Regulatory Statement
Effective July 2, 2024
Sinclair & Rush Inc. has compiled the following regulatory list for our standard parts. We understand that there is often a need to meet multiple regulations simultaneously, so we have gathered as much information as possible. Please note that this data is based on information from our suppliers and other readily available sources. It is not a substitute for any testing you may need to conduct to determine the suitability of these parts for a particular purpose, application, or destination. Sinclair & Rush Inc. does not guarantee results and assumes no obligation or liability in connection with this information.
Sinclair & Rush is uploading the document with information available as of the date of upload and makes no representation as to how any changes occurring subsequent to the upload date might impact the information uploaded.
EC Directive on Waste Electrical and Electronic Equipment (WEEE) and EC Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, RECAST 2011/65/EU (RoHS2) & Directive (EU) 2015/863 (RoHS3) Sinclair & Rush Inc. standard option materials and colors meet the EC directives, and do not contain any substances above reportable thresholds.
China RoHS 2 (effective 1 July 2016) - China’s Ministry of Industry and Information Technology (MITT) Sinclair & Rush Inc. materials do not contain any substances greater than those allowed per GB/T 26572-2011.
REACH (Restriction, Evaluation, and Authorization of Chemicals / Substances of Very High Concern / Restrictions): Sinclair & Rush Inc. standard materials do not contain any of the 235 substances of very high concern (SVHC) June 2023. Some of our standard option parts contain substances in Annex XIV and Annex XVII above reportable permitted thresholds.
IMDS/GADSL (International Material Data System concerning the Global Automotive Declarable Substance List): IMDS submissions are available upon request. Please provide your IMDS ID number. Please refer to individual MDS for declarable substances according to the GADSL. There are no prohibited substances according to the GADSL present in our standard option materials and colors above the applicable thresholds.
CAMDS (China Automotive Material Data System: CAMDS submissions are available upon request. Please provide your CAMDS ID number. Please refer to individual MDS for declarable substances according to the GADSL. There are no prohibited substances according to the GADSL present in our standard option materials and colors above the applicable thresholds.
CDX. (Compliance Data Exchange) CDX submissions are available upon request. Please provide your CDX ID number. Please refer to individual MDS for declarable substances according to the GADSL. There are no prohibited substances according to the GADSL present in our standard option materials and colors above the applicable thresholds.
Sphera BOM Check (2018 revision to the Waste Framework Directive). BOM check is available upon request.
California Proposition 65 Some of our standard option parts contain substances known to the State of California to cause cancer or reproductive harm. Because Sinclair & Rush, Inc. has limited knowledge of your manufacturing processes, products, or the circumstances under which potential exposures may arise, Sinclair & Rush, Inc. is unable to certify that when our product is used, no individuals using our product in California will be exposed to any Proposition 65 chemicals in amounts that require a Proposition 65 warning.
Conflict Minerals CMRT (i.e., tantalite, tin, tungsten, and gold) Sinclair & Rush Inc. has been assured by our suppliers that metals derived from minerals defined as “Conflict Minerals” per Section 1502 of the Security & Exchange Commission Dodd-Frank Wall Street Reform and Consumer Protection Act are not present in our standard option materials and colors.
Extended Minerals Reporting Template (EMRT) (i.e cobalt and Mica) Sinclair & Rush Inc. has been assured by our suppliers that metals derived from minerals defined as “Extended Minerals” are not present in our standard option materials and colors.
BPA, DEHP, Lead, Mercury and Sulfur These ingredients are not intentionally utilized in Sinclair & Rush Inc. standard materials: BPA, DEHP, Lead, Mercury, and Sulfur.
Montreal Protocol (CFC’s and HCFC’s) Sinclair & Rush Inc. products are not manufactured with CFC’s or HCFC’s.
JIG (Joint Industry Guide) Level A and Level B substances: Sinclair & Rush Inc. products made from standard option materials and colors do not contain JIG Level A substances. Non-PVC standard option products do not contain Level B substances. Standard option PVC products contain PVC and certain phthalates over 1000ppm.
Animal and plant derived materials: Sinclair & Rush Inc. has no reason to expect that animal, plant derived, or bovine derived materials are present in our products. Sinclair & Rush Inc. products are manufactured using non-animal and plant derived raw materials.
Asbestos: based on our current knowledge of the raw materials used in our manufacturing process, we have no reason to expect that asbestos would be present at any appreciable level, nor do we intentionally add asbestos.
CalSAFER: data management system maintained by the California Department of Toxic Substances Control (DTSC) which operates as the information center for the regulatory activities of the Safer Consumer Products Program (SCP): Sinclair & Rush Inc. has no reason to believe that our part/parts contain a chemical currently listed in the CalSAFER data management system.
Russian Federation as listed in Annex XVII of the Council Regulation (EU) No 833/2014 dated July 31, 2014 (the “Annex XVII”); and incorporation of any steel and iron products as listed in the Annex XVII originating in The Russian Federation when having been processed in a third country. Please note that the steel and or iron used to make our tooling has not been specifically analyzed under Annex XVII of the Council Regulation (EU) No 833/2014 dated July 31, 2014.
CONEG Coalition of Northeastern Governors (CONEG) Model Toxics in Packaging Legislation regulation (mercury, lead, cadmium, and hexavalent chromium) in packaging and packaging component: based on our current knowledge of the raw materials used in our manufacturing process, we have no reason to expect that mercury, lead, cadmium, and hexavalent chromium would be present at any appreciable level, nor do we intentionally add mercury, lead, cadmium, and hexavalent chromium to the listed parts.
The Consumer Product Safety Improvement Act of 2008 (CPSIA): Some of our standard option parts contain substances listed in the Consumer Product Safety Improvement Act of 2008
Cobalt Reporting Template (CRT 2.2): based on our current knowledge of the raw materials used in our manufacturing process, we have no reason to expect that Cobalt would be present at any appreciable level, nor do we intentionally add Cobalt in our process.
IEC 62474 Declarable Substance List (DSL): Some of our standard option parts contain declarable substances per Version D24.00
Polyfluoroalkyl substances/chemicals (PFAS): Sinclair & Rush Inc. does not intentionally add PFOA/PFOS/PFAS chemicals in our processes or aware of any PFAS chemicals from our supply base.
40 C.F.R. 751.401 "U.S. Toxic Substances Control Act (TSCA) Section 6”. The United States Toxic Substances Control Act (TSCA): Sinclair & Rush is knowingly manufacturing or processing an articles or products containing the Regulated Chemical (DINP CAS#. 28553-12-00). Sinclair & Rush Inc. cannot guarantee that the chemical composition of articles or products will remain unchanged over time.
Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury and repealing Regulation (EC) No 1102/2008 Sinclair & Rush is not knowingly manufacturing or processing any articles or products containing Mercury. In fact, we cannot guarantee that the chemical composition of articles or products will remain unchanged over time.
Biocides or fungicides: based on our current knowledge of the raw materials used in our manufacturing process, we have no reason to expect that any biocides or fungicides would be present at any appreciable level, nor do we intentionally add biocides or fungicides to our products.
Flame Retardants: based on our current knowledge of the raw materials used in our manufacturing process, we have no reason to expect that any flame retardants would be present at any appreciable level, nor do we intentionally add flame retardants to our products.
Toxics in Packaging: The regulated metals – lead, mercury, cadmium, and hexavalent chromium -- were not intentionally added to any package or packaging component during the manufacturing process. The sum of the incidental concentration levels of lead, mercury, cadmium and hexavalent chromium present in any package or package component does not exceed one hundred parts per million by weight.