Product Compliance

Our group, NGK Insulators, is one of the world leaders in the manufacturing of copper-beryllium and copper-nickel-tin alloys. We actively participate in environmental studies on all substances used in our products, particularly beryllium, a key element in our Berylco alloys.

Following several evaluations of beryllium conducted by European authorities in recent years, it is important to note that beryllium is not subject to any restrictions—and will not be in the future. Its use requires workplace risk management measures, regulated under the European CMRD Directive (see details below).

Beryllium is also included in the European Union’s list of Critical Raw Materials (34 according to the latest 2023 list) and has been since the first list was established in 2011. Like many other metals essential to the energy and digital transitions, beryllium is officially recognized by European authorities for its economic and strategic importance.

Our priority is to comply with all applicable legal regulations to ensure the long-term availability of our products for our customers. Below is a detailed overview of the main European regulations and directives applicable to our products: REACH, RoHS, as well as ELV, CMRD, and Conflict Minerals.

For more information, you can contact our expert in charge of regulatory affairs and best practices for the use of our products: Angélique Renier.

We provide a downloadable letter confirming our products’ compliance with the main European regulations applicable to them (REACH Regulation, RoHS, ELV, and CMRD Directives, Conflict Minerals). Updated November 5, 2025 (following the latest publication of the REACH Candidate List by the European Chemicals Agency—ECHA). Please contact us for any questions.

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is the European chemical regulation covering the registration, evaluation, authorisation, and restriction of chemical substances, in force since June 1, 2007.

Although our copper-beryllium products are classified as “articles” under REACH (and not substances or mixtures), as a major player in the beryllium industry we registered beryllium in November 2010 (No. 01-2119487146-32-0003). NGK Berylco France, NGK Deutsche Berylco GmbH, and NGK Berylco UK are members of the REACH Beryllium Consortium.

ECHA updates the list of SVHCs every six months. For articles containing any substance from this list, the manufacturer or importer must inform the user of its presence and safe-use conditions.
All our Berylco products are REACH-compliant in that they do not contain any SVHCs.

Our free-machining alloy rods in Berylco 33/25 (CuBe2Pb – UNS C17300) contain lead, which was added to the ECHA Candidate List on June 27, 2018, as an SVHC.

In accordance with Article 33 of REACH Regulation 1907/2006, we declare the presence of lead (max. 0.6%) in these rods. The addition of lead is essential for achieving excellent machinability, and no substitute currently offers equivalent performance.

These rods are registered in the ECHA SCIP database (Substances of Concern In articles as such or in complex objects (Products)): UUID 33e4d665-ee50-412a-8340-3d955ee7fee4.

Beryllium is not—and will not be—on the SVHC list.

Following a Risk Management Option Analysis (RMOA) carried out in Germany, the BAuA (Federal Institute for Occupational Safety and Health) decided in November 2016 not to include beryllium on the candidate list.

RoHS (Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment) limits the use of certain hazardous substances. Since July 1, 2006, all new products placed on the EU market must comply with the directive. RoHS was revised in 2011 (RoHS 2 – 2011/65/EU) and in 2015 (RoHS 3 – 2015/863/EU, effective July 22, 2019).

All Berylco alloys comply with RoHS Directive 2015/863/EU (RoHS 3).

The latest evaluation (ROHS Pack 15 Report Nov. 2020) does not recommend restricting beryllium. There is therefore no restriction on the use of copper-beryllium.

Only our Berylco 33/25 alloy contains a small amount of lead (<1%). Lead is one of the 10 restricted substances under RoHS, but the alloy is compliant due to exemption 6(c) (copper alloys containing up to 4% lead by weight). The European Commission recommended renewing this exemption in 2022 (RoHS Pack 22 Report – Feb. 2022). (RoHS Pack 22 Report February 2022).

ELV (End-of-Life Vehicles) aims to reduce hazardous substances in the recycling and recovery of end-of-life vehicles. Four substances are restricted: lead, mercury, cadmium, hexavalent chromium.

As with RoHS, Berylco 33/25 contains less than 4% lead and is compliant under exemption 3 for copper alloys containing lead.

All our Berylco products comply with Directive 2000/53/EC (ELV).

CMRD (Carcinogens, Mutagens and Reprotoxics Directive) protects workers from carcinogenic, mutagenic, and reprotoxic agents.

Beryllium can pose a risk in the workplace if fine particles are inhaled by sensitized individuals (a chronic respiratory illness known as berylliosis) and has therefore been included in the CMD (entry into force 11 July 2019 of Directive 2019/183 amending Annex III of Directive 2004/37/EC).

This directive sets an Occupational Exposure Limit Value (OELV) for beryllium of 0.6 µg/m³ (micrograms per cubic meter of air—inhalable fraction—8 hours), followed by 0.2 µg/m³ as of 12 July 2026. Member States were given two years to transpose it into national law. This directive ensures compliance with a harmonized limit value throughout the European Union.

France transposed Directive 2019/183 in 2021, with entry into force on 1 March 2022: Decree 2021‑1849.

The beryllium industry has developed a product stewardship program for materials containing beryllium entitled “Be Responsible” (Be referring to the chemical symbol for beryllium). This program is based on workplace best practices as well as the EU OELV of 0.6 µg/m³. It is available free of charge online at www.berylliumsafety.eu (full program in English) and www.berylliumsecurite.fr (summary in French). Simplified, operation‑specific guides are available in major European languages, including French.

Recent epidemiological studies show that beryllium in its metallic form is not carcinogenic. The beryllium industry is currently working with European authorities to update the current classification of metallic beryllium under the EU CLP Regulation. As with many other metals, alloys containing beryllium do not present a hazard when used correctly.

EU Regulation (EU) 2017/821, adopted 17 May 2017, sets due‑diligence obligations for EU importers of tin, tantalum, tungsten and gold (3TG) from conflict‑affected or high‑risk areas. Implementation began on 1 January 2021.

This regulation is based on OECD rules and on US legislation (Section 1502 of the Dodd‑Frank Wall Street Reform and Consumer Act, 2010). Its overall objective is to ensure responsible sourcing within the EU of so‑called conflict minerals and metals (3TG)—notably from the Democratic Republic of Congo and neighboring countries—without contributing to armed conflicts or human‑rights abuses.

Les alliages de cuivre-béryllium Berylco ne contiennent pas de métaux de conflit (pas d’étain, tantale, tungstène, or).

Berylco beryllium‑copper alloys do not contain conflict metals (no tin, tantalum, tungsten, gold).

We can provide our declarations on the presence and origin of metals in our alloys: CMRT (Conflict Minerals Reporting Template), EMRT (Extended Mineral Reporting Template) including copper, cobalt and nickel, and PRT (Pilot Reporting Template). Please contact us.