QAL has been manufacturing and using parts that are RoHS compliant for the last several years.

RoHS Compliance

Quality Assembly & Logistics, LLC (QAL) has been manufacturing and using parts that are RoHS compliant for the last several years. A majority of QAL products are RoHS compliant. All QAL products that are compliant with the RoHS Directive (EU Directive 2002/95/EC and subsequent amendments) are marked “RoHS COMPLIANT.” RoHS COMPLIANT means that the substances restricted by the EU Directive 2002/95/EC and subsequent amendments of the European Parliament are not contained in a finished product above threshold limits stated below unless the restrictive substance is subject of an exemption contained in the RoHS Directive, QAL considered the amendment to the Annex II, dated March 31, 2015. The Amendment to Annex II, dated March 31, 2015 additionally restricts the use of DEHP, BBP, DBP, and DIBP in Electrical and electronic equipment and becomes effective July 22, 2019.
QAL cannot guarantee that inventory held by distributors or other third parties is RoHS compliant.

Restricted Substance Maximum Threshold Limit
Cadmium and its compounds 100 ppm (0.01 weight %)
Mercury and its compounds 100 ppm (0.01 weight %)
Hexavalent chromium and its compounds 100 ppm (0.01 weight %)
Lead and its compounds ** 100 ppm (0.01 weight %)
Polybrominated biphenyls (PBB) 100 ppm (0.01 weight %)
Polybrominated diphenyl ethers (PBDE) 100 ppm (0.01 weight %)
Bis (2-Ethylexyl) phthalate (DEHP) 100 ppm (0.01 weight %)
Benzyl butyl phthalate (BBP) 100 ppm (0.01 weight %)
Dibutyl phthalate (DBP) 100 ppm (0.01 weight %)
Diisobutyl phthalate (DIBP) 100 ppm (0.01 weight %)
**Except when allowed by the Directive. For example, 3500 ppm in steel, 4000 ppm in aluminum alloys and 40000 ppm in copper alloys.

The compliance of QAL products with RoHS is affected through:

  • Controlling the materials and finishes that are used in our products.
  • Periodic audits of our suppliers to ensure compliance
  • Periodic analysis, on an as-needed basis, of our products

Before Directive 2011/65/EU is in full force, QAL will continue to mark our parts as “RoHS Compliant,” implying that the parts meet requirements of Directive 2002/95/EC.

Once Directive 2011/65/EU (RoHS- Recast) is fully implemented, certain products may have “CE” marking in an effort to consolidate marking requirements as mandated by the European Parliament.

REACH Compliance

In June 2007, the European Union Regulation (EC) 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) was first released. This Regulation establishes specific duties and obligations for companies in the European Union (EU) that manufacture or import substances on their own, in preparations or in articles.

  • Under the structure of the REACH Regulation, Quality Assembly & Logistics, LLC (QAL) is a manufacturer and supplier of “articles” to our EU customers through QAL Distributors located within the EU. We do not manufacture or supply “substances” or “preparations” and our articles do not involve the “intentional release of substances”. Accordingly, we foresee no registration or pre-registration requirement for the products we supply you.
  • QAL is constantly monitoring the Substances of Very High Concern (SVHC), as defined by REACH in our products. Constant monitoring will be an on-going process since the complete list of SVHCs will be released and updated in stages.
  • QAL’s customers are always encouraged to visit the following site to get the most up to date information on current list of SVHCs under REACH: https://echa.europa.eu/candidate-list-table
  • QAL products (articles) do not contain Substances of Very High Concern (SVHC) above the threshold value declared as per ECHA with 181 SVHC at current date.

 

REACH Compliance

In June 2007, the European Union Regulation (EC) 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) was first released. This Regulation establishes specific duties and obligations for companies in the European Union (EU) that manufacture or import substances on their own, in preparations or in articles.

  • Under the structure of the REACH Regulation, Quality Assembly & Logistics, LLC (QAL) is a manufacturer and supplier of “articles” to our EU customers through QAL Distributors located within the EU. We do not manufacture or supply “substances” or “preparations” and our articles do not involve the “intentional release of substances”. Accordingly, we foresee no registration or pre-registration requirement for the products we supply you.
  • QAL is constantly monitoring the Substances of Very High Concern (SVHC), as defined by REACH in our products. Constant monitoring will be an on-going process since the complete list of SVHCs will be released and updated in stages.
  • QAL’s customers are always encouraged to visit the following site to get the most up to date information on current list of SVHCs under REACH: https://echa.europa.eu/candidate-list-table
  • QAL products (articles) do not contain Substances of Very High Concern (SVHC) above the threshold value declared as per ECHA with 181 SVHC at current date.

 

Conflict Minerals

Quality Assembly & Logistics, LLC is committed to be compliant with section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding the sourcing of tantalum, tin, tungsten and gold from certain mines within the DRC – Democratic Republic of the Congo to adjoining countries as are defined in the act.

Conflict Minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively “3TG”). As required by Rule 13p-1 under the Securities Exchange Act of 1934, companies that manufacture or have manufactured products containing conflict minerals that are necessary to the functionality or production of the product to disclose annually whether any of those minerals originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country. If the conflict minerals originated in any of those countries, the Rule requires companies to submit a report to the Securities and Exchange Commission (“SEC”) that includes a description of the measures taken to exercise due diligence on the conflict mineral’s source and chain of custody, a description of the products manufactured or contracted to be manufactured that are not DRC conflict free or undeterminable, the facilities used to process the conflict minerals, the country of origin of the conflict minerals, and the efforts to determine the mine or location of origin.

Supply Chain Inquiries

For the purpose of preparing our annual report, QAL reviews our supply base in order to determine the suppliers of materials/components that possibly contain 3TG. This review occurred for all material suppliers. Based upon the results of the review described, we conducted a survey of our direct suppliers that were determined to be potential suppliers of conflict minerals ultimately contained within our products.

Our objective in conducting this survey was to understand the following:

  • Do any of the parts supplied to QAL contain 3TG?
  • Are any of the conflict minerals necessary to the functionality or production of the product?
  • Do any of the metals originate from the DRC or an adjoining country?
  • Is the conflict mineral from recycled or scrap sources?
  • Have the smelters of those metals been identified?
  • Are the smelters that have been identified certified conflict free?

Our inquiries were sent with a stated deadline and followed up with reminder and late notices. In addition, management analyzed the responses received against the pre-determined criteria in order to determine whether further due diligence was required. Additional due diligence included direct follow-up either by telephone contact or the exchange of emails with the suppliers. Our process was designed to identify the source of minerals and determine the chain of custody. If the supplier was able to provide us with a smelter listing, we compared each of the smelter identification codes to the Conflict-free Smelter Program (CFSP”) listing (www.conflictfreesourcinginitiative.org) to determine if the indicated smelter was considered to be in compliance.

QAL has an established Risk Management Plan that evaluates and quantifies various risks facing the company. Any changes to the regulatory needs and decrees, such as the Dodd-Frank Act would be included in the Risk Management Plan. Since we do not typically have a direct relationship with 3TG smelters and refiners, we do not perform or direct audits of these suppliers.
We have many tiers in our supply chain and are therefore dependent upon our suppliers as well as their lower level suppliers to determine which specific smelters are providing the source metals that eventually become incorporated into our products. Our ability to deliver products that are conflict-free is directly dependent on smelters adopting policies, internal controls and due diligence procedures that will provide both QAL and our customers with reasonable confidence that their products are conflict-free. Sue to the limited information provide to us by our suppliers in response to our survey, we are not able to identify all of the various smelting facilities that processed the 3TG contained within our products.

Modern Slavery Act and Human Trafficking

Quality Assembly & Logistics, LLC in support of the Unites States Government policy prohibiting human trafficking. QAL is dedicated to being incompliance with Executive Order 13627 – Strengthening Protections Against Trafficking in Persons in Federal Contacts” and title XVII of the National Defense Authorization Act. We expect our employees, distributors, and suppliers to not use forced, bonded, involuntary prison labor, indentured servants, slavery as to not procure commercial sex acts or engage in human trafficking. These stipulations include but are not limited to the following:

  • Transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, abduction, coercion or any fraudulent activity for the purpose of exploitation
  • Concealing, confiscating, destroying, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as driver’s licenses or passports irrespective of issuing authority
  • Using any fraudulent or misleading practices during the recruitment process

Failure to comply with these rules could result in disciplinary action up to and including termination.

Quality assembly & Logistics, LLC has had rules in place against using forced labor, including illegal child labor, slave labor and abusive punishment of workers. QAL works on trying to comply with all of the applicable employment and labor laws within each country that the company conducts business. The use of forced, child or slave labor is prohibited for any person providing any service or represent any QAL Medical, LLC product. We expect all distributors, contractors and suppliers to abide by these policies.

QAL has human trafficking awareness training provided to all employees, this is done to help identify, recognize and mitigate risks within our supply chain and distributor base. Any violation of law relating to basic working conditions and human rights, including laws regarding human trafficking, and slavery will be considered a breach and ground for contract termination.

Quality Assembly & Logistics, LLC

QAL is an industry leader in lean manufacturing and modular assembly solutions.
We have earned a reputation of diversity, dependability and quality at a competitive price.

Contact Quality Assembly & Logistics, LLC today for all your electro-mechanical assembly needs.
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