Conflict Minerals Policy Statement
As required by the Conflict Minerals provisions under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 Section 1502, Flambeau continues to work proactively with all of our qualified suppliers to ensure our products do not contain any Conflict Minerals.
Flambeau supports the efforts to end human suffering and the environmental impact associated with mining of certain minerals from an area described as the "Conflict Region" located in the eastern portion of the Democratic Republic of Congo (DRC) and surrounding countries. Flambeau is committed to meeting legislative and regulatory requirements that seek to eliminate these issues.
Tracing the origin and chain of custody of "conflict minerals" (tin, tantalum, tungsten and gold) throughout a global supply chain is a complex process. This can only be accomplished with the cooperation and support of a vast number of industries, and public and private stakeholders. Flambeau continues to work proactively with its suppliers, industry groups and other stakeholders to develop and implement policies and systems to reduce the risk of minerals in our supply chain coming from mines that finance or benefit armed groups in the DRC region.
Flambeau does not knowingly procure any product with tin, tantalum, tungsten or gold that originates from the Conflict Region. In addition, we expect our suppliers and their suppliers to acquire minerals only from responsible sources that do not violate labor or human rights.
RoHS Regulation Policy Statement
We at Flambeau Inc. share your concern for product safety and appreciate your interest in our program for compliance with EU Directives 2011/65/EU and 2015/863/EU, otherwise known as EU RoHS for 10 substances. To ensure that our customer-facing requirements are fulfilled, we actively engage our raw material and component suppliers to identify any RoHS substances in our products that would impact our customers’ ability to meet their business obligations and importation requirements for European market access.
Our compliance processes include continuous engagement with various stakeholders in our supply chain to rule out any uncertainty regarding the presence or non-presence of listed substances in our products.
As you are undoubtedly aware, the EU RoHS Directive is dynamic, with exemptions periodically added and repealed. Consequently, Flambeau Inc. will conduct ongoing due diligence to support the subsequent layers of our supply chain in meeting their respective business and reporting requirements associated with this directive. With these ongoing efforts, we are committed to proactively informing you of any changes to the compliance status of our products.
REACH Regulation Policy Statement
(Registration, Evaluation, Authorization and Restriction of Chemicals)
This statement confirms that Flambeau Inc. is aware of the requirements of REACH Regulation (EC) No 1907-2006 of the European Parliament and of the Council of 18 December 2006. As of 16 July 2019, the ECHA had identified 201 "candidate" Substances of Very High Concern (SVHC).
It is Flambeau's intention to comply with the requirements of this regulation as it applies to producers of Articles. We continue to work with our suppliers to identify if any SVHC components are contained in the materials procured for use in manufacturing our products.
What is an article?
The meaning of an "article" is defined in Article 3 (3):
Article: means an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition;
The function of an article is determined by the intended use and purpose of the article as this is identified by the supplier of the article. The function is also determined according to the expectations determined by the buyer of the article.
Duty to communicate information about the chemicals in the products to the ECHA applies according to Article 7 of REACH.
Article 7 (1) requires Producers and Importers of products to register with the ECHA chemical substances that are intentionally released from the products during use.
Article 7 (2) requires Producers and Importers of products to notify the ECHA of the content of Substances of Very High Concern (SVHC’s) if the concentration of SVHC is above 0.1” weight by weight (w/w) and the total amount put on the EU market by the subject company is more than 1 ton per year.