RoHS & REACH Declaration

1. RoHS Declaration

We declare under our sole responsibility that the product identified above conforms to the requirements of:

• Directive 2011/65/EU (RoHS 2) of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment, as amended by Commission Delegated Directive (EU) 2015/863 (RoHS 3); and
• The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (UK RoHS).

The product does not contain the following restricted substances above the maximum concentration values tolerated by weight in homogeneous materials, except where a listed exemption applies:

Exemptions Relied Upon (Annex III)

The following EU RoHS Annex III exemptions apply to specific homogeneous materials in the product:

• 6(c) — Copper alloy containing up to 4 % lead by weight (brass threaded heat-set inserts).
• 7(a) — Lead in high-melting-temperature-type solders (lead-based alloys containing 85 % or more lead by weight) (internal die/clip attach within certain semiconductor components, e.g. the P-channel MOSFET).
• 6(a) / 6(b) — Lead as an alloying element in steel / aluminium, where applicable (fasteners), within the permitted limits.

All other materials are RoHS-compliant without reliance on an exemption.

2. REACH / SVHC Declaration

We declare that, to the best of our knowledge and based on the declarations obtained from our suppliers, the product complies with Regulation (EC) No 1907/2006 (REACH) and UK REACH. The SVHC status of the product is declared per component article (ECHA Candidate List), as follows. Articles not listed below do not contain any Candidate List SVHC above 0.1 % by weight; two component articles exceed that threshold and are communicated under Article 33 in Section 3.

• The polymer enclosure is PETG (polyethylene terephthalate glycol-modified; Kexcelled THE K5™ PETG, manufactured by NorthBridge New Material Technology (Suzhou) Co., Ltd.). PETG is not produced from Bisphenol A. Supplier evidence on file: REACH SVHC test report CCI251001762EN-3 (all 251 candidate-list SVHC, list of 2025-11-05, each < 0.1 % w/w — PASS), EU RoHS Certificate of Conformity CCI251001762EN-1CER (IEC 62321 methods), and UK RoHS CoC CCI251001762EN-2CER — Compliance Control Institute (Guangzhou), CNAS-accredited, November 2025.
• The printed overlay label (where fitted) comprises Mativ JetView™ UV polycarbonate film, part 572-000121-010 (signed supplier declaration, 2026-08-21: no Candidate List SVHC above 0.1 % — list of 2026-02-04; RoHS 3 compliant), bonded with 3M™ Adhesive Transfer Tape 9472LE (300LSE) (3M Regulatory Data Sheet v22.02, 2025-08-14: no SVHC above 0.1 % — June 2025 list; RoHS below all MCVs; contains an Annex XVII substance — entries 3, 40, 69 and 75 consulted for downstream conditions of use), printed with Mimaki LH-100 UV-cured ink (manufacturer RoHS declaration, 2026-04-01, covering all Mimaki inks). The cured ink's photoinitiator content is the subject of the first Article 33 communication in Section 3.

3. Article 33 Communication — SVHC above 0.1 % w/w of an article

Pursuant to REACH Article 33(1) (and the equivalent provision of UK REACH), the following Candidate List substances are present above 0.1 % by weight of the component article stated. Neither affects RoHS conformity (Section 1), and no special safe-use measures are required:

• Printed overlay label — UV-cure photoinitiators 2-methyl-1-(4-methylthiophenyl)-2-morpholinopropan-1-one (CAS 71868-10-5) and diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide (TPO, CAS 75980-60-8), conservatively declared above 0.1 % w/w of the label on a documented worst-case assessment. Safe use: the substances are bound in the cured ink film of a bonded exterior label; no exposure arises in normal use, maintenance or foreseeable misuse. Dispose of as WEEE at end of life.
• Brass threaded heat-set inserts — lead (CAS 7439-92-1), present as an alloying constituent of machining brass (covered for RoHS by Annex III exemption 6(c)), above 0.1 % w/w of the insert. Safe use: the inserts are internal to the enclosure and not accessible in normal use. Dispose of as WEEE at end of life.

Consumer requests under Article 33(2) are answered within 45 days via [email protected]. The information above is provided to our EU and GB recipients for the purposes of their own obligations, including any SCIP notification incumbent on EU suppliers of the product.

4. Basis of Declaration

This declaration is issued on the basis of supplier RoHS/REACH declarations, manufacturer material data, and documented internal material assessments held in the product's technical documentation file, collected against the as-built bill of materials. It is self-declared; no notified body is involved.