Compliance

Declaration of Conformity
Toxic Substance Control act (TSCA)

The Toxic Substances Control Act of 1976 provides EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures for manufacturing or importing. TSCA addresses the production, importation, use, and disposal of specific chemicals. The TSCA does not apply to finished goods or parts.

Various sections of TSCA provide authority to:

  • Require, under Section 5, pre-manufacture notification for “new chemical substances” before manufacture.
  • Require, under Section 4, testing of chemicals by manufacturers, importers, and processors where risks or exposures of concern are found.
  • Issue Significant New Use Rules (SNURs), under Section 5, when it identifies a “significant new use” that could result in exposures to, or releases of, a substance of concern.
  • Under Section 6(h) compliance, EFI products comply with the PIP (3:1) (phenol, isopropylated = (3:1), CAS 68937-41-7 requirements. There is also no release during manufacturing, processing, or distribution.
  • Maintain the TSCA Inventory, under Section 8, which contains more than 83,000 chemicals. As new chemicals are commercially manufactured or imported, they are placed on the list.
  • Require those importing or exporting chemicals, under Sections 12(b) and 13, to comply with certification reporting and/or other requirements.
  • Require, under Section 8, reporting and record-keeping by persons who manufacture, import, process, and/or distribute chemical substances in commerce.
  • Require, under Section 8(e), that any person who manufactures (including imports), processes, or distributes in commerce a chemical substance or mixture and who obtains information which reasonably supports the conclusion that such substance or mixture presents a substantial risk of injury to health or the environment to immediately inform EPA, except where EPA has been adequately informed of such information. EPA screens all TSCA b§8(e) submissions as well as voluntary “For Your Information” (FYI) submissions. The latter are not required by law but are submitted by industry and public interest groups for a variety of reasons.

The Toxic Substance Control Act (TSCA) does not apply to the parts in which Electronic Fasteners, Inc. sells.

Electronic Fasteners, Inc. assures customers that everything reasonably possible is being performed to maintain compliance with all environmental standards. Controls are in place to help assure that our products remain compliant. We will continue to communicate with our suppliers and maintain compliance records for all our products as part of our compliance program.

Should you have any questions or concerns regarding this statement, please do not hesitate to contact us. Email compliance@bluecircleadvisors.com for any further information.

Del Furbish
Sales & Marketing Manager

Click here for the full letter.

International Traffic in Arms Regulation

REGISTRANT CODE: M27231

EXPIRATION DATE: 07/31/2021

RoHS & Mercury Free, REACH, and Conflict Minerals Compliance Statements

Introduction

Electronic Fasteners Incorporated is working to maintain ROHS, REACH, and Conflict Minerals compliance for all products we sell. We are working with our representatives, manufacturers, importers and distributors throughout the world to ensure that they too comply with their obligations under these regulations, as well as, meeting our recommended guidelines.

We will maintain our strong commitment to global corporate responsibility, taking into account customers, employees, manufacturers, and the environment. We will share our findings and make declarations available to you, while continuing to work with our business partners and supply chain to enforce high standards of compliance.

Below we have provided a basic overview of the regulations for your convenience and a downloadable copy of our compliance policy statements.

View our RoHS Directive – 2002/95/EC

The Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive was established by the European Union (E.U.). It affects manufacturers, sellers, distributors and recyclers of electrical and electronic equipment containing lead, cadmium, mercury, hexavalent chrome, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE).

After July 1, 2006 the use of the materials above specified thresholds were banned in new products sold in Europe; however each E.U. member country applies its own laws in regard to the directive. As noted, the Directive requires that each separate homogenous part of the component not contain more than the specified concentrations for the following substances:

Lead (PB) 0.01% maximum
Cadmium (Cd) 0.01% maximum
Mercury (Hg)) 0.1% maximum
Hexavalent Chromium (CrVI) 0.1% maximum
Polybrominated biphenyls (PBB) 0.1% maximum
Polybrominated diphenyl ethers (PBDE) 0.1% maximum

The term homogenous refers to meeting the concentration of each restricted material and being below the specified threshold for each component capable of being physically separated.

Examples of homogenous materials include: glass, plastics, ceramics, alloys, metals, paper, resins, and coatings.

Click here to read the RoHS Directive Documentation

View our REACH Directive – 1907/2006

This Declaration of Conformity based on the European Union regulation REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals no. 1907/2006) confirms that based on all available information up to this date from Electronic Fasteners suppliers, that all duties under Article 33 have been met.

Our understanding is that Article 7(1) requires producers and importers to register with ECHA the chemical substances released from any of our products during use. In addition, Article 7 (2) requires that we notify ECHA of any Substances of Very High Concern (SVHCs) if the concentration is above 0.1% by weight and the total amount put on the market in the European Union is over 1 ton a year.

It is Electronic Fasteners duty to pass on this information to our customers regarding the presence of an SVHC in a concentration above the threshold.

It is also our responsibility to respond to requests within a 45 day window with the appropriate documentation for material disclosures.

For more information on REACH legislation, click this link: www.echa.europa.eu

Click here to read the REACH Directive Documentation

View our Dodd-Frank Wall Street Reform Act – Conflict Minerals, Section 1502

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, along with the United States Securities and Exchange Commission have adopted the rule into law, requiring corporations listed on the Unites States stock exchange to report the use of “Conflict Minerals” in the sourcing and manufacturing of products.

The term “conflict minerals” is used to describe the minerals cassiterite, columbite-tantalite, gold, wolframite, and/or their derivatives, including tin, tantalum, and tungsten, originating from the Democratic Republic of Congo and the specified adjoining countries in Africa, known to support human rights violations and funding to rebel warlords.

As a privately held company, we are not required to report to the SEC, however, many of our customers are required to meet this obligation. In an effort to support our customers, we are committed to get the best available information from our suppliers on all products we sell, and to openly share that information with our customers.

As of March 2015, the findings demonstrate that to the best of our knowledge, materials from our suppliers do not contain Conflict Minerals, or to the extent they might, such products are “DRC conflict free” as defined by paragraph (e) (4) of Section 1502.

We will continue to work with our suppliers to identify any potential use of Conflict Minerals in our supply chain, and ensure the representations made in this compliance statement remain accurate. To that end, we reserve the right to amend this statement at any time based on subsequent developments or information.

Click here to read the Conflict Minerals Statement Documentation

Proposition 65 

In 1986, California voters approved the Safe Drinking Water and Toxic Enforcement Act known as Proposition 65. The purpose of Proposition 65 is to ensure that people are informed about exposure to chemicals known by the State of California to cause cancer, birth defects and/or other reproductive harm. In 2017, California updated the warning rules. Products containing Proposition 65 substances must carry a new warning statement unless they can be shown to not have an exposure risk.

Proposition 65 mandates that California maintain and publish a list of chemicals that are known to cause cancer, birth defects and/or other reproductive harm. The list is updated annually and includes a wide variety of chemicals that can be found in dyes, solvents, drugs, food-additives, by-products of certain processes, pesticides and tobacco products.

A chemical can be listed if it has been classified as a carcinogen or as a reproductive toxicant by an organization deemed “authoritative” on the subject. For carcinogens, the U.S. Environmental Protection Agency, U.S. Food and Drug Administration, National Institute for Occupational Safety and Health, the National Toxicology Program, and the International Agency for Research on Cancer are deemed authoritative. With respect to reproductive toxicants, the authorities are the U.S. Environmental Protection Agency, U.S. Food and Drug Administration, National Institute for Occupational Safety and Health, and International Agency for Research on Cancer. A chemical can also be listed if it is required to be labeled or identified as a carcinogen or as a reproductive toxicant by an agency of the state or federal government.

To comply, businesses are: (1) prohibited from knowingly discharging listed chemicals into sources of drinking water; and (2) required to provide a “clear and reasonable” warning before knowingly and intentionally exposing anyone to a listed chemical.

The California government clarified that “The fact that a product bears a Proposition 65 warning does not mean by itself that the product is unsafe.” The government has also explained, “You could think of Proposition 65 more as a ‘right to know’ law than a pure product safety law.” See http://www.p65warnings.ca.gov

A Proposition 65 warning means one of two things: (1) the business has evaluated the exposure and has concluded that it exceeds the “no significant risk level”; or (2) the business has chosen to provide a warning simply based on its knowledge about the presence of a listed chemical without attempting to evaluate the exposure.

At EFI, we use the short form warning on our purchase orders from suppliers, packaging, and our website.

For more information contact: 888-890-7780 or

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