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Article 33 Declaration

Our trade association, The Surface Engineering Association (SEA) has assisted in producing this document.

Article 33: Duty to communicate information on substances in articles

  1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0.1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.

  2. On request by a consumer any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0.1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.

The relevant information shall be provided, free of charge, within 45 days of receipt of the request.

Surface treatment processes use a wide variety of substances, some of which have already been classified as SVHCs (Substances of Very High Concern) and many more that meet the criteria set out in Article 57 and will probably, at some point in the future, be classified as SVHCs. However, it is extremely unlikely that any of these will be present on the finished component in a concentration above 0.1% on a weight for weight basis. The reason for this statement is explained below :

SVHC - Boric Acid

Boric acid is used in a number of surface treatment processes essentially as a pH control agent but will not be present in the finished article.

SVHC – Chromium Trioxide

Hard chromium electroplating and many decorative chromium electroplating processes use chromium trioxide but the final coating consists of Chromium Metal and no chromium trioxide will be present in the finished article.

SVHC – Sodium & Potassium Dichromate

These are used to produce a number of passivation type coatings and although chromates will still be present on the finished article, they will not be in the form of sodium or potassium dichromate in a concentration above 0.1% on a weight for weight basis.

The above are only examples and similar logic may be applicable to other substances but this will be considered on a case by case basis as and when further substances are listed as SVHCs under the REACH regulation.

We are aware of our duties under REACH and we will continue to monitor the SVHC situation via the European Chemicals Agency (ECHA) website and will proactively notify you should the situation arise where any articles processed by us contain SVHCs above the stated threshold.

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