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HomeMy WebLinkAboutREACH - Wieland Rolled Products NA - WaterburyWieland July 8, 2025 RE: Wieland Rolled Products North America, LLC — Regulatory Updates To Our Valued Customer, This letter applies to the stainless -steel alloy product supplied to you. A summary of Wieland's compliance statements for common regulatory frameworks is provided below. Toxic Substance Control Act (TSCA) Wieland complies with the United States Environmental Protection Agency's (EPA) TSCA Section 8(a) Chemical Data Reporting (CDR) rule that requires chemical manufacturers, processors, and users of covered chemicals to report information regarding chemical concentrations and potential exposure in industrial, commercial and consumer settings. Furthermore, Wieland complies with TSCA Section 6(a), which imposes restrictions on the manufacture, processing, distribution in commerce, use, or disposal of the following chemical substances: • Asbestos • Lead, when used in paint • Polychlorinated biphenyls (PCBs) • Dioxins • Chlorofluorocarbons (CFCs, ozone depleting substances) • Metallic mercury, when used in consumer products • Formaldehyde, when used in composite wood products • Nitrites, when used in certain cutting fluids • Hexavalent chromium compounds, when used in water treatment • Five Persistent, Bio accumulative, and Toxic (PBT) substances: o PIP 3:1 (CAS 68937-41-7) o Deca BDE (CAS 1163-19-5) o 2,4,6 TTBP (CAS 732-26-3) o HCBD (CAS 87-68-3) o PCTP (CAS 133-49-3) Wieland continues to monitor updates to TSCA, and we are aware that the following chemical substances have restrictions set for future dates from the date of this letter. We are proactive in assuring our compliance with the restrictions on these chemical substances upon their future TSCA prohibition dates becoming effective, as outlined below: • Methylene Chloride — April 2026 • Trichloroethylene (TCE) — September 2025 • Perchloroethylene (PCE) — September 2026 • Carbon Tetrachloride — June 2027 Wieland Rolled Products North America, LLC 1215 Piedmont Street I Waterbury, CT 06706 I USA P +1 203 597 5000 I wieland.com Wieland Restriction of Hazardous Substances (RoHS) The European Union has issued various directives that control substances of concern. One such directive is the Restriction of Hazardous Substances in electrical and electronic equipment (EEE). There have been two main revisions to this directive (RoHS 2) Recast Directive (2011 / 65 / EU) and the Revision to Annex II (2015 / 863) (RoHS3). Wieland meets the directive and certification that to the best of our knowledge Mercury, Cadmium, Zinc, Lead, Hexavalent Chromium, and Phthalates are not present in levels above the threshold established by the RoHS directive as outlined below: Chemical Substance Threshold Value (By Weight in Homogeneous Material) Lead 0.1% Mercury 0.01% Cadmium 0.01% Hexavalent Chromium 0.1% Polybrominated Biphenyls (PBB's) 0.1% Polybrominated Diphenyl Ethers (PBDE's) 0.1% Bis(2-ethylhexyl) Phthalate (DEHP) 0.1% Benzyl butyl phthalate (BPPj_ 0.1% Diisobutyl Phthalate (DI BP) 0.1% Dibutyl Phthalate (DBP) 0.1% Registration, Evaluation, and Authorization of Chemicals (REACH) Wieland has reviewed the updated June 25, 2025, Candidate Listing of Substances of Very High Concern (SVHC) with 250 chemicals in the list. We can confirm that to the best of our knowledge our product does not contain SVHCs included in the European Chemicals Agency (ECHA) Candidate List in a concentration above 0.1% by weight. Under REACH guidelines, a North American company that exports product to the EU is not obligated by REACH to register or make notifications itself as REACH only obligates EU based companies or nominated EU representatives of the non-EU exporter. REACH obligations for non-EU exporters must therefore be fulfilled by the EU importers or by an EU appointed representative. Consequently, the registration or notification with ECHA of a substance covered by REACH is not the responsibility of Wieland. Please contact me at (860) 384-0205 if you have any questions on this information. Sincerely, ;,../Z— Justin Penfield Environmental Engineering Manager Wieland Rolled Products North America, LLC Waterbury, CT Wieland Rolled Products North America, LLC 215 Piedmont Street Waterbury, CT 06706 USA P +1 203 597 5000 wieland.com