Declaration on substances in Winterhalter products
In accordance with REACH Regulation (EC) No. 1907/2006
1. Compliance with REACH Regulation (EC) No. 1907/2006 for “articles”
Winterhalter supplies machines, warewashing systems and accessories, and is thus a part of the supply chain and dependent on information from sub-suppliers over several stages. As a “downstream user”, we do not have an obligation to register our articles according to REACH. This also applies to imports of articles from non-EU countries. A declaration of ingredients in our products can only be made insofar as we have available the corresponding declaration from our suppliers.
We have therefore created a portal for our suppliers of components (“articles”) and requested them to provide us with information and statements on conformity. Discussions with suppliers and customers regarding material declarations are actively conducted by Winterhalter. Winterhalter develops products for a diverse and broad field of uses and applications within the area of commercial dishwashing. Winterhalter does not use any substances listed in Annex XVII of the REACH Regulation above the limits specified therein insofar as the products fall within the regulated field of application. This is based, in particular, on the statements and information provided by our suppliers. The legal situation or the status of the SVHC List at the time of delivery of the machines and equipment applies.
2. Obligation to communicate information about SVHC substances according to the Candidate List for articles:
According to Article 33 of the REACH Regulation, the supplier of an article must inform downstream customers about Substances of Very High Concern (SVHC) according to the REACH Candidate List () if the substance is present above a concentration of 0.1% by weight. As a minimum, this must include the name of the substance and, if applicable, information on safe use. Based on our queries, two suppliers have thus far notified us that a limit value of 0.1 percent by weight of an SVHS substance has been exceeded. This applies to three terminals or safety thermostats in several of our dishwasher models in an area that is not accessible to the user. In all cases they are not installed into the washing line.
|Winterhalter part number||Component designation||SVHC|
|3109153||UDK 4-PE DOUBLE TERMINAL|
|3109165||DOUBLE TERMINAL, UK, 5-TWIN-PE|
|3109174||Protective conductor terminal USLKG 35|
CAS No. 556-67-2 D4 octamethylcyclotetrasiloxane,
CAS No. 7439-92-1 lead
|3125 030||Safety thermostat|
CAS No. 61788-32-7 terphenyl, hydrogenated
CAS No. 7439-92-1 lead – component can be part of the
The suppliers have informed us that these products do not pose a hazard if they are used as intended. Therefore, no special instructions for safe use are required. Information in the form of a safety data sheet is also not required.
2.1 Information according to Art. 33 (1) REACH on lead metal in materials made of brass / copper alloys and in electrical / electronic components
Lead metal (CAS No. 7439-92-1) was included in the REACH Candidate List due to its reproduction toxicity on 27 June 2018. Lead, along with over 200 other substances, is therefore classed as an SVHC substance. The use of lead has already been regulated for many years.
The potential negative properties of lead are not new as such, and the obligation to communicate information under REACH is not based on new scientific knowledge about the metal. All previous safety measures for activities related to materials containing lead remain unchanged. The obligation to communicate information is based solely on the fact that lead has been included in the Reach Candidate List by the European Chemicals Agency. One of the aims of the inclusion is to obtain information on the quantities of these substances used within the EU. Lead acts as a chip breaker and lubricant in copper alloys, e.g. in brass parts, and improves the machinability of these parts, which gives the finished component other properties, such as improved corrosion resistance or electrical contacting. For this reason, lead currently remains an important alloying agent in copper materials. Moreover, it is also still technically difficult to remove lead unintentionally introduced into the recycling chain.
Pursuant to Art. 33 (1) of the REACH Regulation, we are therefore obliged to inform you that we use components that contain parts made of copper alloys with a lead content of more than 0.1% by weight (CAS No.: 7439-92-1). This applies in particular to parts made of brass or other copper alloys inside our machines, i.e. components that are not accessible to the warewasher user or that are otherwise coated in a different material.
This may affect:
- components with parts made of brass or copper alloy contents with lead content
- screw terminal terminals and class-C parts/small parts, e.g. brass / copper alloy nuts
Lead in electronic components
We also have an obligation to inform you if electronic or electrical assemblies contain even just one component with a lead metal content of more than 0.1 percent by weight, e.g. in diodes, quartz crystals, voltage regulators, using permissible exceptions according to RoHS 7 (a), 7 (c I) or 6.
Parts such as this are not accessible to the warewasher user. This applies to
- electronic flat modules such as our central control units, power units, PCBs, frequency inverters, as applicable.
- Our tubular heating elements may partially also contain brass inside.
- Cross-flow ventilators or blowers
Please get in contact with us if you would like more information or a complete list of all brass or lead metal parts.
3. Chemical products: REACH and CLP guidelines, SVHC
As a downstream user of chemicals, we do not have an obligation to register according to REACH Regulation (EC) No. 1907/2006. However, we do pay close attention to compliance with this regulation in our manufacturer audits. Consequently, no raw materials listed in Annex XIV of the REACH Regulation are used in the manufacture of any of our products. We are in close contact with our chemicals manufacturers. We are in possession of the complete formulae and process parameters. Manufacturers have a contractual obligation to communicate information prior to any change in production conditions, raw materials and their suppliers. We are thus immediately notified of the use of SVHC substances in this way. We would like to explicitly point out here that the use of such substances does not comply with our mission statement and they are never used in our detergents, rinse aids and machine care products.
Winterhalter has been complying with CLP Regulation (EC) No. 1272/2008 Europe-wide for years. We also follow this standard worldwide, under consideration of country-specific laws. Safety data sheets and labels are checked on a regular basis and adapted to new conditions as required.
|Marco Bertiller||Dr Andreas Witt||Sven Hahn|
|Head of BU Product & Technology|
Head of Consumables
Head of EHS,