As the EU REACH SVHC list adds another two ingredients, it is an excellent time to talk about the burden of environmental regulations on business. The SVHC list is updated every six months. Every update means companies need to request new certifications to the expanded list. For a company that sells small components, thousands of customers and parts need to be updated. The addition of new regulations compounds this.
Apple Rubber Regulation Policy
We will always try to comply with all customers’ regulations.
- Customer’s Certificates: Since we developed our certificates, our position is always to use our certificates. We will elevate filling in customers’ certificates based on business viability.
- Automatic Updates: We don’t automatically send out updates to REACH or other regulations. If customers require constant updates, we are part of BOMCHECK.net and IMDS, and we keep parts in that system up to date.
- Proof Of Purchase: We require the parts to be directly purchased from Apple Rubber to be certified. We get many requests from customers that buy parts through distributors. We request that you go through the distributor to get a compliance letter. We have seen cases where parts are not purchased from Apple Rubber.
- Active Purchase: Apple Rubber requires purchasing the product within the last three years. In some cases, we will be certified based on the project life cycle. An example would be a medical device taking years to qualify.
- Certificate Of Conformance: REACH or other compliance declarations will not be added to our part COC. We will provide a one-time certificate at the time of the first article or when compliance is updated at the customer’s request.
- Adding to Part Drawings: We take exceptions to environmental regulations added to drawings, especially when regulations are constantly updating; our customers have their regulations that are not provided.
Changing Regulations
California Prop 65: New list April 21, 2023 – old list January 27, 2023, approx. 900 chemicals
REACH SVHC: New list June 14, 2023 – old list January 17, 2023, 235 chemicals
EU Persistent Organic Pollutant: New List January 23, 2023
EU MDR: New list ATP18 Dated May 23, 2023.
EPA Toxic Substance Control Act
New Regulations
Many countries and US states are starting to impose or propose regulations banning PFAS chemicals. This could have a large effect on the rubber and plastic industries. See our latest Hot Topic about the subject. Apple Rubber processes both Fluorocarbon and Fluorosilicone rubber compounds. These are designated with CAS# 64706-30-5 and CAS# 68952-02-3. Currently, these CAS# are not part of the EPA’s TSCA section 8(a)(7). Nor has there been an official ban on any of the EU members. We will continually monitor these regulations. Customers should not request that we eliminate PFAS use if they are currently purchasing FKM or FS O-rings or parts since these are part of the PFAS family.
Apple Rubber will try to make all reasonable efforts to comply with customer requests for environmental regulations. Because of the vast number of requests, we ask for patience when requiring a response. We also request that customers assure parts are purchased directly from us. In addition, we ask you to provide an active part list with the last purchase PO number. Additional information will help speed up the response.