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REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

June 18, 2012 The European Chemical Agency (ECHA) added thirteen new SVHC's to Candidate List. All substances are classified as carcinogenic, mutagenic or toxic for reproduction. None of KOA's parts contain any of the below mentioned 13 SVHC's greater than 0.1% by weight of the product. CAS #

112-49-2 110-71-4 1303-86-2 75-12-7 17570-76-2 2451-62-9 59653-74-6 90-94-8 101-61-1 548-62-9 2580-56-5 6786-83-0 561-41-1

Substance

1,2'bis(2-methoxyethoxy)ethane (TEGDME: triglyme) 1,2-dimethoxythane; ethylene glycol dimethyl ether (EGDME) Diboron trioxide* Formamide Lead(II)bis(methanesulfonate) TGIC (1,3,5-tris(oxiranylmethyl)-1,3,5-triazine-2,4,6(1H,3H,5H)-trione) B-TGIC(1,3,5-tris[(2S and 2R)-2,3-epoxypropyl]-1,3,5-triazine-2,4,6(1H, 3H, 5H)-trione) 4,4'-bis(dimethylamino)benzophenone(Michler's ketone) N,N,N',N'-tetramethyl-4,4'-methylenedianiline (Michler'sbase) [4-[4,4'-bis(dimethylamino)benzhydrylidene]cyclohexa-`2,5-dien-1ylidene) dimethylammonium chloride (C.I.Basic Violet 3) [4-[[4-anilone-1-naphthyl][4-(dimethylamine)phenyl[methylene]cycohexa2,5-dien-1-ylidenel] dimethylammonium chloride (C.I. Basic Blue 26) A,a-Bis[4-(dimethylamino0phenyl]-4 (phenylamino)naptthalene-1methanol (C.I. Solvent Blue 4) 4,4'-bis(dimethylamino)-4"-(methylamine)trityl,alcohol

* Koa uses Diboron Trioxide (CAS# 1303862) as a precursor to several of its glass substances. Diboron trioxide is used as an isolated, onsite intermediate substance at facilities outside the European Economic Area. In the manufacturing process, the diboron trioxide is completely consumed when forming a new substance, a leadborosilicate glass. No manufacturing takes place in the European Economic Area, and Koa does not import diboron trioxide as a substance or in preparations. Under the standard life cycles of any of these articles, diboron trioxide is not expected to be present or released under normal or reasonably foreseeable use, so the glass substances do not meet the registration requirements of REACH article 7. Because of the above, the REACH restrictions on diboron trioxide do not apply to Koa products. (Reference Appendix A for details).

December 19, 2011 The European Chemical Agency (ECHA) published a new list of twenty additional substances that it has identified as SVHCs, regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. Twelve have been included in the Candidate List following the unanimous agreement of the Member State Committee while the other eight, which did not receive comments challenging the identification as SVHC during public consultation, were directly added to the Candidate List. Nineteen SVHCs are carcinogenic and/or toxic for reproduction. Additionally, for the first time a substance 4-tert-octyl phenol - has been identified as an SVHC because of its endocrine disrupting properties which give rise to an equivalent level of concern due to its probable serious effects to the environment. CAS #

7778-44-1

Substance

Calcium arsenate

Possible Applications

Present in complex raw materials (which themselves are by-products from metallurgical processes) that are used mainly for copper and lead refining. The substance is used to precipitate nickel from the molten metal and to

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

manufacture diarsenic trioxide. However, most of the substance seems to be disposed of as waste. 111-96-6 Bis(2-methoxyethyl) ether Used primarily as a reaction solvent or process chemical in a wide variety of applications. It is also used as solvent for battery electrolytes, and possibly in other products such as sealants, adhesives, fuels and automotive care products. Mainly used in coatings in the aeronautic/ aerospace, steel and aluminum coil coating and vehicle coating sectors. No registration for lead dipicrate has been submitted to ECHA. The substance is an explosive like lead diazide and lead styphnate. It may be used in low amounts in detonator mixtures together with the two other mentioned lead compounds. Used as solvent, mainly in the manufacture of various substances and in the production of fibers for clothing and other applications. Also used as reagent, and in products such as industrial coatings, insulation paper, polyimide films, paint strippers and ink removers. Mainly used to remove gas bubbles from ceramic glass melt (fining agent) and in the production of laminated printed circuit boards. To lesser extent the substance is also used in the manufacture of semiconductors and as laboratory agent. Used in the manufacture of dyes for tattooing and coloration of paper, polymers and aluminum foil. Present in complex raw materials for manufacture of copper, lead and a range of precious metals. The trilead diarsenate contained in the raw materials is in the metallurgical refinement process transformed to calcium arsenate and diarsenic trioxide. Whereas most of the calcium arsenate appears to be disposed of as waste the diarsenic trioxide is used further. Used mainly for manufacture of other substances. Minor uses as solvent in the chemical and pharmaceutical industry, as well as in laboratories Used in coatings in the vehicle coating and aeronautic / aerospace sectors. Mainly used in the manufacture of polymer preparations and of ethoxylate surfactants. It is further used as a component in adhesives, coatings, inks and rubber articles. Technical MDA is mainly used for manufacture of other substances. Minor uses are as ion exchange resins in nuclear power plants, as hardener for epoxy resins, e.g. for the production of rolls, pipes and moulds, and as well for adhesives. No registration for bis(2-methoxyethyl) phthalate has been submitted to ECHA. Hence, the substance seems not to be manufactured in or imported to the EU in quantities above 1 t/y. Main uses in the past were as plasticizer in polymeric materials and paints, lacquers and varnishes, including printing inks.

11103-86-9

Potassium hydroxyoctaoxodizincatedichromate Lead dipicrate

6477-64-1

127-19-5

N, N-dimethylacetamide

7778-39-4

Arsenic Acid

90-04-0 3687-31-8

2-Methoxyaniline, o-Anisidine Trilead diarsenate

107-06-1

1,2-dichloroethane

45663-84-5 140-66-9

Pentazinc chromate octahydroxide 4-(1,1,3,3-tetramethylbutyl) phenol

25214-70-4

Formaldehyde, oligomeric reaction products with aniline

117-82-8

Bis(2-methoxyethyl) phthalate

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

13424-46-9 15245-44-0

Lead diazide, Lead azide Lead styphnate

101-14-4

2,2'-dichloro-4,4'-methylenedianiline

77-09-8

Phenolphthalein

24613-89-6

Dichromium tris (chromate)

-----

Zirconia Aluminosilicate Refractory Ceramic Fibers

-----

Aluminosilicate Refractory Ceramic Fibers

Used as initiator or booster in detonators for both civilian and military uses and as initiator in pyrotechnic devices. Mainly used as a primer for small caliber and rifle ammunition. Other common uses are in ammunition pyrotechnics, powder actuated devices and detonators for civilian use. Used as curing agent in resins and in the production of polymer articles and also for manufacture of other substances. The substance may further be used in construction and arts. Mainly used as laboratory agent (pH indicator solutions). Minor uses are in pharmaceutical preparations and in some special applications (e.g. pH-indicator paper, disappearing inks). Used in mixtures for metal surface treatment in the aeronautic/aerospace, steel and aluminum coating sectors. Fibers are used for high-temperature insulation, almost exclusively in industrial applications (insulation of industrial furnaces and equipment, equipment for the automotive and aircraft/aerospace industry) and in fire protection (buildings and industrial process equipment). Fibers are used for high-temperature insulation, almost exclusively in industrial applications (insulation of industrial furnaces and equipment, equipment for the automotive and aircraft/aerospace industry) and in fire protection (buildings and industrial process equipment).

None of KOA's parts contain any of the above mentioned 20 SVHC's greater than 0.1% by weight of the product. June 20, 2011 The European Chemical Agency (ECHA) published a new list of eight additional substances that it has identified as SVHCs, regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. CAS #

7676-79-6 111-15-9

Substance

Colbalt Dichloride 2-ethoxyethyl acetate

Possible Applications

Component in some paints and pigments used to produce a blue color found in the electrical industry Used as a solvent in some paints, coatings and adhesives, as well as in some wood stains and varnishes. It is also used as an industrial solvent and in automobile lacquers to retard evaporation and impart high gloss. A red coloring agent in pyrotechnics Principally used in Canada as a plasticizer for PVC (polyvinyl chloride) which may currently or was previously used in a variety of applications such as industrial, automotive, and construction materials Mainly used as a foaming agent in preparing polymer foams, but significant applications also include its uses as a precursor

7789-06-2 68515-42-4

Strontium Chromate 1,2-Benzenedicarboxylix acid, di-C7-11 branched and linear alkyl esters

7803-57-8 302-01-2

Hydrazine

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

to polymerization catalysts and pharmaceuticals. Additionally, hydrazine is used in various rocket fuels and to prepare the gas precursors used in air bags. 872-50-4 1-methyl-2-pyrrolidone Used to dissolve a wide range of chemicals, especially in the polymers field. It also used as a solvent for surface treatment of textiles, resins and metal coated plastics or as a paint stripper It is mainly used to make other chemicals. Some of it is also used as an industrial solvent, paint and varnish remover, and cleaning and degreasing agent Vinyl flooring, tile and carpet backing; Moulding and coating plastisols;Partial replacement for other low molecular weight plasticizers (e.g. DEHP) in extrusion, Injection moulding and calendaring applications requiring improved process ability.

96-18-4

1,2,3-trichloropropane

71888-89-6

1,2-Benzenedicarboxylic acid, di-C6-8branched alkyl esters, C7-rich

None of KOA's parts contain any of the above mentioned 8 SVHC's. December 15, 2010 The European Chemical Agency (ECHA) published a new list of eight additional substances that it has identified as SVHCs, regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. CAS #

10124-43-3

Substance

Cobalt (II) Sulphate

Possible Applications

Used in storage batteries and electroplating baths. It is used in sympathetic inks and as an additive to soils and animal feeds. It is a raw material to make other cobalt salts Mainly used in the production of other chemicals and the manufacturer of catalysts. Further applications may include surface treatment and batteries Used in the manufacturer of catalysts. Minor uses may include feed additive, production of other chemicals, production of pigments and adhesion (in ground coat frit) Used in the manufacturer of catalysts. Minor uses may include production of other chemicals, surface treatment, alloys, production of pigments, dyes, rubber adhesion and feed additive Mainly used as solvent, chemical intermediate and additive for fuels Mainly used as solvent and chemical intermediate Used for metal finishing and as fixing agent in waterborne wood preservatives These acids and their oligomers are generated when chromium trioxide is dissolved in water. Chromium trioxide is mainly used in form of aqueous solutions. Consequently, the uses of these substances are the same as indicated for chromium trioxide

10141-05-6

Cobalt (II) Dinirate

513-79-1

Cobalt (II) Carbonate

71-48-7

Cobalt (II) Diacetale

109-86-4 110-80-5 1333-82-0 7738-94-5 13530-68-2

2-Methoxyethanol 2-Ethoxyethanol Chromium Trioxide Acids generated from Chromium Trioxide and their organics: Chromic Acid Dichromic Acid Oligomers of Chromic Acid and Dichromic Acid

None of KOA's parts contain any of the above mentioned 8 SVHC's.

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

August 30, 2010 The European Chemical Agency (ECHA) published a new list of three additional substances that it has identified as SVHCs, regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. CAS #

87-757-1 120-82-1 108-70-3

Substance

1,2,3-Trichlorobenzene 1,2,4-Trichlorobenzene 1,3,5-Trichlorobenzene

Possible Applications

Insecticidal fumigants against moths, as space deodorizers, as general insecticides and fungicides on crops, metal treatments; in industrial deodorants; in cleaners for drains.

None of KOA's parts contain any of the above mentioned 3 SVHC's. June 10, 2010 The European Chemical Agency (ECHA) published a new list of ten additional substances that it has identified as SVHCs, regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. CAS #

10043-35-3 11113-50-1

Substance

Boric Acid

Possible Applications

Uses include a multitude of applications, e,g, in biocides and preservatives, personal care products, food additives, glass, ceramics, rubber, fertilizers, flame retardants, paints, industrial fluids, brake fluids, soldering products, film developers. Uses include a multitude of applications, e,g, in biocides and preservatives, personal care products, food additives, glass, ceramics, rubber, fertilizers, flame retardants, paints, industrial fluids, brake fluids, soldering products, film developers. Uses include a multitude of applications, e.g. in glass and glass fibers, ceramics, detergents and cleaners, personal care products, industrial fluids, metallurgy, adhesives, flame retardants, biocides, fertilizers. It has been used in pyrotechnics and in the early days of photography as well as in lithography, as a pure source of nitrogen in the laboratory, and as a catalyst. It is also used as a mordant for dyeing pigments, in the manufacturing of alizarin, chrome alum, leather tanning and oil purification. Yellow chemical indicator used for identifying concentrations of chloride ions in a salt solution with silver nitrate (AgNO3). Most commonly used as an oxidizing agent in various laboratory and industrial applications It is used as a mordant in dyeing, as an oxidizing agent in organic chemistry, and in analytical chemistry Primary uses are as an intermediate in the production of hydrofluorocarbon refrigerants and as a cleaning agent

1330-43-4 12179-04-3 1303-96-4

Disodium Tetraborate, Anhydrous

12267-73-1

Tetraboron Disodium Heptaoxide, Hydrate

7789-09-5

Ammonium Dichromate

7789-00-6

Potassium Chromate

7778-50-9 7775-11-3 79-01-6

Potassium Dichromate Sodium Dichromate Trichloroethylene

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

None of KOA's parts contain any of the above mentioned 10 SVHC's. March 30, 2010 The European Chemical Agency (ECHA) published a new list of five additional substances that it has identified as SVHCs, regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. CAS #

134237-50-6 134237-51-7 134237-52-8 7789-12-0 10588-01-9

Substance

Alpha-hexabromocyclododecane Beta-hexabromocyclododecane Gamma-hexabromocyclododecane Solium Dichromate

Possible Applications

Flame retardant used in HIPS and textiles Flame retardant used in HIPS and textiles Flame retardant used in HIPS and textiles Chrome-tanning of leather, corrosion inhibitor in paints, morant in textile dyeing process

None of KOA's parts contain any of the above mentioned 5 SVHC's. January 10, 2010 The European Chemicals Agency (ECHA) has recently released its second listing of 15 Substances of Very High Concern (SVHC) regarding Regulation (EC) No 1907/20066 under the REACH regulation ­ shown below. CAS #

90640-80-5 91995-17-4 91995-15-2 90640-82-7 90640-8166

Substance

Anthracene Oil Anthracene oil, anthracene pastes, distn, lights Anthracene oil, anthracene paste, anthracene fraction Anthracene oil, anthracene-low Anthracene oil, anthracene paste

Possible Applications

The substances are mainly used in the manufacturing of other substances, such as anthracene and carbon black. They may also be used as reducing agents in blast furnaces as components in bunker fuel, for impregnating, sealing and corrosion protection.

65996-93-2

Pitch, coal, tar, high temp

79-06-1

Acrylamide

Pitch, coal tar, high temp. is mainly used in the production of electrodes for industrial applications. Smaller volumes are dedicated to specific uses such as heavy duty corrosion protection, special purpose paving, manufacture of other substances and the production of clay targets Almost exclusively used for the synthesis if polyacrylamides, which are used in various applications, in particular in waste water and paper processing. Minor uses of acrylamide comprise the preparation of polyacrylamide gels for research purposes and as grouting agents in civil engineering

-

Aluminosilicate Refractory Ceramic Fibers Aluminosilicate Refractory Ceramic fibers are fibers covered by index # 650-017-008 in Annex VI, part 3, table 3.2 of Regulation (EC) No 1272/2008 and fulfill the 2 following conditions: a) Al2O3 and SiO2 are present with the following concentration ranges: * Al2O3: 43.5-47% w/w and SiO2: 49.5 53.5% w/w, or

Refractory ceramic fibers are used for high-temperature insulation, almost exclusively in industrial applications (insulation of industrial furnaces and equipment, equipment for the automotive and aircraft/aerospace industry) and in fire protection (buildings and industrial process equipment)

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

-

* Al2O3: 45.5-50.5% and SiO2: 48.5-54% w/w. b) fibers have a length weighted geometric mean diameter less two standard geometric erros of 6 or less micrometers (µm). Zirconia Aluminosilicate, Refractory Ceramic Fibers Zirconia Aluminosilicate, Refractory Ceramic Fibers are fibers covered by index # 650-017-00-8 in Annex VI, part 3, table 3.2 of Regulation (EC) No. 1272/2008 and fulfill the two following conditions: a) Al2O3 and SiO2 and ZrO2 are present with the following concentration ranges: * Al2O3: 35-36% w/w and * SiO2: 47.4-50% w/w and * ZrO2: 15-17% w/w b) fibers have a length weighted geometric diameter less two standard geometric errors of 6 or less micrometers (µm). 2,4-Dinitrotoluene

Refractory ceramic fibers are used for high-temperature insulation, almost exclusively in industrial applications (insulation of industrial furnaces and equipment, equipment for the automotive and aircraft/aerospace industry) and in fire protection (buildings and industrial process equipment)

121-14-2

84-69-5

Diisobutyl phthalate

7758-97-6

Lead chromate

12656-85-8

Lead Chromate molybdate sulphate red (C.I. Pigment Red 104)

1344-37-2

Lead sulfochromate yellow (C.I. Pigment Yellow 34)

115-96-8

Tris(2-chloroethyl)phophate

Used in the production of toluene diisocyanate, which is used for the manufacture of flexible polyurethane foams. The substance is also used as gelatinizing-plasticizing agent for the manufacture of explosive mixtures (e.g. for airbags in cars) Diisobutyl phthalate is used as plasticizer for nitrocellulose, cellulose ether, polyacrylate and polyacete dispersions and as a gelling aid in combination with other plasticizers, which are widely used for plastics, lacquers, adhesives, explosive material and nail polish Lead chromate is used for manufacturing pigments and dyes, as a pigment or coating agent in industrial and maritime paint products or for embalming/restoring of art products. Further potential uses include as detergents and bleaches, photosensitive materials and for the manufacture of pyrotechnic powder Lead Chromate molybdate sulphate red (C.I. Pigment Red 104) is used as a coloring, painting and coating agent in sectors such as the rubber, plastic and paints, coatings and varnishes industries. Applications comprise the production of agricultural equipment, vehicles and aircraft as well as road and airstrip painting Used as a coloring, painting and coating agent in sectors such as rubber, plastic and paintings, coatings and varnishes industries. Applications comprise the production of agricultural equipment, vehicles and aircraft as well as road and airstrip painting. The substance is further used for camouflage and ammunition marking in the defense area Mainly used as additive plasticizers and viscosity regulator with flame-retarding properties for acrylic resins, polyurethane, polyvinyl chloride and other polymers. Other fields of applications are adhesives, coatings, flame resistant paints and varnishes. The main industrial branches to use TCEP are the furniture, the textile and the building industry

None of KOA's parts contain any of the above mentioned 15 SVHC's.

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

August 22, 2008 The European Chemicals Agency (ECHA) released its first listing of 16 Substances of Very High Concern (SVHC) under the REACH regulation ­ shown below. CAS # Substance Possible Applications

101-77-9 56-35-9 85-68-7 120-12-7 15606-95-8 25637-99-4 294-62-2 81-15-2 85535-84-8 4,4'-Methylendianilin Bis(tribulytin) oxide, hexabutyldistannoxane (TBTO) Benzybutylphlthale (BBP) Anthracene Triethyl arsenate Hexabromocyclodecane, 1,3,5,7,9,11Hexabromcyclododecane (HBCDD) Cyclododecane 5-tert-butyl-2,4,6-trinitro-m-xylene Alkanes, C10-13, chloro (Short chain chlorinated paraffin's) Cobalt(@+) dichloride Raw material to produce methylendiphenyl dilisocyanate for PUR (main application). Hardener is epoxy resin, adhesives Biocide in anti-fouling paint and other biocidal uses, also for industrial use Plasticizer (mainly for PVC), adhesives, inks, lacquers, small use in package, cosmetics From coal distiliiation. Raw material for synthesis Wood preservation (phased out), pesticide, glass goods, E&E products, PVC Flame retardant (mainly in PS), In constructions, buildings, also in flame-retardant textiles and E&E products Intermediate in product of HBCDD. In production for chemicals to produce polymers like polyamides, polyester, perfumes. Raw materials for binding media for temporary sealing, etc. Cosmetics Metal working lubricants, fat liquoring of leather, flame retardant in textiles, rubber, paints, sealants, adhesives Absorber for pages, humidity indicator, to produce vitamins B12, dye mordant for glass industry, solid lubricant, catalyst, invisible inks, drying agent, production of non-ferrous metals, electroplating, additive in rubber production Production of other Cr-products as chromate pigments, use for paints and plastic coloration, corrosive protection for metals, in vitamin K production, preparation of colored glass and ceramic glazes in wood preparation, in production of essential oils and perfumes Plasticizer in resins and polymers (mainly PVC) Wood preservation (phased out), pesticide, glass goods, E&E products, PVC Dying industry, metallurgy (harden copper, lead, gold), special glasses wood preservation Decolorizing agent for glass and enamels, application in glass and lead glass industry, wood preservation, to produce other chemicals Plasticizer in resins and polymer (mainly PVC). Also used in printing inks, adhesives (e,g, paper, package) sealing/grouting agents, nitrocellulose paints, film coatings, glass fibers, consumer products

7646-79-9

7789-12-0 117-81-7 7784-81-7 1303-28-2 1327-53-3 84-74-2

Sodium dichromate, dihydrate Di(2-ethylhexyl)phthalate DEHP Lead hydrogen arsenate Diarsenic pentoxide Diarsenic trioxide Dibutylphltalate

None of KOA's parts contain any of the above mentioned 16 SVHC's. KOA will continue to monitor the ECHA's listings and will update this bulletin as more SVHC's are released. If you have any questions please feel free to contact me at any time. Regards,

Brian Piscitelli

Brian Piscitelli Manager of Engineering and Quality

REACH Bulletin

Bolivar Drive, PO Box 547 Bradford, PA 16701 Phone: 814-362-5536 Fax: 814-362-8883 www.koaspeer.com ECHA's listing of SVHC's

[email protected] APPENDIX A

On December 18, 2006, the European Parliament and the Council of the European Union enacted regulation (EC) no. 1907/2006, which is known as "Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)*." The REACH regulation includes several lists of substances that require attention. One of these lists is annex XIV, a list of substances that require specific authorization for use. Another is annex XVII, a list of substances with restrictions on manufacture, placing on the market, and use. Regulators, including the European Chemical Agency, use the term "substances of very high concern" or "SVHCs" for annex XIV substances and the term "restricted substances" for annex XVII substances. In practice, some companies use the term "SVHCs" to refer to both annex XIV and annex XVII substances. On February 9, 2012, the European Commission issued Commission regulation (EU) no. 109/2012, which added a number of restricted substances to annex XVII of the REACH regulation. This regulation entered into force on March 1, 2012, and applies from June 1, 2012. One of the new restricted substances is diboron trioxide (B2O3), also known as boric oxide or boron trioxide. This substance has EC index number 005-008-00-8, EINECS number 215-125-8, and CAS registry number 1303-86-2. Koa uses diboron trioxide as a precursor to several of its glass substances. Diboron trioxide is used as an isolated, onsite intermediate substance at facilities outside the European Economic Area. In the manufacturing process, the diboron trioxide is completely consumed when forming a new substance, a lead-borosilicate glass. No manufacturing takes place in the European Economic Area, and Koa does not import diboron trioxide as a substance or in preparations. It does not, therefore, fall under the registration requirements of REACH title II. Lead-borosilicate glasses are substances of variable composition, and most of the compositions do not have CAS or EINECS numbers assigned to them. They are chemically distinct from diboron trioxide and require specific processing to yield any chemical products that would include diboron trioxide. These glass substances are used in composite materials within articles manufactured by Koa. In most cases, these substances and materials are entirely internal to the articles. Even in cases where the materials may be exposed to the outside, they are not expected to be heavily handled by human beings. Under the standard life cycles of any of these articles, diboron trioxide is not expected to be present or released under normal or reasonably foreseeable use, so the glass substances do not meet the registration requirements of REACH article 7. Human handling of the article is expected to be minimal. Because of the above, the REACH restrictions on diboron trioxide do not apply to Koa products.

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