On 27th June 2018 the heavy metal lead (Pb) was added to REACH’s ‘Candidate List of Substances of Very High Concern for authorisation’ (‘Candidate List of SVHC’). This triggered certain duties and obligations under the REACH regulation for many companies, including manufacturers of building hardware. In relation to building hardware products, lead is used frequently as a minor addition to alloys of which components (and in some cases the products themselves) are made of. Lead is added because of its chip breaking properties, allowing better and more efficient machining of e.g. brass and steel.
The most prominent duty under the REACH regulation is the ‘duty to communicate information on substances in articles’ (REACH regulation, Article 33). The trigger for this ‘duty to communicate information on substances in articles’ is when components of products (in some cases the products themselves) contain lead in a concentration above 0.1 % weight by weight (w/w). As this obligation impacts many suppliers of building hardware products (e.g. cylinders, door closers) ARGE has prepared a recommendation on how to comply with this and other related obligations. ARGE has also established an example information letter, which outlines which information content suppliers have to provide in order to meet the duties under REACH regulation, Article 33.
With this service ARGE hopes to make it easier for building hardware manufacturers to act in compliance with the respective REACH obligations. The recommendation and the example of an information letter can be found here.