Material Compliance and Product Conformity

01Our role in the supply chain

A1-ESD Equipment GmbH is a trading company. Under the applicable product and substance legislation we act as a distributor. We do not manufacture articles, we do not assemble them and we do not modify them.

Information on material composition is available to us only to the extent that manufacturers provide it. We pass this information on unchanged. We do not carry out our own analytical testing.

02REACH and substances of very high concern

Regulation (EC) No 1907/2006

The European Chemicals Agency ECHA maintains the Candidate List of substances of very high concern (SVHC). It is updated twice a year and currently holds 253 entries, as of 4 February 2026.

Information to business customers

If an article contains a Candidate List substance in a concentration above 0.1 percent by weight, we inform our business customers under Article 33(1) REACH without being asked and on an article specific basis. The notifications we receive from manufacturers are decisive here. Unless a manufacturer notifies us otherwise, we assume that the articles we supply do not exceed the threshold.

Information to consumers

Under Article 33(2) REACH consumers are entitled to ask whether an article contains a Candidate List substance above 0.1 percent by weight. We provide this information free of charge within 45 days of receiving the request.

Safety data sheets

For substances and mixtures such as cleaning media, fluxes or heat transfer fluids we provide the manufacturers' safety data sheets in their current version. They are available for download with the relevant articles.

Open the current Candidate List at ECHA

03RoHS, restriction of hazardous substances in electrical equipment

Directive 2011/65/EU

As a distributor under Article 10 of Directive 2011/65/EU, before making electrical or electronic equipment available on the market we verify that it bears the CE marking, that the required documents and instructions are supplied with it and that the manufacturer and the importer have complied with their identification requirements. We do not make equipment available where we are aware of a non conformity.

The EU declaration of conformity is issued by the manufacturer. We forward it on an article specific basis. For many articles it is available directly on the product page in the documents section.

04EU POP Regulation, persistent organic pollutants

Regulation (EU) 2019/1021

The POP Regulation implements the Stockholm Convention into European law and restricts the manufacture, use and placing on the market of persistent organic pollutants. For the distribution of articles, Annexes I and II are the relevant parts.

According to the information available to us from our upstream suppliers, the articles we supply do not contain substances listed in Annex I or Annex II of Regulation (EU) 2019/1021 above the limit values set out there. This statement is based on manufacturer information and applies unless the respective manufacturer notifies us otherwise.

05PPWR, substance restrictions and packaging products

Regulation (EU) 2025/40

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has applied directly in all Member States since 12 August 2026 and has replaced Packaging Directive 94/62/EC. In Germany, the Packaging Law Implementation Act took the place of the Packaging Act on the same date. This page deals with the substance related requirements and with our obligations as a distributor. Information on registration, licensing and disposal is set out on the page Disposal and Environment.

Heavy metals

Under Article 5, the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium is subject to a limit of 100 mg/kg. The limit applies to all packaging, including transport and shipping packaging. The Regulation does not provide quantity thresholds for it.

The shipping packaging we use consists predominantly of the original packaging of the respective manufacturer, which we pass on unchanged, and of reused cartons from our incoming goods. For our own packaging material used in addition, we are obtaining our suppliers' declarations regarding Article 5. The substances named are not intentionally added by us. For packaging products that we supply as goods, the statements of the respective manufacturer are decisive.

PFAS

The specific limits for per and polyfluoroalkyl substances under Article 5(5) apply exclusively to packaging that comes into contact with food. Our range contains no packaging intended by the manufacturer for direct food contact. The provision is therefore not relevant to our shipping packaging.

Harmonised analytical methods for PFAS in packaging are not yet available across the EU. Laboratory results obtained by third parties are therefore comparable only to a limited extent.

Packaging products in our range

Part of our range is packaging within the meaning of the PPWR, for example ESD shielding bags, ESD packaging, corrugated board containers and transport packaging. For these products we are a distributor within the meaning of Article 19.

Before making them available on the market we verify that the required marking is present, that the EU declaration of conformity and the technical documentation are held by the manufacturer, and that the producer is entered in the producer register of the Member State concerned. We do not make available any product where we are aware of a non conformity.

The EU declaration of conformity under the PPWR is issued by the manufacturer. We forward it on an article specific basis where it is available to us.

Manufacturer and producer

The Regulation distinguishes between the manufacturer, Erzeuger in the German text, and the producer, Hersteller in the German text. The manufacturer carries the conformity responsibility for the packaging as a product. The producer carries the extended producer responsibility for financing waste management. When you make an enquiry, please state which of the two roles your question relates to.

Scope of our statements

We do not issue blanket PPWR confirmations covering products of third party manufacturers, for the reasons set out under Our role in the supply chain. On request we issue a company confirmation regarding our shipping practice and our registration in the packaging register.

06SCIP database

Directive 2008/98/EC

Under the Waste Framework Directive, suppliers of articles containing a Candidate List substance above 0.1 percent by weight submit the relevant data to the ECHA SCIP database. Articles that are passed on unchanged may be covered by a simplified notification referring to the notification made by the upstream supplier.

We share manufacturers' SCIP numbers on request, as far as they have been provided to us. If no SCIP number is available for an article, we request it from the manufacturer and report back to you.

07Waste electrical equipment, batteries and packaging

ElektroG, BattDG, PPWR

The mandatory information under the German acts on electrical equipment and batteries, and under the EU Packaging Regulation together with the German Packaging Law Implementation Act, is collected on a separate page. It also covers the registration of manufacturers with stiftung ear and the licensing of our packaging: Disposal and Environment.

We take back waste equipment and waste batteries from our deliveries within the statutory framework. Please agree the return with us in advance so that transport and disposal can be organised properly.

08Conflict minerals

Regulation (EU) 2017/821

Regulation (EU) 2017/821 addresses Union importers of tin, tantalum, tungsten and gold and of their ores. A1-ESD Equipment GmbH does not import minerals or metals within the meaning of this Regulation into the Union and is therefore not an addressee of its obligations.

Where manufacturers provide reports based on the Responsible Minerals Initiative templates, such as CMRT or EMRT, we forward them on request. Further details are given in our conflict minerals statement.

09Supply chain due diligence

LkSG, Directive (EU) 2024/1760

A1-ESD Equipment GmbH is below the employee thresholds of the German Supply Chain Due Diligence Act and of the Corporate Sustainability Due Diligence Directive. We are therefore not directly subject to them.

We answer enquiries from customers who are themselves subject to these rules as far as we are able. We source predominantly from established European and Japanese manufacturers and we expect our suppliers to comply with applicable labour, environmental and human rights legislation.

10Upcoming requirements

Further stages of the PPWR

The requirements of the EU Packaging Regulation enter into force in stages. Harmonised marking of packaging is scheduled for August 2028. From 1 January 2030 the requirements on recyclability of at least 70 percent, the minimum recycled content in plastic packaging and the limitation of empty space in shipping packaging to 50 percent apply. From 2038 the recyclability requirement rises to at least 80 percent. The relevant design criteria are to be laid down by the European Commission by 1 January 2028. Numerous delegated and implementing acts are still outstanding. We follow the procedure and will incorporate the requirements as soon as they apply.

PFAS restriction under REACH

The restriction proposal on per and polyfluoroalkyl substances is under assessment by the ECHA scientific committees. No final legal act has been adopted so far. Seals, hoses and fluorinated heat transfer media would be among the products affected. We follow the procedure and query composition data from the manufacturers concerned.

Ecodesign Regulation and digital product passport

Regulation (EU) 2024/1781 introduces product group specific requirements and the digital product passport in stages. As soon as delegated acts apply to the product groups we carry, we will make the data carriers and information provided by the manufacturer available through our product pages.

11Requesting information

To give you a reliable answer we need details of the specific article. Please send us the following to compliance@esd.equipment:

• A1-ESD Equipment GmbH article numbers, alternatively manufacturer name and type designation
• order or delivery note number and the period of supply
• your customer number with us or your invoicing address
• the specific topics you need covered, for example REACH, RoHS, POP, PPWR, SCIP or conflict minerals
• your deadline, if you are bound to one

Processing

Information under Article 33 REACH and the forwarding of existing manufacturer and conformity declarations are free of charge. We normally process enquiries within ten working days. If a declaration first has to be requested from the manufacturer, processing takes longer and we will keep you informed of the status.