AXING AG surveys and monitors its suppliers, as well as the articles used in its products, with regard to substances of very high concern (SVHCs) in accordance with the REACH Regulation. On this basis, AXING AG confirms that – with the exception of lead – none of the substances listed on the ECHA Candidate List (https://chem.echa.europa.eu/obligation-lists/candidateList) is present in a concentration above 0.1 % weight by weight (w/w) in any of the articles incorporated in its products. This statement is based on the ECHA Candidate List as updated on 4 February 2026 (253 entries).
Substance concerned
Lead, CAS No. 7439-92-1, EC No. 231-100-4, on the Candidate List since 27 June 2018.
Products affected
According to the available supplier declarations and material data, lead is present in AXING products exclusively in F-connectors (F-sockets and F-plugs) made from a lead-containing copper alloy (‘free-cutting brass’). The following are affected:
In products where the F-socket is an integral part of the die-cast housing, no lead-containing copper alloy is used. These products are not affected by this information.
Basis of assessment
According to the judgment of the Court of Justice of the European Union (CJEU) of 10 September 2015 (Case C-106/14), an article incorporated into a complex product remains an article within the meaning of the REACH Regulation as long as it retains its special shape, surface or design (the ‘once an article, always an article’ principle). The 0.1 % (w/w) threshold therefore applies to the individual article – in this case, the F-connector as a whole – and not to the total weight of the end product or the cable.
Duty to provide information
As the lead content of these F-connectors exceeds the threshold of 0.1 % (w/w), there is an obligation under Article 33 of the REACH Regulation to provide information to recipients of the articles. AXING AG fulfils this obligation by means of this customer information. On request, we will inform you which specific products are affected.
Guidance on safe use
When installed and used as intended, no significant exposure to the lead bound in the material is to be expected under normal handling conditions. Mechanical or thermal processing of the material is not part of the intended use of the products. At the end of their service life, the products must be disposed of in accordance with the applicable waste disposal regulations.
Restriction under REACH Annex XVII, entry 63
For lead in articles that are supplied to the general public and may be placed in the mouth by children, REACH Annex XVII, entry 63(7), applies. Articles falling within the scope of the RoHS Directive 2011/65/EU are exempted under entry 63(8)(k)(iv); for these, RoHS exemption 6(c) contains its own, equivalent condition (see Statement on the RoHS Directive). The AXING products concerned comply with the applicable requirements.
All AXING products falling within the scope of the RoHS Directive 2011/65/EU, as amended, are RoHS-compliant. RoHS compliance is declared in the respective EU declaration of conformity and is a prerequisite for CE marking.
RoHS exemption 6(c)
Insofar as the lead-containing copper alloys of the aforementioned F-connectors are used in electrical and electronic equipment, their use falls under RoHS exemption 6(c) in Annex III to Directive 2011/65/EU. This exemption permits copper alloy containing up to 4 % lead by weight, relative to the homogeneous material, i.e. the copper alloy itself. The copper alloys used in AXING products have a lead content of less than 4 % by weight.
REACH and RoHS apply different thresholds: the threshold of 0.1 % (w/w) under Article 33 of the REACH Regulation refers to the article and triggers an obligation to provide information. The RoHS Directive limits lead to 0.1 % by weight in homogeneous materials; by way of derogation, RoHS exemption 6(c) permits up to 4 % lead by weight in copper alloys. The obligation to provide information under REACH therefore does not preclude RoHS compliance.
Commission Delegated Directive (EU) 2025/2364 renewed RoHS exemption 6(c) until 30 June 2027. A further application for renewal was submitted in December 2025. In accordance with Article 5(5) of Directive 2011/65/EU, the exemption remains valid until the European Commission has taken a decision on this application.
The same Delegated Directive introduced an additional condition for the application of the exemption: for electrical and electronic equipment intended for supply to the general public, where the equipment itself or its accessible parts may be placed in the mouth by children during normal or foreseeable use, RoHS exemption 6(c) applies only under the conditions laid down in the exemption. The AXING products concerned meet these conditions.
Technical background
In copper alloys, lead acts as a chip breaker and lubricant and improves their machinability (see recital 3 of Commission Delegated Directive (EU) 2018/741). Lead-free copper alloys require a technical reassessment and qualification on a component-by-component basis. AXING AG uses lead-free copper alloys wherever technically feasible.
This customer information will be updated whenever the ECHA Candidate List is updated or the RoHS exemptions are amended. The latest version can be found at www.axing.com. For product-specific enquiries, please contact umwelt@axing.com.
The information on substance content is based on supplier declarations and on data collected as part of our ongoing due diligence process for goods and materials from suppliers. It reflects the state of knowledge as at the date stated. AXING AG reserves the right to update this customer information as required. The statements in the EU declarations of conformity for the respective products remain unaffected.