Compliance & Material Conformity

The ongoing conflict and extreme violence in the Democratic Republic of the Congo (DRC) are fueled in part by the trade in “conflict minerals,” which are defined as tantalum, tin, tungsten, and gold, or their derivatives.

GEVAG, together with our partners in the supply chain, will take responsible measures to ensure that conflict minerals are not sourced by GEVAG or our supply chain partners in a manner that directly or indirectly benefits armed groups responsible for serious human rights violations in the Democratic Republic of the Congo or neighboring countries.

GEVAG will not knowingly use metals in its products that originate from conflict regions.

GEVAG is also working with stakeholders to prevent the unintended consequence of a massive economic withdrawal from the DRC region, which would cause severe hardship for millions of Congolese workers employed in legitimate mines.

GEVAG is committed to complying with the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502, which requires companies to investigate the origin of conflict minerals in their supply chains and to report on the due diligence they conduct to determine whether their purchases have supported armed groups in the Democratic Republic of the Congo.

GEVAG has incorporated the principles of this guideline into our supplier contracts and will work with suppliers to increase transparency in the supply chain.

GEVAG expects its suppliers to comply with our requests to provide declarations and to conduct due diligence regarding the origin of any conflict minerals in the products they supply to us.

GEVAG has established the measures that can be taken against companies that are not conflict-free and/or do not comply with disclosure requests (reduction of supply volumes, exclusion of the supplier, increased awareness-raising, etc.).

Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (“RoHS Directive”) has been continuously updated since its entry into force in 2011, including by Commission Delegated Directive (EU) 2015/863 (“RoHS III”) of March 31, 2015, and most recently by Commission Delegated Directive (EU) 2025/2364 of September 8, 2025.

In Germany, the directive is implemented through the Electrical and Electronic Equipment Substances Ordinance (ElektroStoffV). According to this regulation, electrical and electronic equipment—including cables and replacement parts—may not be placed on the market if it contains more than 0.1 percent by weight of lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, or DIBP, or more than 0.01 percent by weight of cadmium per homogeneous material.

Exemptions apply to certain substances and uses. For example, the exemptions listed in Annex III apply to lead as an alloying element:

*) RoHS exemptions for lead-containing components do not apply to electrical and electronic equipment intended for the general public if children could put it in their mouths. Components containing lead must be kept out of the reach of children unless there is evidence of compliance with the limit values for lead release and protective coating. The responsibility for further assessment of product safety lies with the company that processes the respective assembly.

Fasteners, as such, do not fall within the scope of the Directive. The situation may be different if they are components of the electrical and electronic equipment specified in the Directive.

As a distributor and/or importer of products (screws, nuts, small parts, etc.), GEVAG takes its obligations under the REACH Regulation (EC 1907/2006) very seriously.

With regard to Annex XVII of the REACH Regulation, we would like to inform you that the products supplied do not contain any of the listed substances, and that the products are not typically used in accordance with the restriction conditions set forth in Annex XVII for the respective substance.

For all products containing substances of very high concern (SVHCs) as defined in the REACH Candidate List in concentrations exceeding 0.1 percent by mass, Article 33 of the REACH Regulation requires that this information be communicated throughout the supply chain. In this context, we ask our suppliers to provide us with the necessary information.

Below is an update on the current situation:

Chromium trioxide (chromium(VI) oxide or chromium trioxide)

This substance is present in yellow, black, and olive chromate coatings, as well as in the Dacromet zinc flake coating. However, due to the thin layer thickness of the chromate coating, its proportion in the product (or sub-product) is significantly less than 0.1 percent by mass. Accordingly, there is no obligation to provide information regarding this under Article 33.

Lead (CAS No. 7439-92-1, EC No. 231-100-4)

Lead may be present as an alloying element in machine components at concentrations exceeding 0.1 percent by mass, based on the respective product, in the following strength classes/materials:

• Strength classes: 4.6, 4.8, 5.8, 6.8, 04, 4, 5, 6, 14H, 17H, 22H, 33H, 45H
• Free-cutting steel
• Copper alloys (e.g., brass, bronze)
• Aluminum Alloys

The classification of lead as toxic to reproduction does not mean that materials containing lead pose an immediate danger. However, processing these materials involves health hazards. Furthermore, the potentially toxic properties of lead have been known for years and must be taken into account accordingly. In addition, the relevant occupational safety and waste disposal regulations must be followed.

Background / Proposal to Restrict PFAS:

On September 25, 2023, the European Chemicals Agency (ECHA) concluded the consultation phase on the PFAS restriction proposal (official name: ECHA Restriction Dossier) and initiated the evaluation by the scientific committees (including the RAC Committee). A revision of the comprehensive approach is highly likely, and the lack of a risk-based approach to date has also been heavily criticized by industry associations, including WSM.

The main uses of PFAS include fluorinated gases (e.g., firefighting foams, refrigerants), textiles (e.g., outdoor clothing), food contact applications (e.g., pizza boxes), the transportation industry (chemical transport), and also, for example, in lubricants. The use of PFAS in steel and metal processing occurs in a very narrow area of metal plating with highly specialized technical specifications (resistance to temperature, pressure, radiation, and chemicals) in various finishing processes.

Some current facts and findings to date from the ECHA assessment:

The authorities submitting the dossiers and ECHA are currently using a so-called “sector-by-sector” approach to gain an overview of the record number of over 6,000 submissions; the restriction dossier is currently being revised. Significant relevant environmental impacts of PFAS arise from the PFAS manufacturing process and from leaching during landfilling. Leaching during the operational phase of technical products (e.g., surface coatings) plays a negligible role. During the incineration phase (e.g., steel recycling processes) at temperatures above 1,100 °C, PFAS are destroyed.

The European Commission, as the contracting authority, notes that essential industrial uses of PFAS are crucial for, among other things, the Green Deal (ECHA Progress Update, November 2024). It is foreseeable that the use of PFAS in many consumer products (e.g., cosmetics, food contact materials, and casual clothing) will be banned. Furthermore, there are no substitution options for many technically demanding and critical PFAS applications.

Conclusion and Implications for Our Products:

There is currently no legal obligation to report or provide information. The decisive factor in the future will be whether a restriction or ban on PFAS in industrial products is implemented at all. Internally, we have voluntarily stepped up our efforts regarding PFAS in our business processes (e.g., development, procurement, production) and are currently assessing the extent to which our production and products are affected.

We ask for your understanding that, in accordance with our legal compliance policy, we ensure compliance with the relevant environmental regulations; however, we do not yet have any specific information regarding PFAS.

Regarding “Regulation (EU) 2019/1021 of the European Parliament and of the Council of June 20, 2019, on Persistent Organic Pollutants” (EU Regulation 2019/1021/EU), known by its short title as the EU POP Regulation (where POP is the English acronym for Persistent Organic Pollutant), we would like to make the following statement:

• In accordance with our corporate and environmental policy, compliance with the POP Regulation and the associated restrictions and bans on substances is mandatory for us and an integral part of our General Terms and Conditions (GTC).
• The substances covered by the regulation are not relevant to the steel and metal processing industry and are not used in our manufacturing process.
• Persistent organic pollutants (POPs) are organic substances that remain in the environment, accumulate in living organisms, and pose a threat to our health and the environment. They can be transported across international borders through the air, water, or migratory species.
• Chemicals identified as POPs include pesticides (such as DDT), industrial chemicals (such as PCBs—polychlorinated biphenyls, which were widely used in electrical equipment), and unintended byproducts resulting from industrial processes, decomposition, or combustion (e.g., dioxins and furans).
• POPs are regulated worldwide by the Stockholm Convention and the Aarhus Protocol. These legal instruments are implemented in the European Union through the POPs Regulation.
• Our company is NOT a manufacturer, distributor, or user of the substances restricted or prohibited under the POPs Regulation as listed in Annex I and Annex II.
• We systematically monitor developments regarding the restrictions and bans under the POP Regulation to ensure legal compliance and a smooth transition.
• We require our suppliers to comply with the POP Regulation to ensure that substance bans are observed throughout the supply chain. Our General Terms and Conditions of Purchase include provisions designed to ensure that we adequately fulfill our due diligence obligations regarding substance policy and the POP Regulation.
• As part of our product development and manufacturing processes, we have implemented internal procedures and controls over the years to ensure and document this so-called material compliance of our products.

Under the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) assesses potential risks posed by new and existing chemicals in order to prevent or reduce harmful environmental impacts.

On June 22, 2016, the Frank R. Lautenberg Chemical Safety for the 21st Century Act was enacted as an amendment to TSCA. In 2016, the EPA identified five PBT chemicals for expedited action that meet the criteria of Section 6(h) of TSCA and published a proposed rule in 2019. The EPA published the final rules on January 6, 2021.

According to these regulations, the following five substances may no longer be sold as substances or as substances in products:

• 2,4,6-Tris(tert-butyl)phenol (2,4,6-TTBP), CAS No. 732-26-3
• Hexachlorobutadiene (HCBD), CAS No. 87-68-3
• Pentachlorothiophenol (PCTP), CAS No. 133-49-3
• decaBDE (decabromodiphenyl ether), CAS No. 1163-19-5
• Isopropylated phenol phosphate (PIP), CAS No. 68937-41-7

To ensure that our products always comply with current regulatory requirements, we review them regularly and maintain close contact with our suppliers.

We hereby confirm that our products do NOT contain any of the substances listed above, in accordance with Section 6(h) of the TSCA.