|RoHS||WEEE||REACH||California Proposition 65||Conflict Materials Policy||Counterfeit Electronic Part Detection Policy|
Acromag Inc. is a company that is very sensitive to the environment. We strive everyday to improve our world and leave it better for future generations. We are interested in the initiatives lead by the European Union (EU) and plan to be an active participant in supporting their programs.
Acromag is a leader in industrial I/O for process monitoring and control. Some products manufactured by Acromag comply with the following RoHS (Restrictions on Hazardous Substances) EU directive (consult factory for details):
EU Directive 2011/65/EU (RoHS 2 Recast, June 8, 2011)
Acromag Incorporated is aware that the 2011/65/EU (RoHS) Directive is limiting the use of certain hazardous substances in electrical and electronic equipment.
The following materials are not to exceed the legal limits:
Lead (PB, see exemption)
Chromium (Cr VI)
Polybrominated biphenyl (PBB)
Polybrominated diphenyl ethers (PBDE)
The following statement regarding conformity of our products to the EU Directive 2011/65/EU (RoHS) is based on our actual research and inquiries with our suppliers:
Acromag is moving towards 100% usage of lead-free soldering metals, unless specific customers or technical requirements need lead-containing soldering materials.
Acromag can also upon customer request provide requested products using lead-free soldering metals.
The RoHS status of many of our products are listed on data sheets, in catalogues, or in our product data base.
"Waste of Electrical and Electronic Equipment" (WEEE) is an initiative to control the disposal of electronic equipment sold in the European Union.
All Acromag equipment shipped to the EU member states since the date of the directive is marked with the Wheeled Bin mark.
Acromag has a new no-charge “take-back” service that gives customers the option to return used Acromag hardware products to be recycled. Products covered by the WEEE directive shipped to EU member states may be returned to Acromag at no charge. Acromag ensures that the products are properly recycled. This service helps reduce the impact on landfills and other disposal sites and provides an environmentally safe end-of-life solution.
To send hardware products to be recycled, customers can contact Acromag to obtain an RMA number and Acromag staff will reply with information on how to ship the product. There is no charge for the disposal but the customer must pay for shipping. After the product is returned, Acromag also can provide a Certificate of Custody change upon customer request.
Product “take-back” regulations are constantly evolving. Current regulations do not require Acromag to take back its products. However, by launching a WEEE take-back program, Acromag demonstrates a commitment to the environment and its customers by helping them dispose of Acromag products responsibly.
The Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) is a European Community Regulation related to the safe use and identification of chemicals (Regulation (EC) Number 1907/2006). REACH entered into force on June 1, 2007 with the aim of improving the protection of human health and the environment through better and earlier identification of the intrinsic properties of chemical substances. REACH was aimed at streamlining and improving former European Union chemical legislation by replacing approximately 40 individual pieces of legislation and harmonizing with the remaining legislation. The new legislative framework under REACH shifts responsibility for the control and safety of chemicals from government authorities to industry and created the European Chemicals Agency to act as a central coordinator.
Acromag is an importer of articles as defined in the Regulation. However, registration requirements under Article 7 of REACH do not currently apply to articles imported by Acromag into the European Union because:
- Substances are not present in the articles in quantities totaling over one ton per year
- Substances are not intended to be released under normal or reasonably foreseeable conditions of use.
Acromag is not categorized as a downstream user under REACH because it does not use the substances in the course of its professional activities and therefore has no applicable requirements under Article 37 of REACH. Acromag will continue to monitor REACH developments and will comply with any applicable requirements.
As Substances of Very High Concern (SVHCs) are added to Annex XIV of the Regulation (Authorization List), Acromag will assess whether both of the following conditions are met:
1. The substance is present in the articles in quantities over one (1) ton per year
2. The substances are present in Acromag devices above a concentration level of 0.1% w/w
Acromag shall comply with the requirements of Article 7(2) and Article 33 of the Regulation, as necessary. For informational purposes, Acromag has contacted its material and manufacturing vendors to verify that Acromag devices do not contain SVHCs. (Note that several vendors have not established a REACH compliance statement yet. Acromag is surveying vendors to determine their status and will continue to do so.)
Further information on REACH can be obtained at: http://echa.europa.eu/reach_en.asp
Conflict Materials Policy
Acromag Conflict Material Policy
There has been increased awareness of violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region”, which is situated in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries. Companies around the globe have been requested to practice reasonable due diligence with their supply chain to assure that specified metals are not being sourced from mines in the Conflict Region, which is controlled by non-government military groups, or unlawful military factions.
Acromag supports this initiative and has either obtained, or is in the process of obtaining, information from our current metal suppliers concerning the origin of the metals that are used in the manufacture of Acromag products. Based upon information provided by our suppliers, Acromag does not knowingly use metals derived from the Conflict Region in our products.
Suppliers of metals used in the manufacture of Acromag products (specifically gold, tin, tantalum, and tungsten) must demonstrate that they understand the conflict minerals laws and will not knowingly procure specified metals that originate from the Conflict Region.
All Acromag suppliers of any fabricated materials such as Printed Circuit Boards, Metalwork, and Transformers have been surveyed and reported to not be sourcing materials from these regions.
Supplier Guidelines: Suppliers must review and agree in writing to the following conflict minerals contractual language:
• Supplier represents and warrants that it is in full compliance with conflict minerals laws, including, without limitation, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 as it may be amended from time to time and any regulations, rules, decisions or orders relating thereto adopted by the Securities and Exchange Commission or successor governmental agency responsible for adopting regulations relating thereto (collectively, (“Dodd-Frank Section 1502”).
• Supplier must cooperate with Acromag to make available to Acromag and/or its agents, full material declarations that identify the sources of and amount of all substances contained in the Products. Unless Acromag specifically agrees in writing that a particular Product may contain a particular material, Supplier will also provide a statement that the Products do not contain various materials at issue in applicable laws and regulations.
• Supplier must declare each Product’s compliance to all applicable hazardous material legislation and identify any substances that are banned or must be declared under applicable laws. In addition, Supplier will make available any documentation that supports the declaration. Without limiting the generality of the foregoing, Supplier agrees to disclose to Acromag, upon Acromag’s request, to the extent known or discoverable by Supplier following inquiry, the original source of all minerals contained in the Product.
• If Supplier does not know the original source of the minerals, Supplier agrees to cooperate with Acromag, including disclosing from whom Supplier purchased the minerals and urging others to disclose such information, so that the original source of minerals can be accurately determined and reported. Supplier shall comply with all laws regarding the sourcing of minerals, including, without limitation, laws prohibiting the sourcing of minerals from mines controlled by combatants and Dodd-Frank Section 1502.
• Without any further consideration, Supplier shall provide such further cooperation as Acromag may reasonably require in order to meet any obligations it may have under conflict minerals laws, including, without limitation, under Dodd-Frank Section 1502.
As a leading global company in the development of instrumentation, Acromag is committed to ensuring the safety, health and protection of people and the environment worldwide. We promote these principles in our global business practices and our code of conduct.
Acromag Counterfeit Electronic Part Detection and Avoidance System
Acromag Counterfeit Electronic Part Detection and Avoidance System
As a supplier to the Department of Defense DOD and the prime contractors, Acromag understands that the responsibility to insure the integrity of the electronic components used on our products is all of our responsibility. Even though Acromag supplies COTS commercial off the shelf products, every effort is made to insure that counterfeit or inferior parts do not make it into our products.
Our Counterfeit Electronic Part Detection and Avoidance System is based on DFARS 246.870-2(b) and 252.246-7007(b). The Key parts of the program are.
1. Training of Personnel
a. All personnel must have documented records of training on this program.
2. Use only Trusted Suppliers
a. Original component/equipment manufacturers OCM/OEM
b. Authorized/franchised distributors
3. Using other suppliers (Independent Distributors)
a. Validate that the Distributor meets basic standards.
• Distributors who maintain a third party quality management system and are a member of one or more of the following trade organizations and have implemented one of the following control programs:
AFDEC-Association of Franchised Distribution of Electronic Components
CEDA-China Electronics Distributor Alliance
COG-Components Obsolescence Group
ECIA-Electronic Component Industry Associates
ECSN-Electronic Component Supply Network
ERAI-Electronic Resellers Association International
GIDEP-Government Industry Data Exchange Program
IDEA-Independent Distributors of Electronics Association
SIA-Semiconductor Industries Associates
TECS-Chinese Reliability Electronic Components Supplier
IDEA-STD-1010-acceptability of electronic components distributed in the open market
CCAP-101-counterfeit component avoidance program
AS5553-counterfeit electronic parts: avoidance, detection, mitigation, & disposition
b. Obtain Traceability records including chain of custody from the OCM to the Independent Distributor.
c. Inspection and Testing of Electronic Parts. (Used only as a second level of validation when the chain of custody is broken)
d. Notify any affected customers and get approval before building any products.
4. Secure Process for electronic part traceability. DFARS 252.246-7007 ( c) (4) IUID.
5. Flow down to any Subcontractors.
a. Any sub-contractors must conform to the same policy as Acromag.
6. Methods to Identify Counterfeit Parts.
7. Quarantining and reporting Counterfeit Parts.
8. Keep informed on counterfeit information and trends.
9. Review the Government – Industry Data Exchange Program for the latest information.
10. Control of Obsolete Parts Policy
a. Often, OCMs discontinue selling key parts needed for products.
b. Parts obtained to meet life-time buy obligations must meet stringent validation guidelines.
c. Any customers affected will be notified before products are built.
Acromag “California Proposition 65” position statement - download pdf
The following is Acromag position statement on California’s Safe Drinking Water & Toxic Enforcement Act of 1986. The Act, commonly known as Proposition 65 (Prop 65), establishes a list of chemicals which the State of California risk assessment process has determined to present a risk of cancer, birth defects or other reproductive harm.
As part of “regular” electronic assembly, Acromag products may contain trace amounts of lead from solder and components. Most assemblies are in enclosures and protect the user from contact. Since Acromag is uncertain on how much exposure levels of lead and lead components or any other chemicals there is without testing, Acromag will state the following.
Acromag does not intentionally add any of the remaining materials on the chemical list.
WARNING: Acromag products can expose you to chemicals including lead and lead components,which is known to the State of California to cause cancer and birth defects or other reproductive harm.
For more information, go to www.P65Warnings.ca.gov.
Human safety is Acromag’s number one concern. We welcome all environmental concerns and will work every day to make our products the safest they can be. We will continue to monitor the California Proposition 65 for any new chemicals or information to keep our customers informed.
September 17, 2018