Absence of Harmful Substances - GADSL, Conflict Materials, Prop 65

Information on GADSL

Global Automotive Declarable Substance List

The Global Automotive Declarable Substance List (GADSL) is a comprehensive list of substances that may be used in automotive components and remain in the vehicle throughout its entire lifecycle. It is the result of global collaboration within the automotive industry, aimed at simplifying communication and information exchange regarding the use of specific chemical substances in automotive parts.

The GADSL categorizes substances as either declarable or prohibited. While not legally binding, it serves as a tool to support legal regulations, such as the recycling of end-of-life vehicles within the European Union under Directive 2000/53/EC.

Our Commitment to GADSL Compliance: At SAB Bröckskes GmbH & Co. KG, we maintain constant communication with our material suppliers regarding the presence of substances listed in GADSL. We collect material declarations from our suppliers for any substances that are either declarable or prohibited. Upon request, we are always prepared to provide the relevant material declarations.

Disclaimer: Please note that ingredient analysis is not part of our incoming or outgoing goods inspection. Our material declarations are based on our current knowledge, the best available information, and supporting documents such as safety data sheets, material declarations, and supplier statements.

Explication on the Use of so Called Conflict Minerals

On January 1, 2021, the European Conflict Materials Regulation (EC 2017/821) came into effect as a response to the Dodd-Frank Act in the United States. Under this regulation, European importers of conflict materials—including tin, tantalum, tungsten (Wolfram), their ores, and gold (3TG)—are subject to due diligence and supply chain oversight. The primary goal is to prevent the financing of violence and human rights violations in conflict-affected and high-risk areas.

Due Diligence and Compliance Requirements The regulation mandates that European importers of 3TG establish a risk management system for raw material procurement, which must be verified through third-party audits.

•  Direct impact (Upstream industry): Companies that import 3TG materials into the European Union and exceed certain quantity thresholds are directly affected by the regulation.

•  Limited impact (Downstream industry): Manufacturers and importers of finished products are not legally bound by this regulation. However, they are encouraged to implement voluntary due diligence measures.

Our Commitment: At SAB Bröckskes GmbH & Co. KG, we maintain written declarations from our sub-suppliers confirming that the materials we receive do not contain conflict metals—particularly tin sourced from the Democratic Republic of the Congo or its neighboring countries.

Prohibition of PBT Materials acc. to TSCA Paragraph 6(h)

In January 2021, the U.S. Environmental Protection Agency (EPA) announced a ban on the production, use, and distribution of five Persistent, Bioaccumulative, and Toxic (PBT) substances, as well as any materials containing these substances.

The following substances are affected:

•  Phenol, Isopropylphosphate (3:1) (PIP (3:1)) – CAS 68937-41-7 (Completely prohibited)

•  Decabromodiphenyl ether (DecaBDE) – CAS 1163-19-5 (Completely prohibited)

•  2,4,6-Tris(tert-butyl)phenol (2,4,6-TTBP) – CAS 732-26 (Restricted to a maximum concentration of 0.3% by weight)

•  Hexachlorobutadiene (HCBD) – CAS 87-68-3 (Completely prohibited)

•  Pentachlorothiophenol (PCTP) – CAS 133-49-3 (Restricted to a maximum concentration of 1% by weight)

These limit values apply to all homogeneous materials contained in the product.

California Proposition 65

The California Safe Drinking Water and Toxic Enforcement Act of 1986, commonly known as California Proposition 65 (CP65), regulates chemical exposure to protect public health. The core requirement states:

“No person shall knowingly expose an individual to chemicals known to cause cancer or reproductive toxicity without providing a clear and appropriate warning in advance.”

This regulation applies to approximately 900 substances identified by the Office of Environmental Health Hazard Assessment (OEHHA) as carcinogenic, capable of causing birth defects, or toxic to reproduction.

CP65 is applicable only to consumer products when there is a risk of consumer exposure to the listed substances. It is specifically relevant to the product’s condition at the time of import into California.