We take legal regulations and the preservation of our environment very seriously.
As you can already read under the heading of sustainability, the protection of our environment and the sustainable use of resources are very important to us. For this reason, we of course pay strict attention to compliance with statutory regulations. Find out more about our statement on conflict minerals, REACH and ROHS at ROLEC.
STATEMENT IN REGARDS TO CONFLICT MINERALS
On July 21, 2010, US President Barack Obama signed the Dodd-Frank Act, which in addition to the regulation of financial markets also obligated companies to not use raw materials from conflict regions (§ 1502).
This includes the publication and reporting obligations for “conflict minerals”: Companies listed in the US stock exchanges must publish the usage of certain raw materials that come from the Democratic Republic of Congo or other neighboring states (Angola, Burundi, Republic of Congo, Rwanda, Zambia, Sudan, Tanzania, Uganda, Central-African Republic).
Conflict materials in regards to this law include tin, tantalum, tungsten and gold.
We are aware that the mining of these “conflict minerals” in different countries, particularly in Central Africa, may lead to profits that are used to finance armed conflicts that may result in unacceptable human rights violations.
We have informed our suppliers that we cannot accept products and raw materials that contain gold, tantalum, tin or tungsten from conflict regions. Our suppliers were asked to inform us immediately if they use such “conflict minerals” in their products. All previous confirmations in our supply chain have not shown any deviations from the order. Thus, we assume that ROLEC products do not contain the named minerals from the aforementioned region.
Furthermore, the compliance with this order is a component of our delivery conditions and we have asked our suppliers to guarantee that no “conflict minerals” are used in their supply chain.
Registration – Evaluation – Authorisation of Chemicals (REACH)
Safe implementation of materials throughout the entire value creation chain
The concept of sustainability is anchored in our company’s philosophy: ROLEC thinks, acts and feels with strategy, passion and environmental awareness! We, too, follow the obligation:
In general, chemicals should be produced and used such that negative effects on humans and the environment remain reduced to an absolute minimum.
The European Union implemented this in legislation effective 1 June 2007 with the “REACH” Regulation. It is based on the principal of self-responsibility in all companies who import, manufacture and process chemicals. They are responsible for guaranteeing that their materials and processes are handled in a safe manner. They are obligated to have the materials implemented registered, to collect the requisite data and to pass them along throughout the value creation chain.
Suppliers of articles will fundamentally only have a disclosure obligation if more than 0.1% (w/w) of articles* exported from outside the EU consists of substances on the candidate list published by the ECHA (European Chemicals Agency, Helsinki)(Art. 33).
(*The term articles in this context means articles whose form, surface and design determines function to a greater degree than does the chemical composition.)
REACH and relevance for ROLEC
ROLEC Gehäuse-Systeme GmbH is a “downstream user” and “supplier of articles” under the REACh- Regulation; therefore, there is no registration obligation. Our products do not release any substances. Thus, Art. 7 (1) of the Regulation is not subject to application for us. However, we certainly do meet our disclosure obligations as a “supplier of articles” (Art. 33 REACH Regulation).
The materials and processes (lacquer, powder coatings, adhesives, coolants and lubricants we produce) are exclusively procured in the EU. Customers procuring these materials and looking to use them for applications such as repairs or their own production will receive the respective safety data sheets from our suppliers in compliance with REACH.
We do, of course, have all products procured outside the EU (components and components groups) tested for the potential presence of substances on the candidate list. Should they be present in a critical volume (> 0.1% (w/w)), we notify all parties involved immediately.
Upstream suppliers and REACH
The REACH Regulation means: “No data – no market!”
For Rolec, this means: Our suppliers must be aware that we can only purchase products from them when they have their products tested in line with REACH and can supply the requisite data.
Of course, we also expect our suppliers working outside the EU’s borders – be they importers or manufacturers – to have acted on time to meet these requirements.
All suppliers domiciled outside the EU have been required to have the material compositions and preparations affecting our products tested for substances in the candidate list and to replace them as necessary. The latter has not been necessary thus far; none of our products has required modification of its composition due to REACH. REACH represents a “living system” and is constantly being expanded. We, too, continue to ensure the harmlessness of the materials we use. Thus, REACH is an integral part to all of our processes.
Directive 2011 / 65 / EU “Reduction of hazardous substances” (RoHS)
Safety and transparency with the selected material
ROLEC Gehäuse-Systeme GmbH follows all of the standard rules and legal requirements in selecting materials. All standard ROLEC products exclusively use products complying with Directive 2011 / 65 / EU “Reduction of hazardous substances”.
It stipulates that, since 1 July 2006, only electronic equipment may be brought to the market in certain product categories that are free of certain hazardous materials. This particularly applies to lead, quicksilver, chrome-6, polyprominated biphyenyle (PBB) and polybrominated diphenyl ethers (PBDE). Rolec’s product palette has been RoHS-compliant since 1 May 2005.
Tailored to the special requirements in certain sectors and our customers’ core competences, we deliver custom-made solutions that can deviate from our standard products. This guarantees that everyone who places an order will receive the highest level of safety and complete transparency in the composition of high quality ROLEC enclosures.