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Delphi RoHs and Reach statement

Date: 17 July 2014 

Subject: REACH and RoHS - Certification / Notification

 

Dear Ralf Dietrich, Power and Signal Group

 

This letter is to respond to your request for specific information concerning products Delphi supplies to you. Products are defined as substances, preparations, or articles according to the European Union Regulation EC 1907/2006. Delphi Automotive and its affiliates ("Delphi") are committed to taking the necessary steps to ensure compliance with our European Chemicals Regulations REACH (Regulation European Community 1907/2006) obligations and to providing information on lead, mercury, cadmium, hexavalent chrome, polybrominated biphenyls, and polybrominated diphenyl ether substances per Directive 2011/65/EU of the European Parliament and of the Council on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). Delphi understands its REACH obligations and has formed a global team to implement our internal business process to ensure applicable REACH compliance for substances, preparations, and articles used or manufactured in the EU and for those imported into the EU by Delphi or its legal representatives. We have also implemented a continuous process for gathering information concerning our wide array of products as necessary to assist our suppliers and customers in complying with their registration and notification obligations under the EU REACH regulation. In general, Delphi is a supplier of articles, and not a supplier of substances and preparations.

Just as you rely upon Delphi to provide information on the materials, parts, and subcomponents we supply you, Delphi relies upon its suppliers in gathering this information. The accuracy and completeness of our information depends upon the reporting of our suppliers, and the many cascading tiers of part and material manufacturers that ultimately feed the vehicle industry at large. Delphi is obligating its suppliers to provide complete and accurate data, and Delphi has gathered and treated the information with due care and reasonable diligence.

To the best of our knowledge, and per the Automotive Industry Guideline, www.acea.be/reach, substances and preparations used in the articles supplied to our customers do not intentionally release and are integral to the functioning of the part, and therefore are not subject to REACH registration. At this time, Delphi has no intention of registering substances in articles. In addition, Delphi will rely on the substances of concern data reporting process via the International Materials Data System (IMDS) and the Global Automotive Declarable Substances List (GADSL www.gadsl.org) to identify and notify you of the substances of very high concern (SVHC) contained in the articles supplied to you. There is wide automotive industry acceptanceof the use of already existing Material Management Systems (e.g. IMDS, CAMDS, MACSI…) to

fulfil Art. 33obligations. There are also processes in place updating the GADSL with ECHAdossier potential SVHC substances as they apply to the automotive industry.

Delphi will notify you of the SVHC content of our products utilizing IMDS submissions, or equivalent, with updates and resubmissions as needed. If you have products that do nothave an IMDS submission received from Delphi, please let us know and we will strive tocomplete that request in a timely manner.

We are closely monitoring the addition of substances to the REACH Candidate List and Annex XIV. Analysis of our products and suppliers data is on-going to assure that we continue to be in compliance with the European Chemicals Regulations REACH. Delphi’s strategy will be to pursue the replacement of substances not receiving authorization by ECHA in a timely manner prior to the “sunset dates.” For applications/uses that do receive authorization, we will work with suppliers, and will be in contact with all customers prior to the “sunset dates”. Prohibited substances will be investigated for elimination if they are used in a prohibited application.

Based upon the balance of the information provided from our suppliers to date and to the best of Delphi’s knowledge, the part numbers in Appendix A are in compliance with RoHS Directive 2011/65/EU and its annexes and do not contain any of the SVHCs in the Candidate List of the European Chemicals Regulations REACH (Regulation European Community 1907/2006) above the substance concentration threshold of 0.1% (w/w) in the article as supplied. Furthermore, they are in compliance with Annex XVII amendment COMMISSION REGULATION (EC) No 552/2009 of REACH. 

Delphi’s primary global REACH /SVHC contact is:

Brenda Baney

Product Design for Environment/Global SOC Manager

Delphi

Delphi Corporation

4068 Overlook Trail Dr.

Roanoke, VA 24018

USA

Telephone: +1.(540) 206 2379

Fax: +1.(540) 206 2379

 

e-mail: Brenda.B.Baney@delphi.com

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