Declarations
LINAK® is committed to providing our customers with products that meet a high standard of innovation, performance, and environmental safety. This high standard of compliance is also set as a requirement for our suppliers. Achieving this target requires the ability to quickly adapt to the following environmental regulations, directives, and conventions:
- REACH (Registration, Evaluation and Authorization of Chemicals) (Regulation (EC) No 1907/2006)
- RoHS (Reduction of Hazardous Substances) (Directive 2011/65/EU and Directive 2015/863)
- PFAS (Per- and Polyfluoroalkyl Substances)
- Battery Directive (2006/66/EC and Directive 2013/56/EC)
- California Proposition 65 (Safe Drinking Water and Toxic Enforcement Act of 1986)
- Toxic Substances Control Act (TSCA)
- MDR (Medical Device Regulation)
- POP (Persistent Organic Pollutants) ((EU) No 2019/1021)
- Minamata Convention on Mercury
- Packaging and packaging waste directive
- Biocompatibility
- EU Ecolabel
- WEEE directive (Waste Electrical and Electronic Equipment)
- PVC-Free™
- ZERO™ standby technology
- Recycled materials
- Conflict minerals
REACH
The Registration, Evaluation and Authorization of Chemicals regulation is a European regulation on chemicals. LINAK supports the objectives of the REACH (Regulation (EC) No 1907/2006) and complies with the following regulations:
- Candidate List of SVHCs
- REACH Annex XIV – Authorization list
- REACH Annex XVII – Restriction List
The European Chemicals Agency (ECHA) added Lead to the Candidate List of Substances of Very High Concern (SVHC), on June 27, 2018. (www.echa.europa.eu/web/guest/candidate-list-table).
A part of the LINAK product range is affected by this inclusion, meaning that Lead is contained in some products with a concentration above 0.1% (w/w). Where reasonably technically possible, LINAK aims to substitute Lead in our products.
Read more about the REACH statement for LINAK.
RoHS
Reduction of Hazardous Substances (RoHS) is a European directive (Directive 2011/65/EU and Directive 2015/863) that restricts the use of hazardous substances in electrical and electronic equipment. At LINAK, we are continuously monitoring new coming regulations in the EU RoHS directive. All LINAK products are RoHS compliant at all times.
Read more about the current valid RoHS statement for LINAK.
PFAS
PFAS (Per- and Polyfluoroalkyl Substances) are a large, complex group of synthetic chemicals that are difficult for the environment to degrade. For this reason, PFAS are also known as "forever chemicals".
LINAK is aware that the manufacturing and usage of PFAS are in the process of being restricted under REACH, and we are currently in the process of documenting our use of PFAS (analysis expected to be completed by Q2-2024). We support and keep up to date with the REACH restriction proposal to ensure that our products continue to meet the REACH requirements.
Read our LINAK PFAS statement.
Battery Directive
The Battery Directive (2006/66/EC and Directive 2013/56/EC) establishes rules regarding placing batteries, accumulators, and waste batteries on the market containing hazardous substances. It also establishes specific rules for the collection, treatment, recycling and discarding of waste batteries and accumulators. LINAK complies with and meets all obligations related to this directive, including marking batteries with crossed-out wheelie-bin and chemical signs: Pb (lead), Cd (cadmium) and/or Hg (mercury) – according to which chemical that exists in which battery, above the threshold.
Proposition 65
Proposition 65 (Safe Drinking Water and Toxic Enforcement Act of 1986) is a California law that requires businesses to notify Californians about significant chemicals that cause cancer or birth defects or other reproductive harm. Through the analysis of item specifications, internal and external data gathering, LINAK has identified a number of products that currently require a warning label to be applied when shipping to California.
Read more about the Proposition 65 statement of LINAK.
Toxic Substances Control Act (TSCA)
TSCA Section 6(h) of the Toxic Substances Control Act, focuses on the expedited regulation of persistent, bioaccumulative, and toxic (PBT) chemicals. The Toxic Substances Control Act (TSCA) allows the US Environmental Protection Agency to restrict the use of certain substances, like PBT chemicals, in order to help reduce exposure. On January 6, 2021, the Agency restricted the use of 2,4,6-tris (tert-butyl) phenol (“2,4,6-TTBP”), Decabromodiphenyl ether (“DecaBDE”), Hexachlorobutadiene (“HCBD”), Pentachlorothiophenol (“PCTP”) & Phenol, isopropylated phosphate (3:1) (“PIP (3:1)”).
Read more about the TSCA Section 6(h) statement of LINAK.
Medical Devices Regulation (MDR)
The MDR entered into force on May 25, 2017 and has been mandatory since May 26, 2021.
LINAK products are not classified as medical electrical equipment or systems, nor do they fall within the scope of the EU Medical Device Directive/Regulation or other similar national regulations. The products are components to be built into a piece of medical electrical equipment by a manufacturer. However, we acknowledge the need for medical device manufacturers to be informed about substance content.
The MDR requires the manufacturer of medical devices to state whether the medical device contains Latex or not. Regarding Latex, we can advise, to the best of our knowledge, that none of our MEDLINE® products contain this substance.
As this is an ongoing process, we will provide information about progress in a timely manner.
POP
POPs (Commission Regulation (EU) No 2019/1021 on Persistent Organic Pollutants/Stockholm Convention, is a list of chemical substances posing a risk of causing adverse effects to human health and the environment. LINAK complies with the chemical substances listed in the POP regulation.
Minamata Convention on Mercury
LINAK is subject to The Minamata Convention on Mercury, as signed by Denmark on October 10, 2013 and approved on May 18, 2017. Therefore, LINAK complies with this convention that aims to protect human health and the environment from releases of mercury and mercury compounds.
Packaging and packaging waste directive
LINAK declares that our basic packaging method is cardboard boxes on disposable pallets, heat-treated according to IPPC standard ISPM No. 15, which complies with the Packaging and packaging waste directives 2018/852, 2004/12/EC and the amendment in 94/62/EC. See statement in QA-16-09-008.
Biocompatibility
LINAK MEDLINE®& CARELINE® products, intended to be incorporated into electrical medical equipment and systems, comply with IEC 60601-1:2012 clause 11.7. All parts of the products that in normal use can come into contact with the skin surface of the patient or the user are assessed. Assessment is according to post-observation experience and the nature and duration of anticipated contact with human tissues when in use. The assessment is based on LINAK products being non-invasive and in contact with intact skin only. Declaration of Biocompatibility.pdf
EU Ecolabel
Established in 1992, and recognized across Europe and worldwide, the EU Ecolabel is a label of environmental excellence that is awarded to products and services meeting high environmental standards throughout their life cycle. The EU Ecolabel is a voluntary label promoting environmental excellence, which can be trusted and, among other things, sets demands on ingredients taking the users into account. The Ecolabel applies to furniture, for example, and more and more furniture manufacturers apply for this label for their products. LINAK manufactures components, not end products; thus, LINAK products are not within the scope of the EU Ecolabel. However, as we deliver components used in furniture, we pay attention to the demands and standards, and several of our standard DESKLINE® products meet these demands. If you would like to know more about which LINAK DESKLINE products can help you obtain the EU Ecolabel, please contact your local subsidiary, or use this e-mail chemicalcompliance@linak.com.
WEEE directive (Waste Electrical and Electronic Equipment)
Some of the LINAK products are marked with a crossed-out wheeled bin symbol. This symbol indicates that the product falls within the scope of the WEEE Directive and must not be disposed of in unsorted waste.
By ensuring this product is disposed of correctly, you help prevent potential negative effects on the environment and on human health due to inappropriate waste treatment. Please ask your local authorities or your European retailer for information about the disposal locations for this product.
It is the responsibility of the user of the electronic product to separate the battery, insofar as is technically possible, prior to disposal. It is also the responsibility of the user to delete any personal data when applicable.
LINAK is registered with the relevant authorities in countries where LINAK falls within the scope of the producer definition of the WEEE Directive and finances its recycling contributions accordingly.
PVC-Free™
PVC-free™ products from LINAK include cables, control boxes, columns, and actuators, as well as control panels – all available for desks, workstations, or kitchen applications. For more information see the link below or contact your local subsidiary.
LINAK PVC-free™: Eco-friendly electric linear actuator systems
ZERO™ standby technology
LINAK ZERO™ technology keeps standby power consumption in adjustable office desks, workstations, and kitchen applications as low as <0.1W – reducing CO₂ emissions to an absolute minimum.
LINAK has developed ZERO™ technology for most control boxes and has set new standards for what is considered responsible standby consumption in applications such as office desks. Contact your local subsidiary for more information.
Recycled materials
Environmental Product Summary (EPS)
For some LINAK DESKLINE systems, LINAK has created an Environmental Product Summary. The declaration states the amount of recycled and recyclable material used in the systems, based on a thorough evaluation of the products and on input from suppliers.
LINAK is committed to providing our customers with products that meet high standards in innovation, performance, and environmental care. Please find the EPS documents available below:
- EPS Desk Frame 1 (DL5/DL6) EMEA (Europe, Middle East and Africa)
- EPS Desk Frame 1 (DL5/DL6) North America
- EPS Desk Frame 2 EMEA (Europe, Middle East and Africa)
How LINAK ensures Component Compliance
LINAK makes all reasonable efforts to ensure appropriate and timely handling of updates in the directive and regulations. Responsibilities and appropriate resources have been assigned to enable us to comply, and LINAK has set up a procedure to handle and ensure chemical compliance. As a part of this procedure, LINAK uses a third-party data management solution to gather information. This information is provided by suppliers in the form of declarations, which are then uploaded in the aforementioned database and monitored by us regularly.
If you need more information or have other requests regarding chemical compliance, please contact chemicalcompliance@linak.com
Dodd-Frank Act on Conflict Minerals
Background
In August 2012, the United States Securities and Exchange Commission (SEC) approved the Final Rule regarding the sourcing of conflict minerals as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. This rule applies to publicly-traded US companies, and requires these companies to report their usage of conflict minerals originating from the Democratic Republic of Congo (DRC) to the SEC on an annual basis.
The US Congress passed the Dodd-Frank Act because of concerns that the exploitation and trade in minerals from the DRC and neighboring countries were financing armed groups, and thereby fueling the ongoing conflict in the area. It is widely reported that armed groups fight for control of mines and use forced labor to mine and transport minerals. The income from these illegal activities funds conflicts in the DRC region and contributes to an emergency humanitarian crisis.
The conflict minerals within the scope of the SEC Final Rule are tin, tantalum, tungsten and gold (3TG), both in the form of ore and as refined materials. The countries concerned include: the Democratic Republic of Congo (DRC), Republic of Congo, Central African Republic (CAR), South Sudan, Rwanda, Uganda, Zambia, Angola, Burundi, and Tanzania.
The Dodd-Frank Act is only applicable to US-listed companies, but their suppliers will also be involved in ensuring compliance with the Act as a contractual obligation.
What is required by a US-listed company?
US-listed companies that use any of the 3TG’s in their products are required to perform a ‘Reasonable Country of Origin Inquiry’ (RCOI). The enquiry must be performed in good faith, and must be designed to determine whether any of the conflict minerals originated from the covered countries, or are from scrap or recycling sources. US-listed companies must submit an annual Conflict Minerals Report to the SEC, with a description of the RCOI process and results.
US-listed companies must undertake due diligence on the source and supply chain of its conflict minerals, if there is reason to believe that the minerals have originated in the covered countries and the minerals are not from scrap or recycling sources.
The SEC classifies the US-listed companies’ products as “DRC Conflict Free”, “Not DRC Conflict Free”, “DRC Conflict Undeterminable”, or “Recycled, or Scrap Due Diligence”. US-listed companies filed their first Conflict Minerals Report to the SEC on May 31, 2014 (for the 2013 calendar year) and must conduct the reporting annually hereafter.
What is the impact on the supply chain of US-listed companies?
US-listed companies are required to provide full disclosure of the content and origin of conflict minerals in their products, and will therefore require their suppliers to declare the content and origin of conflict minerals in supplied products, or maybe even to declare that all products delivered to the customer are “DRC Conflict Free”.
Although the Dodd-Frank Act only applies to US-listed companies, suppliers to US-listed companies will be required to conduct RCOI and due diligence on conflict minerals.
LINAK activities concerning conflict minerals
LINAK is working actively towards full disclosure of the origin of 3TG in our products. However, due to the size and complexity of our global supply chain, it will take some time before we are fully able to provide our US customers all the information required to fulfill their disclosure obligations.
LINAK has taken the following actions:
- We have created a policy outlining our principles and commitment to conflict-free sourcing.
- We are implementing a Reasonable Country of Origin Inquiry (RCOI) process to identify tantalum, tin, tungsten, and gold (3TG) in our supply chain and to determine, to a reasonable extent, the country of origin of these metals. The purpose of these processes is to identify the smelters in our supply chain to be able to conduct due diligence, and thereby facilitate DRC conflict-free sourcing.
- We are incorporating the principles of this policy into our Purchasing Terms and we are working with our suppliers to increase the transparency of our supply chain. We are communicating our policy to suppliers, and we support relevant industry initiatives to stop the possible inclusion of conflict minerals in our products.
LINAK is supportive of applicable international database systems providing relevant disclosure of origin, including the use of the Conflict Minerals Reporting Template (CMRT). LINAK is using the ComplianceMap portal to collect CMRT’s from our supply chain.
Click here to read the LINAK policy on conflict minerals
Customers seeking information from LINAK about conflict minerals are welcome to contact the Conflict Minerals Compliance Team at conflictminerals@linak.com.
Supplier Requirements
LINAK requires suppliers who provide components or materials containing 3TGs to actively work towards DRC conflict-free sourcing. LINAK suppliers must perform their own RCOI and due diligence processes in order to facilitate valid and reliable DRC conflict-free sourcing. We expect our suppliers to work with their own suppliers, in the same way, to ensure traceability of conflict minerals to the originating smelters.
All suppliers are required to provide LINAK with a CMRT through the ComplianceMap portal. If this is not possible, LINAK requires CMRT reports to be sent directly to the Conflict Minerals Compliance Team at conflictminerals@linak.com.