TRADE AND ENVIRONMENTAL COMPLIANCE

PEI-Genesis is dedicated to meeting recognized standards for trade practices, including export compliance. We also meet various environmental compliances including RoHS, REACH and Conflict Materials.

EXPORT COMPLIANCE

PEI-Genesis is dedicated to export compliance with both US and UK export control laws. To maintain compliance, PEI-Genesis is registered with the US State Department and the UK Department for Business, Innovation and Skill (BIS).

These export laws cover defense articles, defense services and technical data. ITAR is product-specific, not application-specific, and it does not affect all military connectors. PEI-Genesis makes it easy for you to maintain export compliance. We will inform you if a requested product is export-controlled, and when shopping online with MyPEI, controlled items are also clearly identified by a red message.

To learn more:
In the US: applicable laws and regulations include the Export Administration Regulations (“EAR”) established under the US Department of Commerce, the International Traffic in Arms Regulations (“ITAR”) established under the US Department of State, and the embargo controls administered by the US Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”). Learn more at http://www.pmddtc.state.gov.

In the UK: export controls are governed by the Export Control Organization (ECO) under the UK Department for Business, Innovation and Skills (BIS). For more information, contact [email protected] or call 020 7215 5000.

ENVIRONMENTAL COMPLIANCE

RoHS - EU Directive 2011/65/EU

EU Directive Requirement - The Directive requires that the homogeneous materials within new electrical and electronic equipment must contain less than 0.1% by weight of lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) and less than 0.01% Cadmium. A list of exemptions for the use of the above substances in specific items is given in Annexes III and IV of Directive 2011/65/EU. The Directive also allows some additional, broader exemptions, for example equipment intended for Military purposes.

PEI-Genesis’ Statement - Although PEI-Genesis is a distributor and most of our products are outside the scope of Directive 2011/65/EU either because they are components or as they are specifically manufactured for use in the military or aerospace sectors, we are committed to helping our customers find information regarding RoHS in order to reduce or eliminate hazardous substances, including using substitutes as and when they become available to the industry.

REACH Compliance

REACH regulation (EC) No 1907/2006 is legislation on chemicals and their safe use, and came into force in June 2007. REACH is aimed at improving the protection of human health and the environment through better and earlier identification of the properties of chemical substances as well as progressive substitution of the most dangerous chemicals when suitable alternatives have been identified.

Substances of Very High Concern (SVHCs)

Under REACH, the most hazardous substances on the market are gradually being added to a list known as the 'Candidate List,' with the view of ensuring their use is correctly controlled, and that safer alternatives are found as soon as possible. The substances on this list are termed 'Substances of Very High Concern' (SVHCs). Cadmium was added to the Candidate List, and hence became a SVHC, on the 20th of June 2013. Lead was added to the Candidate List and became a SVHC on the 27th of June 2018.

Article 33 of REACH

Article 33 requires that any supplier of an article in the EU containing SVHCs above the threshold of 0.1% weight by weight must provide sufficient information to the customer to allow safe use of the article.

The relevance of SVHCs to PEI-Genesis’ products

A number of products that PEI-Genesis supplies are cadmium-plated, and hence contain more than 0.1% by weight of cadmium, an SVHC. Some of our products are affected by Lead with over 0.1% weight, but unlike Cadmium, users of our connectors are not in direct contact with that substance. Lead is a component of the copper alloy, brass, aluminum that is protected by a layer of various other platings such as a layer of nickel, or gold on the surface of the connectors. Not all of our solder is lead free, direct contact with lead in these instances may be possible, and we are gradually working towards favoring lead-free solder.

PEI-Genesis is committed to helping our customers identify parts that contain cadmium and/or Lead providing information to allow safe use of the substance.

Click to read our Safe Use Information for Cadmium

Click to read our Safe Use Information for Lead

Dodd-Frank Act / Conflict Minerals

In 2012, the US Securities and Exchange Commission (SEC) issued rules implementing the ‘conflict minerals’ disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). As a Value-Add Distributor, PEI does not manufacturer any products relieving us from Conflict Minerals reporting obligations. We recognize that suppliers will provide an important link in the due diligence and reporting efforts of our customers. PEI’s approach is to promote the traceability and transparency of supply chains and move towards a conflict-free global supply chain.

‘Conflict Minerals’ in this context refers to specific minerals originating from mines controlled by armed groups in the Democratic Republic of the Congo (DRC) or adjoining countries. The ‘Conflict Minerals’ include Gold (Au), Tin (Sn), Tantalum (Ta), and Tungsten (W).

PEI-Genesis does not purchase minerals directly from mines, smelters, or refiners. Given the fact PEI-Genesis is layers removed from upstream stakeholders, it is difficult to effectively influence their purchasing behaviors, especially within a short period of time. Declarations (CMRTs) look retrospectively at procurement; so, at the time a CMRT is provided, material from smelters may already be part of our connector manufacturer’s supply chain and products. Therefore, actions requesting immediate removal (stopping the use of material from a smelter) of a smelter of concern cannot always be fulfilled. PEI will campaign on a yearly basis to obtain the latest manufacturer’s CMRT report. These yearly campaigns provide direction to the manufacturer’s CMRT for our customers who enquire about CMRT data for products distributed by PEI-Genesis. Click to download PEIs Due Diligence Testament Letter.

California Proposition 65

Proposition 65 requires warnings on products sold in California that contain Proposition 65-listed chemicals at levels that could cause significant exposure to consumers who purchase such products for their personal use or enjoyment. Products that contain Proposition 65-listed chemicals at levels that do not cause significant exposure to consumers are exempt from Proposition 65. Products that contain listed chemicals that are not manufactured for consumer use are also exempt from Proposition 65. Click to download our California Proposition 65 Compliance Statement.