EU REACH - Brass and Copper Scoping

Question: Are brass and copper items within the scope of EU REACH? We sell brass connectors with screws and plastic molded covers (all sold in a bag), and copper connectors (also sold bagged). 

Answer: There are separate answers for brass and copper.

  1. Brass, in order to be machined, usually contains intentionally-added lead at around 0.3%. It is likely, then, that the presence of this lead will mean the brass connectors are declarable. If the lowest piece component contains an SVHC over 0.1%, then theoretically the data needs to flow upwards/"upstream" with some form of safe-use guidance relating to the presence of lead in the brass connector.

  2. Copper is not on the REACH candidate list as a substance. However, the copper manufacturing process can add additional elements, which will vary with each manufacturer's process. This means it may be worth requesting more information from the specific copper manufacturer. The best approach is to confirm this information from the copper manufacturer; you will then be able to make the applicable safe-use guidance statement.

    Trilead diarsenate (CAS 3687-31-8) and calcium arsenate (CAS 7778-44-1) are examples of two substances present in the manufacture of copper which are on the REACH candidate list.

This article is current as of 2018-10-30.

References: https://echa.europa.eu/candidate-list-table

https://echa.europa.eu/substance-information/-/substanceinfo/100.020.890

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