REGULATIONS & COMPLIANCE
Conflict Minerals
Conflict Minerals -- Dodd-Frank Act, Section 1502
Definition of Conflict Minerals
Ores mined for the production of Tantalum, Tungsten, Tin, and Gold (or 3TG as they are known) originating from the Democratic Republic of the Congo (DRC) or adjoining countries.
Regulation
On August 22, 2012, the SEC adopted the final rule implementing Section 1502 of the Dodd-Frank Act, the Conflict Minerals Rule, aimed at reducing a significant source of funding for armed groups that are committing human rights abuses and contributing to the conflict in the Democratic Republic of the Congo. Under the final rule, SEC reporting companies that manufacture or contract to manufacture products that contain conflict minerals must conduct a Reasonable Country of Origin Inquiry (RCOI) on the source and chain of custody of the applicable conflict minerals.
Hobson's Commitment
Although Hobson's Commitment is not a publicly traded company, we are reportable to those that are. It is therefore necessary that Hobson's Commitment comply with these regulations. It is the intent of this policy that Hobson's Commitment, as well as its suppliers, complies with the SEC rules.
As part of conducting an RCOI, Hobson's Commitment has received documentation from its suppliers of raw materials and plating finishes that the materials supplied are conflict free.
Online References
Conflict Minerals Final Rule - PDF document from the Securities and Exchange Commission
SEC News - Background information concerning the development of the Dodd-Frank Act
EICC - Conflict Minerals Reporting Template Dashboard
DFARS -- Defense Federal Acquisition Regulation Supplement
Definition
DFARS Clause 252.225-7009 Restriction on Acquisition of Certain Articles Containing Specialty Metals, as prescribed in 225.7003-5(a)(2). Classification of materials used by Hobson are:
- Steel: is Compliant
- Stainless Steel: is Compliant
- Brass: is Exempt of this Requirement
- Aluminum: is Exempt of this Requirement
Online References
DPAP - The Defense Federal Acquisition Regulation Supplement website
What is DFARS? - Defense Federal Acquisition Regulation Supplement (DFARS) and Procedures, Guidance, and Information (PGI)
REACH -- Registration, Evaluation, Authorization and Restriction of Chemicals
Definition
Registration, Evaluation, Authorization and Restriction of Chemicals. (REACH) Reach Directive EC/1907-2006
The subject regulation undertakes the identification and definition of chemicals of concern, and preparation of said chemicals, that are contained in products for use in the European Union. It details registration obligations of manufactures and suppliers to assure compliance.
The shape, surface and design of our products (articles) are paramount to the chemical composition.
Hobson Mfg. does not manufacture or distribute any products that intentionally release chemicals or any substances of concern as detailed in the REACH regulation.
For these reasons, Hobson products are considered articles that are not affected by the REACH Directive. They do not require registration. -- Paragraph 32 and Chapter 2 (3.3)
Online References
Europa - The main website pertaining to the European Union
What is REACH? - As defined by the European Union
(REACH) Reach Directive EC/1907-2006 - .PDF download
RoHS -- Restriction On Hazardous Materials
Definition
The European Union (EU) has adopted a directive concerning the use of certain hazardous substances in electrical and electronic equipment. Restriction of Hazardous Substance, RoHS, states that after July 1, 2006, electrical and electronic equipment sold in European Union Council Countries, not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). Exceptions are detailed in the Annex to the European Directive.
Hobson's Commitment
We are committed to providing our customers with RoHS compliant products. We will provide aid in the selection of parts that meet the particular requirements of each individual customer.
RoHS Compliance at Hobson
Hobson Mfg. manufactures and distributes precision hardware. In accordance with Dir 2011/65/EU as of June 8th 2011, Hobson follows Annex 3 Section 6 and all later references to RoHS will adhere to this callout. The majority of our products are compliant with RoHS. Section 6 of the Annex to RoHS concerning allowable concentration exemptions states:
"Lead as an alloying element in steel containing up to 0.35% lead by weight, Aluminum containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight."
Custom Part Compliance:
Hobson provides custom parts to many customers. These parts are manufactured to customer supplied drawings and specifications. Any change or deviation is the responsibility of the customer. The customer is responsible for providing new drawings and/or specifications.
Certificate of Compliance
Compliance certification on specific part numbers can be supplied if requested at the time of order placement. RoHS compliance must be stated at time of order placement. Certification of RoHS compliance will be supplied at no charge. Specific analysis of chemical and material content on raw material is available for a fee of $145.00.
Non Compliant Parts
Hobson does have parts that are not compliant because the finish contains cadmium, hexavalent chromium or lead. Many of these parts are for Military applications and are not subject to RoHS specifications.
Online References
RoHS - The main website pertaining to the European Union
RoHS FAQs - As defined by the European Union
RoHS Directive 2011-65-EU - .PDF download
WEEE -- Waste Electrical and Electronic Equipment
Definition
The European Union has adopted a directive concerning the disposal of Waste Electrical and Electronic Equipment (WEEE). Hobson products are not subject to this directive. (Per article 3a)
We assume no responsibility for any finishes or materials that contain restricted substances that are specifically requested by our customers and cannot certify the compliance of these products through the product use and disposal life cycle.
We will not assume liability for the disposal of our product and limit our responsibility to the compliance as stated in the EU directive for products we certify as RoHS compliant. Any product supplied by Hobson Manufacturing that may require disposal at a later time and date, will be the responsibility of the purchasing party in accordance with local laws and regulations.
Online References
Europa - The main website pertaining to the European Union
Waste Electrical and Electronic Equipment - As defined by the European Union
WEEE Directive EC-2002-96 - .PDF download