NGK INSULATORS, LTD.
New Metals Division
April 1, 2009
Copper beryllium alloy has an ideal combination of mechanical and physical properties, i.e., high strength, high electrical conductivity and excellent formability. Copper beryllium alloy is employed in a wide variety of the electrical and electronic components such as connectors, IC sockets, switches, relays, micro motors in telecommunication and automotive industries as well as consumer goods. In addition, copper beryllium alloy has been the indispensable material to achieve miniaturization and high reliability of products.
On the other hand, copper beryllium alloy is sometimes referred to in regulatory compliance and health & safety issues because it contains beryllium. Therefore, we will explain about the revision of the REACH Regulation for the proper understanding.
The REACH Regulation entered into force on June 1, 2007. It deals with the Registration, Evaluation, Authorization and Restriction of Chemical substances. Under the regulation all the chemical substances placed on the market are classified as "substance", "preparation" or "article". Copper Beryllium alloy which NGK supplies for customer use is classified as an "article" as shown in the table below.
| Classification | Definition | Classification in beryllium containing material |
|---|---|---|
| substance | a chemical element and its compounds | beryllium, beryllium oxide |
| preparation | a mixture or solution composed of two or more substances | copper beryllium master alloy (casting use) |
| article | an object which is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition | copper beryllium in forms of strip, plate, rod and wire for downstream users |
There are several requirements in the REACH Regulation as shown in the table below. However, the downstream users who use copper beryllium are not required to go through the procedure of registration or notification and are not subject to the restriction on use of copper beryllium.
 |
Registration of substances | Notification of SVHC in articles | Authorization | Restriction |
|---|---|---|---|---|
| Downstream users* | Not needed | Not needed | Not needed | Not restricted |
| NGK group companies in EU | To be registered(all identified uses to be covered) | Not needed | Required for preparation | No restriction |
Also there is not any law or regulation including the EU Directives such as RoHS and ELV whicht impose restrictions on the use of copper beryllium.
Our European subsidiary located in France has already completed the pre-registration of beryllium for the REACH Regulation. The company joined the Beryllium Consortium and has been making the necessary preparations for the registration to be completed by November 30, 2010. Therefore, it is not necessary for the downstream users to provide a registration.
In the case of substances in quantities totaling over one ton manufactured or imported per year and identified as a substance of very high concern (SVHC) included on the candidate list for authorization in a concentration above 0.1% (w/w), the REACH regulation will put an obligation to make notification to the Agency.
Since beryllium at present is classified as a "substances which should be regarded as if they are carcinogenic to man", there is a possibility that beryllium will be identified as a SVHC. However, our French subsidiary will register beryllium to cover all the identified uses; therefore, the downstream users will be exempt from the obligation to notify.
Recently the Beryllium Consortium has carried out an evaluation on the carcinogenicity of beryllium. The results do not support the conclusion that beryllium is a carcinogen. We will request the European Commission review the classification on carcinogenicity for beryllium immediately after the results have been made public.
For SVHC an authorization is required for its use within the EU. However, only the substance on its own or in a preparation is subject to the authorization. Copper beryllium alloy in forms of strip, plate, rod and wire as well as the components containing copper beryllium alloy are classified as articles, therefore, they are exempt from authorization.
Carcinogens or preparations containing carcinogens are restricted from being produced and placed in the market for use by general consumers in the EU. We have never supplied substances or preparations containing beryllium to the general consumer.
The copper beryllium alloy we supply to the downstream users is not restricted at all.
At present, beryllium is not restricted in the REACH Regulation. Additionally, there is no restriction to the use of the beryllium in other environmental law systems like the RoHS Directive and the ELV Directive, etc.
NGK will make efforts to ensure that our customers will be able to keep using copper beryllium alloy safely without any problem in laws and regulations.
If you have any question about health & safety issues or laws and regulations related to copper beryllium alloy or any request for more detailed information, please contact at:
Sales & Marketing Tel. +81-3-6213-8913
Environmental Control Tel. +81-569-23-5810
NGK INSULATORS, LTD.
