on China RoHS and China RoHS links (Chinese and English)
and assemblies for new Company X brand products must 3.0 exceed the EU Very High Concern (SVHC) in Articles - Reporting
not Substances of available at:
RoHS substance restrictions in Table 1. Any applicable exemptions must be
Requirements http://www.tradecommissioner.gc.ca/eng/document.jsp?
duly communicated by the supplier. did=73745&cid=512&oid=807
Under REACH, Company X products are defined as “articles”.

1 The recast RoHS Directive 2011/65/EU (RoHS II) hasArticle: means an object which during production is given a special shape,
repealed Directive 2002/95/EC (RoHS). The recast RoHS Directivedesign which determines its function to a greater degree than
surface or
does its chemical composition;
2011/65/EU was published in the Official Journal of the European Union on 1
July 2011 and entered into force on 21 July 2011.
2 REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF
As such, Company X requires suppliers to identify (Substance name, CAS
and/or EC number) if any Substances of Very High COUNCILof 16 December 2008 on classification, labelling and packaging
THE Concern (SVHC) are
present at or above the 0.1% weight by weight substances and mixtures, amending and repealing Directives 67/548/EEC
of(w/w). Suppliers of
substances and/or preparations are also required to meet REACH registration Regulation (EC) No 1907/2006
and 1999/45/EC, and amending
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?
uri=OJ:L:2008:353:0001:1355:en:PDF


AS SENTCOM PLIANCE

REACH Declarations
AMERICAN ZETTLER, INC.
75 COLUMBIA • ALISO VIEJO, CA 92656 • 949-831-5000 • FAX 949-831-8642

To: Supplier Reach Team

From: Ed Edsinga

Date: 10/27/2008 Release date Not updated to the most recent SVHC list but the format
2/12/2010 Revised
6/29/2010 Revised
2/14/2011 Revised and necessary elements are otherwise present
6/25/2011 Revised

Subject: Reach Directive

Supplier Communication of SVHC _ EU Regulation EC 1907/2006_AMERICAN ZETTLER
INCORPORATED

Reach Directive declaration: Valid for all American Zettler Inc. companies:
American Zettler, Zettler Magnetics, Zettler Controls, and AZ Displays.

American Zettler products supplied to customers do not contain any of the reported
substances listed in the SVHC_EU Regulation EC 1907/2006 “list of substances” from
October 28, 2008, added substances f rom January 13, 2010, June 18, 2010 &
December 15, 2010. (Candidate List of Substances of very High Concern – total 53
substances).

Zettler procures articles (not chemicals) which are not intended to release any
substance under normal and reasonable foreseeable conditions of use.

Signed:

Ed Edsinga
Engineering Manager

www.azettler.com


AS SENTCOM PLIANCE

 How can Assent Help?
Supply Chain Follow-Up Process
FOLLOW UP process

30 days after supplier-provided resolution date, a call is placed to the
Supplier by the Project Manager

YES Update database.
Has the Supplier Follow-Up process
resolved the part? completed.

NO

New date is agreed upon between Project Manager and Supplier

30 days after second supplier-provided resolution date, a meeting is setup
with the Supplier, the Project Manager and the Purchasing Manager.

Supplier parts must be defined as
either “Yes”, “No” or “Unknown” after
this meeting as per the Supplier
Survey Process and dealt with
accordingly.


AS SENTCOM PLIANCE

How can Assent Help?
Software Services
• Automatically gather environmental compliance data from your supply chain (Declarations,
COC’s, DOC’s, etc.)

• Platform for suppliers to enter environmental compliance information

• Generate custom reports based on gathered compliance data:
• Allows for a top level view of compliance progress or a drill down to product or part level
compliance
• Instantly isolate problem areas based on products, parts or materials.

• Generate compliance documents for Enforcement agencies and downstream users.
• Acts as a platform for internal teams to manage environmental data and make internal declara-
tions based on obtained information:
• Engineering Override

• Automatic communication tool to inform suppliers of changes to environmental regulations
• Free model for large cap companies looking to implement a software platform with their
supply chain


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Questions?
Please submit your questions in writing using the Q&A tool along the top menu tool bar.
Any questions not addressed during the Q&A portion of this webinar will be addressed in
private correspondence after the webinar and in an FAQ document posted to the Assent Compliance
Webinars page.


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