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NGK INSULATORS, LTD.

New Metals Division

April 1, 2009

Position of beryllium in REACH, European Community Regulation

Beryllium copper alloy has an ideal combination of mechanical and physical properties, i.e., high strength, high electrical conductivity and excellent formability. Beryllium Copper 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, beryllium copper alloy has been the indispensable material to achieve miniaturization and high reliability of products.

On the other hand, beryllium copper 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.

Outline

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". Beryllium Copper 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 beryllium copper 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 beryllium copper 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 beryllium copper are not required to go through the procedure of registration or notification and are not subject to the restriction on use of beryllium copper.

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
*downstream users who use beryllium copper in forms of strip, plate, rod and wire (as articles)

Also there is not any law or regulation including the EU Directives such as RoHS and ELV which impose restrictions on the use of beryllium copper.

Registration of Substances

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.

Notification of Substances in Articles

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.

Authorization

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. Beryllium copper alloy in forms of strip, plate, rod and wire as well as the components containing beryllium copper alloy are classified as articles, therefore, they are exempt from authorization.

Restriction

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 beryllium copper 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 beryllium copper alloy safely without any problem in laws and regulations.

If you have any question about health & safety issues or laws and regulations related to beryllium copper 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.

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