• Home
  • Brief company history
  • A few words from the President
• Markets
  • Medical industry
  • Microelectronic and Connector industry
  • Aerospace
  • Speciality markets
• Products
  • Copper-Beryllium
  • Copper Alloys
  • Stainless Steels
  • Titanium
  • Refractory Metals
  • Superalloys
  • Clad Metal Solutions
  • Other Grades
• Partners
• Quality
  • EN / ISO Certificates
  • Customer Approvals
  • AEO Approval
  • Customer Satisfaction Report
  • Customer Satisfaction Questionnaire
  • REACH and RoHS Regulations
• Contacts
  • International Sales Offices / Agents
  • Contact us
• Login page

REACH and RoHS Regulations

Environmental progress : the latest news...

Last 15 December 2010, the European Chemicals Agency (ECHA) has published the 4th List of Substances of Very High Concern (SVHC). None of them is contained in the products delivered by Stainless.

REACH Regulation | RoHS Regulation

Summary for Customers on the European Union REACH Regulation (EC) No 1907/2006 as it relates to Beryllium and Beryllium-containing Materials
November 4, 2008

Brush Wellman Inc. is committed to making our customers’ transition into REACH as simple and straight forward as possible for all of our products, including beryllium, beryllium-containing alloys, and beryllium oxide, you purchase from us, so that you, and all downstream customers, can continue to take advantage of the beneficial properties, high performance and reliability you have come to expect. We will participate in the preparation and submission of the information and documentation as required by the REACH Regulation, including Pre-Registration, Registration, Communication, and Authorization of substances contained in our range of products.

Pre-Registration and Registration: We have determined that the majority of our metal products, as imported into the EU, are articles. This determination is based on the Guidance Document on Substances in Articles classifying metals in massive or wrought form as articles. According to this guidance document, substances in articles do not need to be Pre-Registered or Registered unless a substance exceeds 1 metric tonne per year per manufacturer or importer and the substance is intentionally released from the article. Normal processing of our products such as machining, grinding, welding, etc., as well as, normal wear and tear are not considered as intentional releases. It must be noted that if a metal product is in a form that is to be melted, such as ingots whose shape is materially changed, it is considered to be a substance (pure metal) or a preparation (alloy) whose constituents are subject to the requirements relative to Pre-Registration and Registration.

Even though the majority of our customers buy articles, we have Pre-Registered all product constituents using the “Only Representative” process. We have engaged the services of RCC Cytotest Cell Research GmbH (contact ) to pre-register and register beryllium and beryllium oxide and have engaged the services of UMCO Umwelt Consult GmbH ) to pre-register the other alloy constituents that meet the 1 metric tonne threshold. Brush Wellman will have the Only Representative(s) ensure that the uses of our products are registered and that Safety Data Sheets will be developed and provided in accordance with REACH and the Global Harmonized System (GHS) requirements. We are doing this to ensure the integrity and availability of our products in the marketplace in the event there is a future change in the existing interpretations by the REACH Agency.

Communications: For articles containing a substance that is listed on the Candidate List of Substance of Very High Concern (SVHC) by the European Chemicals Agency (ECHA), the manufacturer or importer is required to inform the recipients of the article about the substance and how the article can be safely used if the listed substance is present in excess of 0.1 wt %. Beryllium was not listed on the first Candidate List that became effective on October 28, 2008. If any of our products contain a listed substance, you will be advised accordingly and we will ensure that your use is included in the substance registration dossier.

Authorization: The aim of Authorization is to ensure that the risks from substances of very high concern are properly controlled or substitution is made if economically and technically viable. The publication of the Candidate List is a first step to identify substances that could require that their use be Authorized. The first Candidate List of 15 substances to be considered for Authorization became effective on October 28, 2008. None of the substances in our products were on this list. Since the European Commission has determined that substances in articles are not subject to Authorization, our customers buying articles will not be subject to use authorizations unless they incorporate a listed substance into one of our products. Based on our understanding of the priorities being considered by the member states for identifying substances to be subject to Authorization, we believe that it is unlikely that substances in our metal products, including beryllium, will require their uses to be authorized.

The above information is being provided based upon current knowledge of REACH interpretations and guidelines. Please be advised that new interpretations and guidelines may change the above guidance. We will strive to keep you informed of any future changes; however, it is highly recommended that those involved with REACH implementation periodically consult the European Chemical Agency website : http://echa.europe.eu/home_en.asp

If you have any questions regarding the information provided above, would like a copy of any of the documents described in this summary or wish to provide feedback, please contact Terry Civic, Manager of Environmental Health and Safety, our point of contact for REACH, via phone at +1 (216) 383-3698 e-mail : . You may also contact Hans Ulrich Büttner, Director Environmental, Health & Safety Europe at +49(0)711 83093-18, or call the Brush Wellman Product Safety Hotline at (800) 862- 4118.

Summary to Customers on the European Union RoHS Directive as it relates to Beryllium and Beryllium-containing Materials
August 11, 2008

Beryllium is not included or restricted in the final European Union (EU) Directive on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS). The RoHS Directive currently restricts the use of lead, cadmium, hexavalent chromium, mercury, PBB and PBDE in electrical and electronic equipment (EEE). Therefore, beryllium (Be), copper beryllium (CuBe) and nickel beryllium (NiBe) alloys and beryllium oxide (BeO) ceramic are acceptable for use in electrical and electronic equipment and are in conformance with the RoHS Directive.

Article 6 of the RoHS Directive requires the European Commission (EC) to periodically evaluate the need to revise the list of substances covered by the RoHS Directive. The EC initiated a project in 2007 to evaluate other substances and contracted with the Öko-Institut e.V. to conduct the evaluation. We learned that beryllium and beryllium oxide were being evaluated along with 44 other substances including antimony trioxide, antimony compounds, arsenic and compounds, cobalt, cobalt oxide, gallium arsenide, nickel and selenium.

We prepared and submitted a document to Öko-Institut e.V. entitled “A Qualitative Overview of the Use of Beryllium, Beryllium-Containing Alloys and Beryllium oxide Ceramic in Electrical and Electronic Equipment (EEE)”. The document provided information about beryllium metal, beryllium-containing alloys and beryllium oxide ceramics as it relates to use of these materials in EEE and the potential health and environmental risks.

We requested and were granted a meeting with representatives of the Öko-Institut e.V. The purpose of the meeting was to provide Öko-Institut e.V. with scientific and technical information on the safe use of beryllium, copper beryllium and nickel beryllium alloys and beryllium oxide ceramic in EEE to aid them in their evaluation of these materials per the established criteria used during the process of exploring the need to revise the list of restricted materials covered by the RoHS Directive. During our March 5^th meeting with the Öko-Institut e.V., we discussed and clarified the important uses of beryllium, copper beryllium and nickel beryllium alloys and beryllium oxide ceramic in EEE, the relatively small use of beryllium (including in alloys) and beryllium oxide ceramic in EEE, the evidence of safe handling during use, disposal and recycling, and the studies which indicate that beryllium is incorrectly classified as a carcinogen.

Based on its thorough review of all the information, the Öko-Institut e.V. determined that beryllium, copper beryllium and nickel beryllium alloys, and beryllium oxide ceramic did not "constitute significant health and environmental risks due to their use in electrical and electronic equipment" and were therefore not included in the recommended list of candidate substances for potential inclusion in RoHS in the draft Final Report on the “Study on Hazardous Substances in Electrical and Electronic Equipment, Not Regulated by the RoHS Directive” submitted to the EC on April 28, 2008.

The Öko-Institut e.V. has reviewed comments submitted on its draft Final Report and issued the Final Report to the EC on June 4, 2008. The EC has not yet issued the Final Report for public review. Based on the recommendations contained in the draft Final Report, we believe that neither beryllium nor beryllium oxide ceramic will be considered by the EC for inclusion in any future RoHS revisions and that these substances as well as copper beryllium and nickel beryllium alloys will continue to be available for use in EEE. We will continue to monitor the activities at the Öko-Institut e.V. and the EC related to revisions to the RoHS Directive.

If you have any questions regarding the information provided above, would like a copy of any of the documents described in this summary or wish to provide feedback, please contact Ted Knudson, Director of Product Stewardship via phone at (216) 383-4040 or e mail at : , or call the Product Safety Hotline at (800) 862-4118.