This notice addresses the compliance status of HART Industrial Unions products with respect to the following European Union and international regulations:
RoHS Directive 2011/65/EU & 2015/863/EU — Restriction of Hazardous Substances (10 restricted substances)
REACH Regulation (EC) No 1907/2006 — Registration, Evaluation, Authorisation and Restriction of Chemicals, including the SVHC Candidate List (Article 33), Annex XIV (Authorisation), and Annex XVII (Restrictions)
3TG EU Regulation 2017/821 & US Dodd-Frank Section 1502 — Conflict Minerals (Tin, Tantalum, Tungsten, Gold)
HART Industrial Unions manufactures industrial pipe unions in a range of base metal alloys—including Brass C36000, Brass C46400, 303 Stainless, A182 F304 Stainless, A182 F316 Stainless, 12L14 Carbon Steel, A105/A350-LF2 Carbon Steel, Monel 400, Hastelloy C276, 90/10 Copper-Nickel (C70600), 70/30 Copper-Nickel (C71500), and Aluminum 6061—paired with elastomeric sealing elements including Viton (FKM-A), Viton Type B (FKM-B), PTFE, Buna-N (Nitrile), Kalrez 4079 (FFKM), EPDM, Silicone, Aflas, and Spiralwound Graphite Gaskets.
The RoHS Directive restricts the use of ten hazardous substances in electrical and electronic equipment (EEE): Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium (Cr VI), Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE), and four phthalates (DEHP, BBP, DBP, DIBP).
Applicability Note: Industrial pipe unions that serve a purely mechanical function (no electrical or electronic components) fall outside the scope of the RoHS Directive, which applies exclusively to electrical and electronic equipment (EEE). Additionally, large-scale stationary industrial tools and large-scale fixed installations are explicitly excluded under Article 2(4)(d)–(e). HART provides the following RoHS compliance data for the benefit of customers integrating our products into EEE assemblies.
| Base Metal Alloy | RoHS Status | Notes |
|---|---|---|
| Brass C36000 (Free-Cutting) | Compliant with Exemption | ~3% Pb. Exempt under Annex III, Exemption 6(c): lead in copper alloys up to 4% by weight. Active through December 31, 2026. |
| Brass C46400 (Naval) | Compliant | No restricted substances above threshold limits. |
| A182 F304 Stainless Steel | Compliant | Chromium is trivalent (Cr III), not hexavalent (Cr VI). Nickel is in metallic form. |
| A182 F316 Stainless Steel | Compliant | Chromium is trivalent (Cr III), not hexavalent (Cr VI). Nickel is in metallic form. |
| 303 Stainless Steel | Compliant | Free-machining grade (sulfur addition). Chromium is trivalent (Cr III). Nickel is in metallic form. No restricted substances above threshold limits. |
| 12L14 Carbon Steel | Compliant with Exemption | ~0.15–0.35% Pb. Exempt under Annex III, Exemption 6(a)-I: lead in steel for machining purposes up to 0.35% by weight. Active through December 31, 2026. |
| A105/A350-LF2 Carbon Steel | Compliant | No restricted substances above threshold limits. |
| Monel 400 | Compliant | Nickel is in metallic alloy form. No restricted substances above threshold limits. |
| Hastelloy C276 | Compliant | Cobalt, molybdenum, tungsten, and nickel are in metallic alloy form. No RoHS-restricted substances present. |
| 90/10 Copper-Nickel (C70600) | Compliant | No restricted substances above threshold limits. |
| 70/30 Copper-Nickel (C71500) | Compliant | No restricted substances above threshold limits. |
| Aluminum 6061 | Compliant | Trace chromium is metallic/trivalent, not hexavalent. No restricted substances above threshold limits. |
| Sealing Material | RoHS Status | Notes |
|---|---|---|
| Viton (FKM-A) | Compliant | No restricted substances above 0.1% (0.01% Cd) threshold limits. |
| Viton Type B (FKM-B) | Compliant | No restricted substances above threshold limits. |
| PTFE | Compliant | No restricted substances above threshold limits. |
| Buna-N (Nitrile / NBR) | Compliant | No restricted substances above threshold limits. |
| Kalrez 4079 (FFKM) | Compliant | No restricted substances above threshold limits. |
| EPDM | Compliant | No restricted substances above threshold limits. |
| Silicone (VMQ) | Compliant | No restricted substances above threshold limits. |
| Aflas (FEPM) | Compliant | No restricted substances above threshold limits. |
| Spiralwound Graphite Gasket | Compliant | No restricted substances above threshold limits. |
Under REACH Article 33, suppliers of articles containing a Substance of Very High Concern (SVHC) at a concentration above 0.1% weight by weight (w/w) must provide sufficient information to allow safe use of the article, including as a minimum the name of the substance. The SVHC Candidate List currently contains 253 substances.
The following HART products contain SVHC substances above the 0.1% w/w notification threshold:
| Material | SVHC Substance | CAS No. | Concentration | Reason for Inclusion |
|---|---|---|---|---|
| Brass C36000 | Lead | 7439-92-1 | ~3% w/w | Toxic for reproduction (Article 57c) |
| 12L14 Carbon Steel | Lead | 7439-92-1 | ~0.15–0.35% w/w | Toxic for reproduction (Article 57c) |
Lead is added to these alloys as a metallurgical alloying element to improve machinability. In their finished solid form, lead is metallurgically bound within the alloy matrix. Safe handling does not require special precautions beyond standard industrial practice for machined metal components.
All other HART base metal alloys and elastomeric sealing materials do not contain SVHC Candidate List substances above the 0.1% w/w notification threshold. Metallic nickel and metallic cobalt in their elemental alloy form are not on the SVHC Candidate List; only certain soluble nickel compounds and specific cobalt salts are listed.
| Material | SVHC > 0.1% w/w | Article 33 Notification |
|---|---|---|
| Brass C36000 | Lead — ~3% | Required |
| 12L14 Carbon Steel | Lead — 0.15–0.35% | Required |
| Brass C46400 | None identified | Not required |
| A182 F304 Stainless | None identified | Not required |
| A182 F316 Stainless | None identified | Not required |
| 303 Stainless | None identified | Not required |
| A105/A350-LF2 Carbon Steel | None identified | Not required |
| Monel 400 | None identified | Not required |
| Hastelloy C276 | None identified | Not required |
| 90/10 Cu-Ni (C70600) | None identified | Not required |
| 70/30 Cu-Ni (C71500) | None identified | Not required |
| Aluminum 6061 | None identified | Not required |
| All Elastomeric Seals | None identified | Not required |
The SVHC Candidate List is updated regularly by ECHA. This assessment reflects the list as of the most recent update. HART monitors ECHA publications and will update this notice as required when new substances are added.
REACH Annex XIV lists substances that require specific authorisation before they may be used or placed on the EU market. HART has reviewed the current Authorisation List and confirms that none of the substances present in our base metal alloys or elastomeric sealing materials are listed on REACH Annex XIV.
Lead metal (CAS 7439-92-1) is on the SVHC Candidate List but has not been added to Annex XIV. The European Commission has indicated that it does not intend to include lead metal on the Authorisation List. No authorisation is required for any HART product.
REACH Annex XVII imposes conditions or prohibitions on the manufacture, placing on the market, and use of certain substances. HART has evaluated the entries relevant to our product materials:
| Entry | Substance | Applicability to HART Products |
|---|---|---|
| Entry 23 | Cadmium | Not applicable — cadmium is not present in HART alloys or sealing materials above restricted concentrations. |
| Entry 27 | Nickel (release rate) | Not applicable — restricts nickel release (>0.5 μg/cm²/week) in articles intended for direct, prolonged skin contact. Industrial pipe unions are not skin-contact articles. |
| Entry 63 | Lead in articles | Not applicable — restricts lead in articles supplied to the general public that can be mouthed by children. Industrial pipe unions are not consumer articles and are not accessible to children. |
No REACH Annex XVII restrictions are applicable to HART industrial pipe unions in their intended industrial service applications. All HART products are compliant with Annex XVII requirements.
EU Regulation 2017/821 and US Dodd-Frank Act Section 1502 require supply chain due diligence for Tin (Sn), Tantalum (Ta), Tungsten (W), and Gold (Au)—collectively known as 3TG—originating from conflict-affected and high-risk areas.
Scope: EU Regulation 2017/821 applies to EU importers of raw 3TG minerals and metals above specified volume thresholds. As a manufacturer of finished industrial articles, HART Industrial Unions is outside the mandatory scope of this regulation. The following disclosure is provided voluntarily to support our customers' due diligence requirements.
| Mineral | Present | Material(s) | Concentration |
|---|---|---|---|
| Tin (Sn) | Yes | Brass C46400 (Naval Brass) | ~0.75% w/w |
| Tungsten (W) | Yes | Hastelloy C276 | ~3.75% w/w |
| Tantalum (Ta) | Not present | Not contained in any HART product. | |
| Gold (Au) | Not present | Not contained in any HART product. | |
HART Industrial Unions is committed to responsible sourcing practices. We do not directly import raw tin or tungsten minerals. The tin in our Brass C46400 and the tungsten in our Hastelloy C276 are sourced from established alloy suppliers who maintain their own responsible minerals sourcing programs.
HART supports the goals of conflict-free mineral sourcing and will provide additional supply chain information, including Conflict Minerals Reporting Templates (CMRTs), to customers upon request.
The following table provides a consolidated view of the regulatory status of each HART base metal alloy.
| Base Metal Alloy | RoHS | REACH SVHC | Annex XIV | Annex XVII | 3TG |
|---|---|---|---|---|---|
| Brass C36000 | Exempt 6(c) | Art. 33 Pb | Clear | Clear | None |
| Brass C46400 | Compliant | Clear | Clear | Clear | Sn |
| A182 F304 Stainless | Compliant | Clear | Clear | Clear | None |
| A182 F316 Stainless | Compliant | Clear | Clear | Clear | None |
| 303 Stainless | Compliant | Clear | Clear | Clear | None |
| 12L14 Carbon Steel | Exempt 6(a)-I | Art. 33 Pb | Clear | Clear | None |
| A105/A350-LF2 | Compliant | Clear | Clear | Clear | None |
| Monel 400 | Compliant | Clear | Clear | Clear | None |
| Hastelloy C276 | Compliant | Clear | Clear | Clear | W |
| 90/10 Cu-Ni (C70600) | Compliant | Clear | Clear | Clear | None |
| 70/30 Cu-Ni (C71500) | Compliant | Clear | Clear | Clear | None |
| Aluminum 6061 | Compliant | Clear | Clear | Clear | None |
Pb = Lead (CAS 7439-92-1) present above 0.1% w/w; REACH Article 33 notification applies.
Sn = Tin present; W = Tungsten present. Voluntary 3TG disclosure — HART is outside the mandatory scope of
EU Regulation 2017/821 as a finished article manufacturer.
Customers requiring material-specific declarations of compliance, REACH Article 33 notifications, Conflict Minerals Reporting Templates (CMRTs), or RoHS certificates of compliance for individual part numbers may contact HART Industrial Unions at:
Phone: 1-800-769-0503 | Email: [email protected]