If your company sells parts into electronics, automotive, aerospace or medical markets, your customers probably ask you to confirm where your materials come from and what’s in them. To answer, you ask your suppliers — including us. These are the requests we see most.
| Requirement | What it’s about | Where it comes from | What you’ll usually ask for |
|---|---|---|---|
| Conflict Minerals (3TG) | Where tin, tantalum, tungsten and gold were sourced | U.S. law (Dodd-Frank Act, Section 1502) | A completed CMRT |
| Extended minerals | Where cobalt, mica and other minerals were sourced | Industry reporting (Responsible Minerals Initiative) | A completed EMRT |
| REACH | Chemical substances of very high concern | European Union regulation | A REACH statement |
| RoHS | Hazardous substances in electrical and electronic equipment | European Union directive | A RoHS statement |
| California Prop 65 | Chemicals known to cause cancer or reproductive harm | California law (Proposition 65) | A Prop 65 statement |
| Safety Data Sheets (SDS) | A material’s hazards and how to handle it safely | U.S. OSHA Hazard Communication Standard | The SDS for each material |
Conflict Minerals and the CMRT
Conflict minerals are four metals, known as 3TG: tin, tantalum, tungsten and gold. U.S. law requires public companies to report whether products they make contain 3TG that may have funded armed groups in the Democratic Republic of the Congo or its neighboring countries. Under the SEC’s rules, 3TG count as conflict minerals no matter where they were mined, so companies trace them through their whole supply chain.
That tracing is done with the Conflict Minerals Reporting Template (CMRT), a free spreadsheet published by the Responsible Minerals Initiative (RMI). Each company in the chain fills one out and passes it to its customer, so the information flows from the smelters up to the finished product.
The EMRT
The Extended Minerals Reporting Template (EMRT) works the same way as the CMRT, for minerals outside 3TG. The current EMRT covers cobalt, copper, natural graphite, lithium, natural mica and nickel. Unlike 3TG, these aren’t regulated by the Dodd-Frank Act; companies collect the EMRT as part of their own responsible-sourcing programs.
REACH
REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals — is the European Union’s main chemicals regulation, managed by the European Chemicals Agency (ECHA).
The part customers usually ask about is the Candidate List of Substances of Very High Concern (SVHC). If a product sold in the EU contains a listed substance above 0.1% by weight, the supplier must tell its customers. ECHA adds substances to the list regularly, so a REACH statement always refers to the list as of a certain date.
RoHS
RoHS — Restriction of Hazardous Substances — is a European Union directive that limits ten substances in electrical and electronic equipment:
- Lead, mercury, cadmium and hexavalent chromium
- Two flame retardants: PBB and PBDE
- Four phthalates: DEHP, BBP, DBP and DIBP
RoHS applies to the finished electrical or electronic product, so you’ll be asked for a RoHS statement when your parts go into one.
California Prop 65
Proposition 65 is a California law passed by voters in 1986. Its official name is the Safe Drinking Water and Toxic Enforcement Act. The state keeps a list of chemicals known to cause cancer, birth defects or other reproductive harm, and updates it at least once a year. Businesses with 10 or more employees must give a “clear and reasonable warning” before they expose people in California to a listed chemical.
Metal buyers often get asked about Prop 65 because some elements in common alloys are on the list. For example, nickel (metallic) is listed as a chemical known to cause cancer, and nickel is a main ingredient in 300-series stainless steel and Alloy 625.
A Prop 65 warning doesn’t mean a product is unsafe or breaks a safety standard. It tells people that a listed chemical is present so they can make their own choices about exposure. Learn more at P65Warnings.ca.gov.
Safety Data Sheets (SDS)
A Safety Data Sheet (SDS) explains a material’s hazards and how to handle, store and work with it safely. OSHA’s Hazard Communication Standard requires them, and every SDS uses the same 16-section format. Solid metal strip is generally safe to handle. Cutting, grinding or welding it can create dust or fumes, though, so an SDS for a metal covers those hazards too. Your safety team will usually want an SDS on file for each material that comes into your shop.
Where to get our statements
Our current Conflict Minerals (CMRT), EMRT, REACH, RoHS and Prop 65 statements and our Safety Data Sheets are free to download from our Compliance Document Library, along with our AS9100 / ISO 9001 certificates and other compliance documents. You can download them any time. There’s no need to request them.
These requirements are updated from time to time, so check the date on each statement.
This article is general information, not legal advice. Check your customers’ requirements for the statements you need.