RoHS 3
This page is provided as an official Policy Statement in regard to the European Union’s issuance of directives 2002/95/EC and 2000/53/EC, which have complicated the use of hexavalent chromium, which is commonly used as the chromate finish for electroplated components. We have studied the regulations carefully and can offer the following compliance statement:
“For parts purchased after December 1, 2006, Bay Fastening Systems certifies that to the best of its knowledge and within commercially practical means of verification, all zinc clear fasteners manufactured by our suppliers and marked with the certification seal shown below comply with the European Directive for Restriction of Hazardous Substances (hereinafter referred to as “Directive,”) also known as RoHS3. This certification may be amended, modified, or withdrawn at the sole discretion of Bay Fastening Systems at any time, at which time all subsequent parts marked as described herein shall comply with the then applicable Bay Fastening Systems RoHS3 certification standard.”
Bay Fastening Systems warrants that Products manufactured by our suppliers are produced according to generally accepted practices of companies manufacturing industrial fasteners. Unless otherwise stated in a mutually agreed purchase order contract, standard commercial tolerances apply. This warranty is made in lieu of all other warranties, expressed or implied, including warranties of merchantability and fitness for a particular purpose.
This warranty is void unless Customer inspects the Products when received and notifies Bay Fastening Systems of any rejections based on non-conformity to specifications of, or defects in the Products within 30 days receipt thereof by Customer. This warranty does not apply to any Products that are reworked or subjected to any additional processing by Customer.
This is a limited warranty for the following reasons:
Supplier verification – The warranty is based largely on the representations and warranties of Bay Fastening System's suppliers. Bay Fastening Systems has surveyed, and will continue to survey, the operations and contractors of its suppliers, where practical, so as to determine the likelihood of continued compliance.
Testing – The international standard for measuring hexavalent chromium in chromate conversion coatings is ISO 3613. This specification states that proper units of measurement are ug/cm2. The European Union does not recognize this standard of measurement. The Directive calls out that chromium must be less than .1% of the weight of the part. Because coatings are only 10-500 nm thick, rounding errors will nearly always guarantee a passing result. Testing is therefore not reliable if conducted according to European directives.
Inventory Control – Many suppliers and contractors had legacy stocks that may or may not comply with the Directive. Short of reworking an entire industry of inventory, there can be no certainty that nonconforming parts can enter the market, especially among offshore suppliers, where internal controls are lax.
Application – The Directive applies to “electrical and electronic equipment” is defined as equipment that is dependent on electric currents or electromagnetic fields in order to work properly and for equipment generation. The Directive describes a list of products. We do not know of the precise use of our products, nor do we make any representation as to the intended use. It is impossible to therefore guarantee compliance to the Directive in each and every circumstance. The normal use of many of Bay Fastening System's products fall outside the List of Products in the Directive.
Conflict with other standards – Compliance with RoHS regulations may compromise the salt spray and performance characteristics of the part such that while the part conforms to the Directive, it may be compromised to other regulations.
2015/863 EU (RoHS3) – was published in 2015 by the EU. This introduced four additional restricted substances (phthalates) to extend conditions of compliance for an introduction date of July 22, 2019. The four additions to restricted substances Bis(2-Ethylhexyl) phthalate (DEHP):< 1000 ppm, Benzyl butyl phthalate (BBP): < 1000 ppm, Dibutyl phthalate (DBP): < 1000 ppm and Diisobutyl phthalate (DIBP): < 1000 ppm. Bay Fastening Systems statements of conformity encompass the directives of these RoHS 3 additions.
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THE ONLY WAY TO GUARANTEE COMPLIANCE WITH THE DIRECTIVES IS TO REWORK ALL OF THE STOCK AT BAY FASTENING SYSTEMS, AS WELL AS ALL STOCK OF ALL OF ITS SUPPLIERS, AND THEN TO TEST FOR THE PRESENCE OF HEXAVALENT CHROMIUM AND OTHER LIMITED SUBSTANCES, FOR EACH AND EVERY INCOMING LOT. THIS IS NOT DEEMED COMMERCIALLY PRACTICAL AND WE KNOW OF NO FIRM THAT HAS ENGAGED THIS ACTION. ADDITIONALLY, THE TESTING PROCEDURE ITSELF CAN PRODUCE FALSE RESULTS.
The following Bay Fastening Systems products are exempt from this policy and warranty statement:
Zinc yellow fasteners and components
Any part used in an application where the Directives do not apply
Please submit questions for clarification of this important policy statement by visiting our Contact Us Page.