Case studies / Friction
REACH changes its normativity on the labeling and SDS of brass containing Pb
As of January 5, 2021, manufacturers/distributors on the EU market of brake pads will not only to notify downstream customers of the presence of SVHCs but ECHA itself as well if it contains a whole contain > = 0.1 % Pb (SVHC)
Recycled brass chips & swarfs are produced during the mechanization of big brass pieces to obtain products such as decorative pieces, taps, balustrades, profiles etc.
These pieces must be machinable, otherwise it would be impossible to obtain the necessary shapes required on these fields. To do so, the standard alloy available in the industry contains 1 -3 % of Pb, as this metal improves its manufacturability.
So far, CLP considered that an alloy is considered a mixture, that, if it do not present any hazard to human health by inhalation, ingestion or contact with skin or the aquatic environmental in the form they are placed on the market, do not need CLP label.
What has changed is that lead, even in its massive form, as agreed in ATP09 at REACH Registration, if it is in a concentration 1-3 % it will contribute to the classification of the mixture with the following indications (which must be indicated on the label) :
· Repr. 1A, H360FD: May damage fertility. May damage the unborn child
· Lact. H362: May cause harm to breast-fed children
· STOT RE 2, H373: May cause damage to central nervous system, blood and kidneys through prolonged or repeated exposure by inhalation and ingestion
At rimsa, we manufacture our own alloy on a unique completely dry process without including lead on the mixture
According to Law 8/2010, not labeling a product according to CLP (being aware of its dangers) is considered a serious offense, penalized with fines from 6.001 € to 85.000 €
Therefore, the alloy must be labeled with lead hazards and the SDS must be updated from June 2020, following the indications below:
- Our Brass chips are considered a MIXTURE, that contains lead, considered SVHC (Substances of Very High Concern).
- Brake PADS/Blocks/Linings are considered ARTICLES (products where shape, surface or design determines its function to a greater degree than does its chemical composition).
- As of January 5, 2021, manufacturers/distributors on the EU market of brake pads (articles) will not only have to notify downstream customers of the presence of SVHCs but ECHA itself if it contains a whole contain > = 0.1 % Pb (SVHC).
So, for those companies using the standard lead-containing brass in the industry, to avoid this new regulation, must remove this material from their formulations?
Obviously not, taking the lead from the mixture, all these companies will be able to continue using this fundamental product on so many formulations. But lead-free brass is not a standard on the industry and the well-known chopped lead-free brass wools become excessively expensive due to its manufacturing process
A large number of OE and Aftermarket manufacturers, including the big groups on friction industry, have already chosen our well-known ecoChip as their seamless ally to remove lead of their formulations and we want to share our expertise with those companies who want to go one step further on their ecological commitment
On the other hand, many other companies might consider to replace brass for a different material, and we want to be on their side too
The latest results from our trustworthy partners reveals that our ecoCast ,certified EN GJL 250 cast iron chips , can replace brass chips and maintain the same performance on existing formulations
These chips are able to provide heat conductivity and damping properties thanks to the graphite flakes segregated from the matrix, which turns this material into a self-lubricated chip that can provide a wear reduction and in the overall, become an alternative material to brass for those partners willing to remove any copper-containing product from their formulation