EU REGULATIONS
FAQs
Frequently Asked Questions about
REACH & Alloys Containing Beryllium
Does the Registration, Evaluation and Authorisation of Chemicals (REACH Regulation) currently restrict the import or use of beryllium-containing alloys?
The vast majority of beryllium-containing alloys and products imported into the European Economic Area (EEA) are classified as articles under REACH and the European Commission (EC) has determined that substances in articles do not require European Chemicals Agency (ECHA) permission to be used or imported into the EEA. This article designation includes copper beryllium (CuBe), nickel beryllium (NiBe) and aluminum beryllium (AlBe) alloys in the form of strip, rod, wire, tube, bar, plate, forgings, extrusions, cast shapes and finished parts. Therefore, beryllium and other elements contained in the most common forms of alloys and products do not have to be authorised to be used or imported into the EEA. It is important to note that these alloys in ingot or powder form and expected to be melted cannot be classified as articles but as mixtures and are regulated in REACH.
I understand that REACH requires registration of substances. Has beryllium been registered in REACH?
Even though the vast majority of beryllium-containing alloys and products provided to European users are articles, the Beryllium consortium (origin of the Beryllium association BeST) has e registered beryllium (CAS number 7440-41-7) and beryllium oxide (CAS number 1304-56-9). Beryllium-containing products may indeed be melted and cast in Europe. Furthermore, this registration is the opportunity to communicate positively about beryllium and to demonstrate scientifically that beryllium metal is, like many other metals, safe when used correctly. This ensures the continued and unhindered use of beryllium-containing products by companies in the EEA.
Is beryllium on the list of Substances of Very High Concern (SVHC)?
No, beryllium is not on the SVHC Candidate List. The initial Substance Evaluation Conclusion Document for beryllium prepared by Germany as part of the “Substance Evaluation” under the Community Rolling Action Plan (CoRAP) program and submitted to ECHA in March 2014 did recommend including beryllium as an SVHC. Stakeholders opposed placing beryllium on the SVHC List and have provided extensive scientific evidence to support their position during the next step in the review process which was a Risk Management Option Analysis (RMOA). Germany published the results of the RMOA in November 2016 and concluded that identifying beryllium as an SVHC was not necessary in lieu of the development and implementation of an EU Occupational Exposure Limit (OEL) and a voluntary product stewardship program The Beryllium Science and Technology Association (BeST) developed and issued a voluntary product stewardship program for beryllium in March 2017 entitled “Be Responsible” which can be found at berylliumsafety.eu. Moreover, beryllium has been included in the Carcinogen and Mutagen Directive (CMD) on 11 July 2019. The CMD features a binding OEL for beryllium (0.6 µg/m3 inhalable 8h TWA). (Directive 2019/983 amending Annex III to Directive 2004/37/EC).
Is there any other important information regarding beryllium and REACH?
Beryllium is not restricted under REACH for professional uses. Beryllium is only restricted for general public uses (REACH Annex XVII - Entry 28). The uses of beryllium-containing casting alloys outside industrial installations (dental or jewellry for example) is advised against.
Beryllium has been identified by the European Commission as one of 30 raw materials determined to be critical to the EU. Materials are designated as “critical” (Critical Raw Materials) when the risks for supply shortage and/or their impacts on the economy are high compared with most other materials. It is widely recognised that beryllium cannot be substituted by any other material in the applications that rely on the unique properties of beryllium to enhance product life, minimize waste, reduce energy utilisation, and allow for product miniaturisation and the decrease of raw material utilisation. More importantly, beryllium cannot be substituted in numerous life-saving and life-enhancing applications that provide for the safety and wellbeing of the general public.
How can I obtain assistance?
If you have any questions regarding regulatory information, would like a copy of any of the documents described in this summary or wish to provide feedback, please contact your usual beryllium-containing materials supplier or BeST.
Frequently Asked Questions about the Banning
or Restricting of Copper Beryllium in Products
(ELV and RoHS Directives)
Is the use of copper beryllium or materials containing beryllium banned or restricted?
No. The use of copper beryllium and beryllium-containing materials is not banned, restricted or otherwise limited by any country worldwide.
Do the EU Directives that address the end-of-life management of automobiles, and electrical and electronic equipment ban or restrict the use of copper beryllium alloys in products?
No. Copper beryllium alloys were not included in any special end-of-life requirements or restrictions in the final EU directives on End-of-Life Vehicles (ELV) , , on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS) , or on Waste Electrical and Electronic Equipment (WEEE) . The only metal and metal compounds banned by these directives are lead, mercury, cadmium and hexavalent chromium.
Does the Registration, Evaluation and Authorisation of Chemicals (REACH Regulation) currently restrict the import or use of beryllium-containing alloys?
The above referenced EU directives can be found and downloaded from the internet at the following website locations:
End-of-Life Vehicle Directive
Annex II Amendment to End-of-Life Vehicle Directive
RoHS Directive
Was copper beryllium included in the RoHS Recast adopted by the European Council?
No. The RoHS Recast issued by the European Council on June 8, 2011 and Amendments issued March 31, 2015 do not include the addition of beryllium or beryllium oxide to the list of restricted substances in electrical and electronic equipment (EEE) nor does it include any requirements related to beryllium or beryllium oxide in EEE. Therefore, copper beryllium alloys, as well as all beryllium-containing alloys, can continue to be used in EEE and are in conformance with the RoHS Directive.
The European Union conducted an assessment using the new RoHS methodology and issued a technical report in September 2019 (Version 2) recommending that beryllium and compounds continue to be used in electrical and electronic equipment (EEE) and should not be restricted. Industry strongly supports this recommendation as confirmation of the material’s strategic value for many industry sectors due to its unique combination of properties that are unmatched by any other material. The continued use of Beryllium in EEE is beneficial to end users in terms of product performance, reliability and product lifecycle.
Microelectronic designers, engineers and manufacturers can be confident that beryllium-containing alloys will continue to be available to provide unique and reliable design solutions in EEE without legislative restrictions.
Does the IEC 62474 - Material Declaration for Products of and for the Electro-technical Industry ban or restrict the use of copper beryllium alloys in products?
No. The use of copper beryllium and beryllium-containing materials is not banned, restricted or otherwise limited by the IEC 62474 - Material Declaration for Products of and for the Electrotechnical Industry. IEC 62474 is a voluntary standard, originally developed by the Consumer Electronics Association (CEA®), DIGITALEUROPE and the Japanese Green Procurement Supply Standardization Initiative (JGPSSI), adopted by the International Electrotechnical Commission and supported by companies in the electronics industry.
How can I obtain assistance?
If you have any questions regarding regulatory information, would like a copy of any of the documents described in this summary or wish to provide feedback, please contact your usual beryllium-containing materials supplier or BeST.
Additionally, information on the Beryllium Product Stewardship Program “Be Responsible” Worker Protection Model and process specific safety guidance can be found at www.berylliumsafety.eu.