Statement from Roto Frank AG on Regulation (EC) No 1907/2006, hereinafter referred to as REACh:
Under REACh, we are a downstream user and are therefore in the same position as our customers. We use some chemical substances in our manufacturing processes, but do not produce or modify any chemicals. The obligation to pre-register and register substances is solely the responsibility of the manufacturers and importers of substances.
Article 33(1) of REACh obligates the supplier of a product which fulfils one of the criteria of Article 57 and contains a substance listed on the ECHA candidate list in accordance with Article 59(1) in a concentration above 0.1% weight by weight (w/w) to provide the purchaser of the product with the information they have available that is sufficient to allow safe use of the product, but at least the name of the substance in question. We will, of course, fulfil this obligation in accordance with regulations in applicable cases in order to guarantee for our customers safe use of our high-quality products that they are used to.
For our product groups for window technology with Tilt&Turn and sliding hardware, door technology and equipment with E-Tec, handles, glazing blocks and folding shutters, we can confirm that, to the best of our knowledge, these products do not contain any substances from the REACh candidate list (version dated 27th June 2018) in concentrations above 0.1% weight by weight (w/w) with the exception of lead, CAS no.: 7439-92-1 EC/list no.: 231-100-4.
In our window technology and door technology equipment and products, we process metal alloys that may, in some cases, have a lead content above 0.1% weight by weight (w/w). Lead, as an alloy element, is bound and will not be released when the product is used as intended. Please follow our installation instructions to ensure safe use.
As far as we are aware, there are at present no other information or concerns which would require us to perform sample analysis on a case-by-case basis as part of our objective duty of care and risk assessment. We will, of course, inform you of new findings, information or other changes in this regard in line with legal regulations.
This declaration applies exclusively to the products supplied by us. It does not cover modifications to products as part of further processing.
Roto Frank AG
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