EC Regulation 1907/2006 Concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
REACH Enforcement Regulations 2008

The regulations require all ‘substances’, which includes all metals, to be registered under REACH. It is important, however, to note that REACH Regulations distinguish between ‘substances’ and ‘preparations’ (which are covered by REACH) and ‘articles’ (which are not governed by REACH and do not require registration).

Our standard semi-finished products in aluminium, aluminium alloys, stainless steel and copper alloys such as sheet, plate, tube, bar and extrusions, are all classed as ‘articles’ and do not need to be registered. Billets, blooms, concast slabs and machined ingots are all also classed as ‘articles’ and do not need to be registered. However, certain types of ingots such as ‘as cast’ ingots, rolling ingots and ingots produced for extrusion processes, are classed as ‘preparations’ and would, therefore, need to be registered.

For the reasons stated, we can confirm that products supplied to you from our standard range are classified as ‘articles’ and, therefore, do not need to be registered under REACH.

A copy of the production diagrams for aluminium and stainless steel is available on request, to help clarify the definitions of ‘substances’, ‘preparations’ and ‘articles.’

Due diligence has been carried out on our current supplier base to establish that ‘substances’ and ‘preparations’ which require registration under REACH have been registered or confirm the absence of such chemicals. For this reason, as far as reasonably practicable, we can confirm that majority of our standard semi-finished products detailed above, don’t contain any of the chemicals listed in the current Candidate List of Substances of Very High Concern (SVHC) 19th January 2021 with the exception of the declaration below:

Additionally, where a grade of material is ordered by a customer where the British, European or International Standard covering the grade requires a deliberate addition of one or more of the substances in order to comply with the standard/grade requirements. In this case, the material will contain a value of each substance in line with the standard requirements:

We declare that some Aluminium & Copper/Brass articles that we sell have the chemical substances, indicated in Attachment XIV of the Reach Regulation as amended on 19/01/2021, present in quantities above 0.1% are:

Substance: Lead
CAS/EINICS: CAS 7439-92-1 / EINICS 231-100-4
Date of inclusion: 27-06-2018
Hazard: Toxic for reproduction Cat. 1A
H360FD - May damage fertility. May damage the unborn child
H362 - May cause harm to breast-fed children

The "Candidate list" of SVHC substances is periodically updated by ECHA and is accessible on: https://echa.europa.eu/candidate-list-table

It is possible that you may purchase other products or metal types from us that are outside of our normal stock range. In these circumstances, we would need to check with the producer that these specific products do not contain any of the listed Substances of Very High Concern and we will advise you accordingly.

We trust that this information clarifies our position regarding compliance with the REACH Regulations. If you have any questions or want to check on any specific product that you are unsure about, please contact us.

This Policy will be updated on amendments to the legislation and as a minimum annually.

Please note that this policy specifically excludes: All Plastics and All Composite Panels.


METAL PROCESSING - SHOWN FOR ALUMINIUM PRODUCTS AS EXAMPLE
The example of aluminium processing is included to show the transition point in the processing of bauxite to final aluminium products. It should be noted that the processing of other metals (for example iron / steel) may show different transition points. The following figure shows the different processing stages and the respective status of the raw material.

PLEASE SEE ATTACHED FACT SHEET ON ALUMINIUM AND HEALTH ISSUED 9TH FEBRUARY 2018 BY THE ALUMINIUM REACH CONSORTIUM AND INTERNATIONAL ALUMINIUM INSTITUTE.