REACH Compliance Declaration — Automatic Valve Industrial

ROSS's Status as a Downstream User

Under the REACH regulation, ROSS is classified as a downstream user because it uses chemical substances and mixtures in its manufacturing processes but does not manufacture or import raw chemical substances into the EU. As a downstream user, ROSS relies on information provided by its supply chain to assess the chemical content of materials and components used in its products. ROSS is not required to register substances with ECHA because its products are non-chemical articles that, under normal and reasonable use, do not release harmful substances. ROSS does not manufacture substances or preparations, and the expected use of its products will not cause the intentional release of substances.

What Is REACH?

REACH stands for Registration, Evaluation, Authorization and Restriction of Chemicals. It is a comprehensive regulation of the European Union, adopted in 2006 under Regulation (EC) No. 1907/2006, that addresses the production, import, and use of chemical substances within the EU. REACH places the responsibility for understanding and managing the risks associated with chemical substances on the companies that manufacture, import, or use them. The regulation is administered by the European Chemicals Agency (ECHA), headquartered in Helsinki, Finland.

REACH has several key objectives: to ensure a high level of protection for human health and the environment from the risks posed by chemicals, to promote alternative methods for hazard assessment, to enhance the competitiveness and innovation of the EU chemicals industry, and to ensure the free movement of substances within the internal market. REACH applies to all chemical substances, not just those used in chemical processes, meaning that articles and products containing or releasing chemical substances are also within its scope.

Substances of Very High Concern (SVHCs)

A central element of REACH is the identification and regulation of Substances of Very High Concern. SVHCs are chemicals that may have serious and often irreversible effects on human health and the environment. A substance may be identified as an SVHC if it is carcinogenic, mutagenic, or toxic for reproduction (CMR); is persistent, bioaccumulative, and toxic (PBT); is very persistent and very bioaccumulative (vPvB); or causes an equivalent level of concern, such as endocrine-disrupting properties. ECHA maintains a candidate list of SVHCs that is updated periodically, currently containing 250 entries. Companies that supply articles containing SVHCs above 0.1% by weight are required to provide sufficient information to downstream users and consumers to allow safe use of the article.

Registration, Evaluation, Authorization, and Restriction

REACH operates through four main processes. Registration requires manufacturers and importers of chemical substances in quantities of one tonne or more per year to register those substances with ECHA and provide data on their properties, hazards, and uses. Evaluation allows ECHA and EU member states to evaluate registration dossiers and test proposals to ensure compliance and assess risks. Authorization requires companies to obtain authorization for the use of SVHCs that have been added to the Authorization List (Annex XIV), ensuring that adequate controls are in place or that viable alternatives are being pursued. Restriction allows the EU to impose conditions or bans on the manufacture, marketing, or use of substances that pose unacceptable risks to health or the environment.

REACH Compliance for Pneumatic Valve Products

Pneumatic valves, solenoid valves, and related fluid power products manufactured by Automatic Valve Industrial are classified as articles under REACH. An article is defined as an object whose function is determined by its shape, surface, or design rather than by its chemical composition. Because pneumatic valves are mechanical or electromechanical devices designed to control the flow of compressed air, they are not classified as chemical substances or preparations under REACH.

ROSS has conducted a thorough review of the materials and components used in its products and has confirmed that SVHCs are not present above the 0.1% by weight threshold in any of its products or packaging. The materials commonly used in pneumatic valve manufacturing include aluminum, brass, steel, zinc, various elastomers and polymers, and lubricants. ROSS works closely with its supply chain to obtain material declarations and certificates of compliance to verify the chemical content of incoming materials and components.

No Registration or Authorization Required

Because ROSS products are non-chemical articles that do not intentionally release substances under normal and foreseeable conditions of use, ROSS is not obligated to register with ECHA. Additionally, ROSS does not foresee any registration, pre-registration, or authorization requirements for the products it supplies. This determination is based on the nature of the products (mechanical and electromechanical devices), their intended use (industrial pneumatic control), and the absence of SVHCs above the reporting threshold.

Why REACH Compliance Matters for Industrial Customers

REACH compliance is essential for companies that manufacture, assemble, or sell products in the European Union. Under REACH Article 33, any supplier of an article containing an SVHC above 0.1% by weight must provide sufficient information about the substance to allow safe use, including at minimum the name of the SVHC. This duty of communication extends throughout the entire supply chain, from raw material suppliers to final product manufacturers and retailers.

For OEMs and system integrators that incorporate Automatic Valve products into their own equipment, the REACH compliance declaration provides documented assurance that the supplied components do not trigger SVHC communication obligations. This simplifies compliance for downstream manufacturers, reduces the administrative burden of SVHC tracking, and supports the assembly of technical documentation required for EU market access. Companies with environmental management systems or corporate sustainability commitments also benefit from sourcing REACH-compliant components as part of their responsible supply chain management practices.

Customer Notification Commitment

ROSS has committed to immediately notify its customers should it become aware that any of its products or packaging contains substances on the SVHC candidate list exceeding concentrations of 0.1% by weight. This proactive communication approach ensures that downstream users have the information they need to maintain their own REACH compliance and to fulfill their duties of communication to their customers and consumers.

Download the REACH Compliance Declaration

The complete REACH Compliance Declaration issued by ROSS Controls, covering Automatic Valve Industrial, ROSS DECCO, and Master Pneumatic products, is available for download in PDF format. This document can be used by procurement teams, compliance officers, environmental managers, and supply chain quality engineers to support supplier qualification, REACH compliance documentation, and technical file assembly for products destined for EU markets.

Frequently Asked Questions

Does ROSS need to register its products under REACH?

No. ROSS products are non-chemical articles (mechanical and electromechanical pneumatic valves) that do not intentionally release substances under normal conditions of use. Therefore, ROSS is not obligated to register with the European Chemicals Agency (ECHA) and does not foresee any registration, pre-registration, or authorization requirements for its products.

What is the SVHC candidate list, and how does it apply to Automatic Valve products?

The SVHC candidate list is maintained by ECHA and currently contains 250 entries of Substances of Very High Concern. ROSS has confirmed that its products do not contain any SVHCs above the 0.1% by weight threshold. This means Automatic Valve products do not trigger the REACH Article 33 communication obligation regarding SVHCs.

How often is the REACH SVHC candidate list updated?

ECHA updates the SVHC candidate list periodically, typically twice per year. ROSS monitors these updates and reviews its product materials against the current list. The most recent list referenced in the ROSS declaration is ECHA/NR/25/20, published in June 2025.

Can I use the ROSS REACH declaration for my own compliance documentation?

Yes. The ROSS REACH Compliance Declaration can be included in your supplier qualification files, technical documentation for CE marking, and REACH compliance records. The declaration provides documented evidence that components sourced from ROSS, Automatic Valve, ROSS DECCO, and Master Pneumatic meet REACH requirements.

What happens if an SVHC is later found in ROSS products?

ROSS has committed to immediately notifying its customers if it becomes aware that any of its products or packaging contains substances on the current SVHC candidate list exceeding concentrations of 0.1% by weight. This ensures downstream users can take appropriate action to maintain their own REACH compliance.