Supplier Requirement: Provide a statement of compliance to current REACH regulations. If there are items provided that are out of compliance please list the item number, the substance, and the concentration (w/total w)%. REACH is a regulation of the European Union that addresses the production and use of chemical substances and their potential impacts on both human health and the environment by requiring companies to communicate information on chemicals up and down the supply chain. All companies manufacturing or importing chemical substances in the European Union in quantities of one metric ton or more per year are required to register these substances with a European Chemicals Agency to ensure that manufacturers, importers, and customers are aware of information on the health and safety of the products supplied. Under REACH, no item may exceed 0.1% by weight threshold of any chemical substances listed on REACH’s SVHC (substances of very high concern) (this list is accessible at the link below). Products exported to the EU must be in full compliance with REACH. However, items defined as “articles” (objects that during production are given a special shape, surface or design that determines its function to a greater degree than does its chemical composition) in REACH are exempt from registration.
SVHC List: SVHC LIST
For more information on REACH, visit https://www.hse.gov.uk/reach/about.htm
Supplier Requirement Please provide a declaration stating compliance to current RoHS directive standards. If necessary list the nonconforming item numbers, the chemical, and its concentrations.
The Restriction of Hazardous Substances (RoHS) directive aims to restrict certain hazardous substances commonly used in the manufacture of various types of electronic and electrical equipment, which links it with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC. The hazardous substances under RoHS, which any RoHS-compliant component is tested for, are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr^8+), polybrominated biphenyls (PBB), polybrominated diphenyl ether (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP) dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP). The maximum permitted concentrations of these substances in products subject to RoHS compliance are 0.1% or 1000 parts-per notation (ppm) by weight, besides cadmium, which is 0.01% or 100 ppm. Businesses that sell applicable or electronic products, equipment, sub-assemblies, cables, components or spare parts directly to RoHS-directed countries, or sells to resellers, distributors or integrators that in turn sell products to these countries, are impacted if they utilize any of these (10) restricted substances.
For more information on RoHS, visit https://www.rohsguide.com/
Supplier Requirement: Please provide a declaration stating compliance to current Proposition 65 standards. If necessary list the nonconforming item numbers the chemical, and its concentrations.
Proposition 65, officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, is administered by California/EPA’s Office of Environmental Health Hazard Assessment (OEHHA) to protect California’s drinking water sources from becoming contaminated with toxic chemical substances known to cause cancer and birth defects. An official list of such substances is made publicly available showing regulated substances’ known risk factors, a unique CAS chemical classification number, the date they were listed, and, if so, whether they have been delisted. The first requirement of Proposition 65 prohibits businesses from knowingly discharging listed substances into drinking water sources, or onto land where the substances can pass into drinking water sources. The second requirement prohibits businesses from knowingly exposing individuals to listed substances without providing a clear and reasonable warning. Ultimately, the law requires companies to notify California about significant amounts of chemicals in products they manufacture; not to control what businesses are putting in their products, but to allow Californians to make informed choices about the products they buy and use.
For more information on California Proposition 65, visit https://oehha.ca.gov/proposition-65
Supplier Requirement: Please provide either a NAFTA Certificate of Origin or a Manufacturer’s Affidavit that declares the HTS designation and the Country of Origin.
The North American Free Trade Agreement (NAFTA) is an agreement signed by Canada, Mexico, and the United States that aims to reduce or eliminate barriers to trade and investment (i.e. non-tariff trade barriers) and to protect the intellectual property rights on traded products. Under NAFTA, producers may export their goods to customers in Canada or Mexico duty-free as long as the goods are comprised of mostly U.S. components. To certify that goods qualify for preferential tariff treatment accorded by NAFTA, a Certificate of Origin must be completed legibly and in full by the exporter and must be in possession of the importer at the time the declaration is made. This document may also be completed voluntarily by the producer for use by the exporter. Exporters who are not producers often request that their producers or distributors provide them with a Certificate of Origin as proof that the final good, or an input used in the manufacture of the final good, meets the rules of origin for exportation to Canada or Mexico. NAFTA does not obligate a producer who is not an exporter to provide the final exporter with a Certificate of Origin. However, if the non-exporting producer does complete the Certificate of Origin, they are subject to the same obligations regarding record.
For more information on NAFTA compliance, visit https://www.cbp.gov/trade/nafta
Supplier Requirement: Please complete the most recent Conflict minerals Reporting Template found at: http://www.responsiblemineralsinitiative.org/conflict-minerals-reporting-template/?
The term “Conflict Minerals” refers to minerals and other derivatives mined in the Democratic Republic of the Congo (DRC) and in adjoining countries where revenues from mining may directly, or indirectly, finance armed groups engaged in civil war, resulting in serious abuses of human rights. To hold companies accountable for buying raw materials from these areas that aid corrupt militias, and to mitigate the chance that the minerals purchased by companies are funding military conflict, the U.S. Dodd-Frank Financial Reform Law was passed in 2010. The law requires U.S. publicly traded companies to evaluate their product lines to determine whether they contain any “conflict minerals”, and if they do, to disclose any of the minerals necessary to the functionality or production of products they manufacture or contract to the manufacture. The minerals covered by this law (collectively referred to as “3TG”) are tantalum (Ta), tin (Sn), tungsten (W) and gold (Au). Companies using such minerals must also disclose their supply chain inquiries to verify whether these minerals originated in the DRC or adjoining countries.
For more information on 3TG Conflict Minerals, visit http://www.responsiblemineralsinitiative.org/about/faq/general-questions/what-are-conflict-minerals/
Supplier Requirement: Please certify that materials provided to Lofton Label Inc. comply with the Coalition of Northeastern Governors Toxics in Packaging Legislation.
The Toxics in Packaging Legislation was established by the Coalition of Northeastern Governors (CONEG) to reduce the amount of lead, cadmium, hexavalent chromium and mercury in packaging and to keep packaging components from entering landfills, waste incinerators, recycling streams and ultimately the environment. The law requires manufacturers to certify that none of the regulated metals were intentionally added to any products during the manufacturing process, and that the sum of the incidental concentration levels present in any product does not exceed 100 ppm by weight (CONEG model limit). The law also requires certificates of compliance to be completed by manufacturers and furnished to state agencies (and to the public upon request), but does allow for certain exemptions that must be approved by individual states. This law is desirable because manufacturers that comply with regulation meet the growing consumer demand for eco-friendly products, while minimizing the hazardous impact of products upon the environment and society.
For more information on CONEG Toxics in Packaging Legislation, visit https://www.bureauveritas.com/services+sheet/toxics-in-packaging_14479?presentationtemplate=bv_master_v2/Services_sheet_full_story_presentation_v2
Supplier Requirement: Please provide a declaration indicating that products provided to Lofton are BPA-free.
Bisphenol A (BPA), a building block of several important polymers and polymer additives used in the production of polycarbonates, is widely used in manufacturing polycarbonate plastics and epoxy resins used in nearly every industry. BPA is suspected to have adverse health effects as a reproductive, developmental and systemic toxicant that is weakly estrogenic, giving it a potential to impact children’s health. There has also been environmental concern over the risk posed by BPA leaching into landfills and bodies of water, consequently affecting the food chain. Due to the various risks associated with BPA, registrants of BPA must demonstrate the safety of BPA and BPA-based materials for human health and the environment. Downstream users must inform registrants about the way they use BPA, to allow registrants to prepare a realistic exposure scenario for each specific use of BPA. Regulations concerning BPA continue to evolve as governments at every level attempt to address public concern and take varying scientific assessments into account.
For more information on BPA and statements identifying any instances of BPA, visit https://www.epa.gov/assessing-and-imagining-chemicals-under-tsca/risk-management-bisphenol-bpa
Supplier Requirement: Please provide a declaration letter identifying that no natural rubber latex or synthetic rubber latex is found in any of the items provided to Lofton.
According to FDA regulation, labeling statements that include the latex content of the product packaging as well as the product itself are required on products containing latex, since repeated or prolonged exposure to natural rubber latex can result in the development of allergies or sensitivity to natural rubber latex, generally in the form of skin-site reactions. If latex is present in production, the extent to which natural rubber latex is used in the manufacture of the product must be defined. In light of the concerns surrounding latex, some manufacturers have taken to labeling products as “latex-free” or indicating that the product “does not contain natural rubber latex”. However, this labeling suggests that products are completely without natural rubber latex, which is problematic because (1) there is always a chance that products were contaminated with latex allergens during the manufacturing process, and (2) the FDA is unaware of any test method capable of detecting and confirming the complete absence of latex proteins capable of causing allergic reactions. The statement “not made with natural rubber latex” should be used only if neither natural rubber latex nor synthetic natural rubber latex derivatives were used to manufacture a product. Qualifications are necessary if the product, its packaging or its container use natural rubber latex or its derivatives. In such cases, the manufacturer should state which component is not made of natural rubber latex. Products currently labeled with “latex-free” statements should update their labeling to adopt FDA’s recommendations.
For more information on Natural Rubber and Latex and statements identifying any instances of Natural Rubber and Latex, visit https://www.raps.org/regulatory-focus™/news-articles/2014/12/does-this-product-contain-latex-fda-adopts-new-labeling-recommendations