Stratton Product Ltd

Certificate of Compliance to:


Stratton Products Ltd (SPL) hereby declare that SPL products comply with the European Directive for the Restriction of use of certain Hazardous Substances (RoHS) including Directive 2015/863 published in 2015 amending Annex II of Directive 2011/65/EU.

We hereby certify that our products do not contain any of the following banned substances, in quantities which would exceed those specified limits (excluding components used that are approved via exemption 7a – Lead in high melting temperature type solders):

  • Lead (Pb): < 1000ppm
  • Mercury (Hg): < 1000ppm
  • Cadmium (Cd): < 100ppm
  • Hexavalent Chromium (Cr6+): < 1000ppm
  • Polybrominated Biphenyls (PBBs): < 1000ppm
  • Polybrominated Diphenyl Ethers (PBDEs): <1000ppm
  • BIS(2-Ethylhexyl) (DEHP): <1000ppm
  • Benzyl butyl phthalate (BBP): <1000ppm
  • Dibutyl phthalate (DBP): <1000ppm
  • Diisobutyl phthalate (DIBP): < 1000 ppm

SPL intends to deal only with suppliers that can demonstrate that they can manufacture their components or materials in an environmentally responsible manner. This declaration is based upon declarations/data supplied by SPL suppliers.



SPL fully supports the aim of Reach in improving the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances.  As a downstream user, the products of SPL are non-chemical products that are not designed to release any substance under normal and reasonably predictable application scenarios during their lifespan. Therefore, as per REACH requirements, SPL products do not need to be registered.


Based on information obtained from our suppliers, this document certifies that NO SPL products contain > 0.1% by weight of the Substances of the Very High Concern (SVHC) as listed by the European Chemical Agency (ECHA) under the provisions of Regulation No. 1907/2006 including the new candidate list that was released on 15th Jan 2019 (197 substances).


All new designs and solutions provided by SPL will give due consideration to the need to reduce hazardous substances.



Conflict minerals are subject to compliance under the U.S. Dodd-Frank Act (which applies to 3TG originating from the DRC and adjoining countries) and the EU Conflict Minerals Regulation (which applies to EU-based importers). CMRT is used to collect refiner and processor information to fulfil regulatory 3TG reporting requirements.  Stratton Products Ltd (SPL) have raised this subject with all our product suppliers and has documented evidence of their compliance via reporting via our “supplier Assessment/Review” process. 

  • SPL does not conduct formal CMRT implementation.



EMRT is a voluntary initiative allowing downstream companies to disclose their cobalt and mica sourcing due diligence efforts in their annual reports and/or websites.  Rather than a requirement, it currently serves as an aid to due diligence and identifying utilized smelters and refiners of cobalt and mica, which was formally launched on 20th October 2021.


However, with a growing demand for cobalt and mica comes major concerns regarding where and how they are sourced. Cobalt and mica are mined in conflict-affected areas, contributing to unethical sourcing issues.  Stratton Products Ltd (SPL) have not instructed our suppliers regarding this, as it is not subject to formal regulation.

  • Our position regarding this will remain “under review” until such Regulation is imposed.


James Cripps

Compliance Manager

Stratton Products Ltd.