In close corporation with our supply chain we strive to ensure compliance with the following chemical regulations on all PR produced products (which is also covered by the PR electronics negative list):
- EU Directive 65/2011/EU RoHS 2 incl. EU Directive 2015/863 RoHS 3
- EU Regulation 1907/2006/EC REACH
- China RoHS 2 – EFUP 50 years
- EU Directive 66/2006/EC on batteries and accumulators and waste batteries and accumulators
- EU Directive 94/62/EC on packaging and packaging waste
- IMO MEPC 269(68)
- US Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502
- EU Directive 2018/851/EP, ECHA SCIP, is under implementation, effective from 5 January 2021
- EU Regulation 2017/821, the Conflict Minerals Regulation, is under implementation
PR Negative List - Fact Sheet
The PR Negative List is divided into three different categories: Banned, Restricted and Substances of Concern.
It provides information about restrictions on the use of Chemical substances in PR electronics' production processes, materials and product components as well as packaging.
If EU REACH limit values are exceeded in some components appearing in the product, information of this must appear on all orders – a link to our Chemical Compliance Statement on all orders ensures this.
EU SCIP Registration from 5 January 2021
Companies supplying articles containing substances of very high concern (SVHCs) according to REACH on the EU market have to submit information on these products / articles to ECHA, as from 5 January 2021.
The European Chemicals Agency (ECHA) has built a database for mandatory registration and storing of these data.
- It is referred to as the Substances of Concern In Products – SCIP registration.
- The information in the database is then made available to waste operators and end users.
PR has registered all affected products based on product main type containing components with SVHC reported from our suppliers for both PR Headquarter (manufacturer) as well as our Sales Subsidiaries within EU.
PR Headquarters will continually ensure that the data entered is maintained as REACH is updated and / or new data is received from our suppliers.
If a PR product is NOT listed in the SCIP Database it means that it does not contain any SVHC’s in a concentration above 0.1% weight by weight (w/w).
See list of SCIP Registration numbers per product main type here
The EU Directive 2015/862 amending the RoHS2 Annex II, adding four new substances to the list of restricted substances (DEHP, BBP, DBP, DIBP) applies from 22 July 2019.
As PR electronic’s products are the type “industrial monitoring and control instruments”, the new restrictions do not apply until 22 July 2021, as the European Commission has decided a longer transition period for these type of products, due to the longer innovation cycles for medical and monitoring and control instruments.
Even though our products are not yet in scope for the RoHS3 legislation, we already comply with the extended RoHS 2 substance list.
Conflict Minerals (tin, tungsten, tantalum, gold)
In 2010, the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act was passed concerning “conflict minerals” originating from the Democratic Republic of the Congo (DRC) or adjoining countries.
Information on minerals and their country of origin present in PR electronics’s products is disclosed using the Conflict Minerals Reporting Template (CMRT) created by the Responsible Minerals Initiative (RMI). The scope for PR electronics’s CMRT is at Company level and thereby encompasses all PR products.
See PR electronics’s CMRT (v5.12)
Maintaining chemical compliance throughout the supply chain
Requirements are continually monitored and assessed. Twice a year PR electronics receive a systematic update and evaluation of legal changes from an external environment advisory company. On a regular basis we perform a systematic chemical compliance assessment of our suppliers.
Until recently, this assessment was been performed manually, but in 2019 we entered into a partnership with Assent Compliance, a supply chain data management company, for a more efficient and platform-based collection and handling of chemical compliance data for all of our components. For more information on the Assent Compliance Platform see: www.assentcompliance.com
Besides collecting data / information from our suppliers, PR electronics has in 2015 also had a few tests successfully performed by an external accredited lab (Bureau Veritas - Germany) on the chemical/material content of some of our complex products and components to validate the data from our suppliers.
New requirements under implementation during 2020/21
- EU Regulation No 1257/2013, EU SRR, is under implementation