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SIC: 3577 and 3679
Regarding Directives and/or Regulations for RoHS, WEEE,
REACH and Conflict Minerals
following summarizes our commitment to key directives and/or regulatory requirements
that have been put in force by assorted government and non-government
organizations in order to identify and control various elements and
compounds of concern at all stages of a product's life cycle -- from
sourcing raw materials to disposing of finished products.
|RoHS and WEEE
Technobox is committed to meeting RoHS
requirements. The company has been working with our suppliers to
identify environmentally-friendly components and methods that will
satisfy RoHS, starting with the substitution of lead-free components for
existing products. As used herein, lead-free implies compliance with
|In support of the RoHS and WEEE
|Will produce lead-free versions of
existing products, provided all parts used in existing products are
obtainable with reasonable lead times, pricing, packaging, and minimum
quantity requirements from component suppliers.
Will consider redesigning products to adhere to the Directives if an
existing product cannot be directly converted to lead-free
manufacturing. Customers may need to make changes to their
implementation (software, etc.) in order to use such redesigned
Will assign new 4-digit orderable part
numbers for lead-free products. (Part numbers for existing products that
contain lead will remain unchanged.) Changes to internal databases have
been made to accommodate products that contain lead and those that are
May charge a premium
for lead-free products as required to offset additional recurring and
non-recurring costs incurred to support the Directives.
Will eventually require a signed waiver with
each order for products containing lead. Customers assume all
responsibility for the use and disposition of products.
Where possible, new product designs will be manufactured to comply with
the RoHS Directive and likely will not be available in versions that
Will implement inspection techniques to
verify vendor claims that components supplied to Technobox are
lead-free. These techniques may include: chemical analysis,
laser-induced breakdown spectroscopy (LIBS), and vendor’s product
|As the industry as a whole moves toward
RoHS compliance, there will be a transition period during which
Technobox will have to maintain both traditional leaded and lead-free
products to accommodate customers. Technobox will clearly mark RoHS
compliant products with a distinctive label (e.g., CONTAINS NO LEAD or
LEAD-FREE) or an equivalent notice. Internationally recognized icons
will be used as practicable.
|Technobox produces both lead-free and
leaded assemblies and has established processes that assure goods are
manufactured and handled accordingly, including appropriate processing,
hadnling, and labeling. Separate rework
stations are maintained for both lead-containing and lead-free products.
DIRECTIVES 2011/65/EU (RoHS2) and
DIRECTIVES 2002/95/EC (RoHS1) and
best of our knowledge, articles produced by Technobox do not contain any
of the REACH Substances of Very High Concern (SVHC), as specified in the
table below, according to the Candidate list published by ECHA (European
Chemical Agency). Furthermore, the articles are not intended to release
any substances under normal and reasonably foreseeable conditions of
use. We are working with component manufacturers and others to provide a
more complete response to REACH inquiries regarding Technobox products.
This qualified response is being submitted to satisfy your immediate
request for a REACH compliance statement.
Upon request we will provide a qualified response to satisfy an immediate request for a REACH compliance statement. Technobox is not required to register with ACHA
EU Regulation - REACH consolidated version (EN) - 30 August 2017
European Chemical Agency (ECHA) - Substance Identification
European Chemical Agency (ECHA) - Substance Candidate List
The US Securities and Exchange Commission (SEC) issued the final rule implementing Section 1502 in August 2012. The Dodd-Frank Wall Street Reform and Consumer Protection Act includes Section 1502
Conflict Minerals. This section modifies the Securities Exchange Act of 1934. Publicly traded companies are now required to include disclosures relating to conflict minerals in annual filings. The initial reporting period started in January 2013.
Technobox recognizes the importance of supporting responsible
supply chain managment. We are aware of the efforts of organizations
like the Conflict Free Sourcing Initiative (CFSI) and Electronic
Industry Citizenship Coalition (EICC). Technobox can provide, upon request, a Conflict Minerals Reporting Template (CMRT).
For purchased components, we rely on statements of the original component manufacturers and bare board manufacturers, as do the distributors and representatives
from whom we buy. We review statements and/or templates provided by vendors.
We make no attempt to verify identified sources or otherwise investigate
entities and/or persons cited. Technobox does not buy raw materials. /font>
Securities and Exchange Commission - Conflict Minerals - 17 CFR Parts
240 and 249b
United States Public Law 111-203 - Dodd-Frank Wall Street Reform and
Consumer Protection Act
United States District Court for DC - Civil Action No. 13-cv-635 (RLW) -
Ruling Upholding Section 1502 Conflict Minerals of Dodd-Frank
Electronic Industry Citizenship Coalition (EICC)
Electronic Components Industry Association (ECIA) - Conflict Minerals
Organisation for Economic Co-operation and Development (OECD) - Due
The Conflict-free Sourcing Initiative (CFSI) - Reasonable Practices to Identify
Sources of Conflict
Thursday, October 12, 2017 04:00:46 PM
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