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European RoHS Directive 2011/65/EU and Commission Delegated Directive (EU) 2015/863 and Its Application to Woodward, Inc.’s Products
Woodward, Inc. ("Woodward") has been closely monitoring changes in legislation regarding restrictions on the use of certain hazardous substances in electrical and electronic equipment sold in the European Union. The new Directive 2011/65/EU (6 entries-commonly referred to as RoHS2) was put in force on 3rd January 2013, thereby repealing EC Directive 2002/95/EC. The Commission Delegated Directive (EU) 2015/863 (10 entries) adds four new substances to the already restricted substance groups.
Based on our best knowledge and belief, Woodward has taken the following positions with respect to the applicability of the RoHS Directive to our products:
1. Woodward's aerospace and military segment products, including those used in connection with Aircraft, Aircraft Turbines, Industrial and Factory Automation, Rotorcraft, Armored and Tactical Vehicles, Guided Missiles and Munitions, Unmanned Aerial Vehicles, and Naval applications, are not currently subject to the restrictions per Article 2.4 (a, b and f) of RoHS2.
2. Woodward's energy segment products, including those used in connection with Electrical Power Generation & Distribution, Large Engines, Small Engines and Industrial Turbomachinery, are considered "industrial monitoring and control instruments" within the meaning of Category 9, as set forth in Annex I to RoHS2. Although these products are in scope of the RoHS Directive (unless excluded per Article 2 of RoHS2) they will not become subject to new substance restrictions (per Annex II of Delegated Directive (EU) 2015/863) until 22 July 2021.
Woodward's Industrial Turbomachinery Systems (ITS) products, which include those used as components of industrial gas turbines, steam turbines, wind turbines, compressors and safety systems, are intended to be sold and used only as part of Large Scale Fixed Installations. Thus, these products are not subject to RoHS restrictions per Article 2.4(c) and (e) of RoHS2 Directive.
Please note that Woodward's position reflects the current approach and is subject to revision of its content in order to reflect the most accurate requirements applicable to Woodward's products. Please contact your sales representative for more details regarding RoHS compliance of a specific Woodward product. We would be happy to provide you with additional information.
If you have any comments or questions concerning this communication, please don't hesitate to contact Woodward representatives.
EU REACH Regulation No. 1907/2006 and Its Application to Woodward, Inc.'s Products
Woodward Inc. understands its obligations and the applicability of EC Regulation No. 1907/2006 with respect to the Registration, Evaluation, Authorization and Restriction of Chemicals (“REACH”) to its products.
Woodward Inc. continuously monitors the changes in legislation to meet those obligations for the products Woodward Inc. manufactures in or imports directly into the EU.
Substances used in the articles supplied by Woodward Inc. are not subject to REACH registration process because these are integral to the functioning of the part and are not intended to be released during normal or reasonably foreseeable conditions.
Just as our customers rely upon us, Woodward Inc. relies upon its suppliers in gathering this information. Therefore the accuracy and completeness of our information depends on the reporting of our suppliers, and the many cascading tiers of components and material manufacturers that constitute the supply chain.
Woodward Inc. is aware of the obligation to communicate specific data on substances contained in products it supplies (Article 33). In particular our company will provide the required information if 0.1% by weight threshold per article of any substance of very high concern (“SVHC”) is exceeded.
Having regard to the verdict of EU Court of Justice on the “Once an Article Always an Article” rule, the complexity of our articles (products) and the recent additions to the SVHC list, Woodward hereby informs you that our articles may contain components (articles) which in turn have been reported to us as potentially containing the following substances:
|Substance||CAS No.||EC No.||Intended Use|
|Lead||7439-92-1||231-100-4||Alloying element in steels, copper alloys, aluminum alloys, Pb/Sn solders in electronics subassemblies|
|Chromium trioxide||1333-82-0||215-607-8||Corrosion protection of metals in processing (Hexavalent chromium may be retained on but not released from the finished article)|
|Bisphenol A||80-05-07||201-245-8||Professional use of articles made of polycarbonate|
|Lead chromate molybdate sulphate red (C.I. Pigment Red 104)||12656-85-8||235-759-9||Colorant used in articles made of polymite material|
Based on input from our supply chain and our manufacturing operations, Woodward believes that, to the best of its knowledge, all components using Annex XIV substances in their manufacture have been produced outside of the European Economic Area and, therefore, are not subject to the REACH Annex XIV authorization process.
Woodward Inc. is enhancing our internal process to ensure the REACH compliance of our products, which includes ongoing efforts to obtain information from suppliers and monitor changes to REACH requirements (including the SVHC Candidate List, Annex XIV and applicable substances listed in Annex XVII).
If you have any comments or questions concerning this communication or related to particular product on the applicability of the statement, please don't hesitate to contact Woodward representatives.