About Common Environmental Specifications Applicable to Tubing

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Common Environmental Specifications Applicable to Tubing
a. EU Directive 2000/53/EC (ELV - End of Life Vehicles) b. EU Directive 2002/95/EC (RoHS) & 2011/65/EU (RoHS2) - Restriction of Hazardous Substances c. EU Directive 2006/1907/EC (REACH - Registration, Evaluation, Authorization and Restriction of Chemicals) d. California Prop 65 d. Conflict Minerals


a. EU Directive 2000/53/EC (ELV - End of Life Vehicles)

This is a law passed by the European Union Parliament that pertains to recycling of motor vehicles. The part that applies to Grayline is that after 7/1/03, new motor vehicles can not be sold in the EU that contain lead, mercury, cadmium or hexavalent chromium except for a few specifically defined applications which do not include tubing. Since vehicles produced in the US are also sold in Europe, the US manufactures have in most cases applied the same rules to vehicles manufactured here. All tubing sold by Grayline conforms to this directive except for some specialty colors which contain lead.


 
b. EU Directive 2002/95/EC (RoHS), 2011/65/EU (RoHS2) & 2015/863/EU (RoHS3) Restriction of Hazardous Substances

European laws that restrict the use of hazardous substances in electronic equipment. These laws were passed along with another mandating recycling of electronic equipment. As of 7/1/06, new electronic equipment can not be sold in the EU if it contains lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, or polybrominated diphenyl ethers except for a few specifically defined applications which do not include tubing. Electrical equipment is defined as anything that uses electricity to work. All tubing sold by Grayline conforms to this directive except for two specialty colors.

2002/95/EC was amended on 10/13/05 to allow DecaBDE in polymeric applications. On 7/1/08, the DecaBDE exemption was annulled. 2011/65/EU (RoHS2) was passed in 2011 with the same substance restrictions but with and expanded scope and additional labeling requirements.

On March 31, 2015, 2015/863 was published. This directive ammended the list of restricted substance by adding four phthalate plasticizers, including DEHP or Di(2-ethylhexyl) phthalate. These new restrictions will be effective on July 22, 2019.


 
c. REACH - Registration, Evaluation, Authorization and Restriction of Chemicals (EU Directive 2006/1907/EC)

European wide regulation that requires that all chemicals used in the EU be registered, evaluated and authorized for specific uses. Grayline makes “articles” under this law and is not currently required to register any substances.

The law provides for the inclusion of Substances of Very High Concern (SVHC) into Annex XIV. Once a substance is included in Annex XIV, they cannot be placed on the market or used in the EU after a “sunset date” unless a company is granted an authorization.

Before SVHC's are included into Annex XIV, they are placed on a "SVHC candidate list". They then undergo a prioritization process.

Substances on the candidate list must be reported to users in the EU. As of January, 2020, there are 205 substances listed on the candidate list. Two substances on the candidate list are used in some of Grayline’s PVC tubing. These are DEHP or Di(2-ethylhexyl) phthalate, a common phthalate plasticizer, and UV-328 or 2-(2H-benzotriazol-2-yl)-4,6-dipentaylphenol. See Grayline’s REACH policy for more details.


 
d. California Prop 65

In 1986, California passed a law (proposition 65). This law requires companies that sell products in California to provide a “clear and reasonable” warning before knowingly and intentionally exposing anyone to a chemical that’s on a special CA Prop 65 List of chemicals that the state has determined to cause cancer, birth defects, or other reproductive harm. This list includes the following substances which are used in some of our tubing: antimony trioxide, carbon black, some phthalate plasticizers and vinyl chloride. We have a section on our Material Safety Data Sheets that address this law.


 
e. Conflict Minerals

In 2010, the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act was passed which included requirements for publicly traded companies to report on the usage of “conflict minerals” originating from the Democratic Republic of the Congo (DRC) or adjoining countries. These "conflict minerals" include Tantalum, Tin, Gold and Tungsten.

It is Grayline's policy to not use materials which contain any form of Tantalum, Tin, Gold and Tungsten which have originated in "conflict" countries as defined by the SEC. Grayline requires our material suppliers to provide information about the presence of "conflict minerals" and their source, if present, in the materials that they supply.

To the best of our knowledge, all of Grayline's tubing products do not contain "conflict minerals" with the exception of GP-125 PO, GP50D-PO, BR-125, and GP80-PO tubing Products. GP-125 PO, GP50D-PO, BR-125, and GP80-PO contain a small amount of a Tin based stabilizer. Per our supplier, the Tin used in these materials is sourced from "conflict-free" smelters.



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