PRODUCT COMPLIANCE & EPR: EXTENDED PRODUCER RESPONSIBILITY
Over the past decades, especially in Europe, many legal requirements for products and their manufacturers and distributors have been established and developed into the most advanced worldwide. These requirements primarily serve to protect people and our environment. LINDY stands behind these requirements explicitly and with great commitment and demands the same from its component and accessory manufacturers.
We distinguish between INBOUND and OUTBOUND requirements.
INBOUND requirements are imposed on products, such as RoHS, REACH, POP, CP65, TSCA, EMC, product safety. LINDY stands for compliance with these requirements for our products and our component and accessory suppliers.
OUTBOUND requirements are those resulting from our sales activities to customers, governmental supervisory authorities, and corresponding service providers. These are, for example, product compliance confirmations for customers, the reporting of quantities of WEEE products, batteries and packaging materials placed on the market and the related financing of the recycling and collection systems.
Product Compliance – INBOUND
Material requirements: RoHS, REACH, POP, CP65 and TSCA
LINDY supports the objectives of RoHS, REACH, POP, CP65 and TSCA, and is fully behind the ban of banned substances and materials like PFAS & MCCP, thus protecting the environment and people. We constantly strive to remain a pioneer in our market sector and to ban hazardous substances from our products.
For assuring compliance, we use test reports from accredited test laboratories for products, components, and accessories. However, for practical reasons, a complete analytical product conformity test for each individual production batch is impossible. The product conformity information we provide is based on laboratory test reports for the products, materials, and components, as well as our confidence in our suppliers and their declarations of conformity, including that they do not modify materials.
LINDY even goes beyond these industry standards and also regularly conducts its own random RoHS, REACH, POP, CP65, TSCA and PFAS and other laboratory tests to assess supplier reliability and ensure compliance of LINDY products.
Further details on RoHS, REACH, SCIP and POP can be found below under a separate point.
EMC, RED, LVD and Product Safety Requirements
We are also fully behind these legal product requirements and all our WEEE products have completed the relevant certifications. Our CE and UKCA declarations of conformity are based on test reports from accredited laboratories, and the labels on our products prove this.
OUTBOUND Compliance
INBOUND compliance is largely harmonised in Europe, so that our products meet the European requirements and can be sold in Europe (EU, CH & UK). We explicitly do not support sales into and the requirements of the EEU (Russia, Belarus, etc.).
OUTBOUND compliance is regulated via framework directives in the EU and United Kingdom, but the requirements are legally regulated so differently in each country that each market operator placing products on the market has to comply with the legal requirements in the country where he sells to end users. LINDY itself covers all these requirements with LINDY’s subsidiaries in the following countries: Germany, United Kingdom, France, Italy, Spain.
Furthermore, we cover all requirements in Switzerland, in Portugal via our partner company, as well as WEEE requirements in Luxembourg. Detailed information on registration numbers according to the WEEE, Battery and Packaging Directives as well as legal information on the respective topics and corresponding recycling information and on cooperating collection systems can be found on our respective country pages at the footer of the website.
For legal reasons, in all other countries our local distributors and B2B customers are themselves responsible for compliance with local legal requirements under the EU directives for WEEE, batteries and packaging waste since they are the market operators placing product on their local market.
OUTBOUND – Customer Information
We exclusively supply B2B customers. Upon reasonable request, we provide CE and UKCA declarations of conformity to customers, many declarations are already available on our product websites. We inform about REACH SVHC on every invoice and delivery note with a reference to the following section with our REACH and POP declarations. Upon reasonable product-related request, we also provide individual product-related information on contained SVHC, SCIP numbers and TSCA and California Proposition 65 compliance.
Download this Product Compliance and EPR statement as PDF
REACH & POP REGULATIONS AND EU SCIP DATABASE
Lindy supports the aims of RoHS, REACH and POP and declares its full support for protecting the environment and the population.
Lindy is continuously striving to stay a pioneer in our market sector and to keep any hazardous substances out of our products.
The REACH Regulation addresses chemical substances, and their potential impact on human health and the environment.
REACH Article 67 and Annex XVII define approximately 70 substance class restrictions for certain use cases and product classes. We assure you that our products are, to the best of our knowledge and verification, REACH Article 67 and Annex XVII compliant.
REACH Article 33 defines a duty to inform if products contain substances of very high concern (SVHC) with a threshold value above 0.1% (1000 ppm). The list of SVHC is updated and extended every 6 months by the EU and can be found on the European Chemicals Agency website: https://echa.europa.eu/candidate-list-table.
We assure you that, to the best of our knowledge and according to our tests, the majority of our products do not do not exceed the 0.1% threshold for SVHCs as per Article 33 of the REACH Regulation.
However, the following exceptions may apply:
• Lithium Button Cells: Products with CR2032, CR2025, CR2016, or similar button cells in enclosed remote controls contain the electrolyte EDGME, an SVHC. • Power Supply Units: Products with interchangeable plugs (Euro, UK, US, Australian) contain brass with up to 4% lead, as is common among power supply manufacturers.
• Integrated Power Supply Units: Some units or products with integrated power supplies contain lead compounds in thermally stressed electronic components.
• Electronic Components: Products with electronic components like diodes and MOSFETs, which are thermally stressed, may contain lead compounds.
• Brass Components: Products with brass components, such as screws, threaded inserts, and connectors, may contain up to 4% lead.
For detailed REACH Article 33 statements regarding lead (Pb) and the electrolyte EDGME in lithium button cells, please visit: www.lindy.com/en/reach/.
EU SCIP database Since January 5, 2021, all products containing more than 0.1% SVHC must be registered in the SCIP database. Lindy ensures all our products are registered accordingly. Distributors, retailers, and companies using Lindy products in their own complex products within the EU are also required to comply. We provide an up-to-date Excel file for Simplified SCIP Notifications of all relevant Lindy products. This file is regularly updated and available to our B2B customers in the password-protected section of our EU websites under Customer Service
The EU POP Regulation addresses the production and use of Persistent Organic Pollutants (POPs). These are chemical substances that persist in the environment, bioaccumulate through the food web, and pose a risk to health and the environment. The Regulation defines prohibitions of use as well as concentration limits for substances in articles for certain product classes. We assure you that our products are, to the best of our knowledge and verification, POP compliant.
Lindy Product Compliance Commitment
As a leading company in our sector, you can be sure that we will not introduce any products to market which do not meet with relevant guidelines and laws.
Currently European and UK product compliance requirements such as POP, RoHS and REACH are the most stringent and advanced. In many countries worldwide, POP, RoHS and REACH requirements have been adopted or are in implementation.
These regulations are made to protect people and the environment.
For practical reasons, the complete analytical product compliance testing of all materials, components, and parts from all suppliers for each individual production run is not possible. The product compliance information we provide is based on initial laboratory test reports for the products, materials, and components, as well as on our ongoing assessment of our suppliers.
In addition, Lindy goes beyond these industrial standards and regularly carries out random laboratory RoHS, REACH, POP, CP65, TSCA and PFAS tests to assess the reliability of suppliers and to ensure compliance for Lindy products. For customers using BOMcheck, please reach out to us for further information
Download the REACH and POP compliance document as a PDF
CONFLICT MINERALS
On July 21, 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted into U.S. law. Section 1502 of this Act requires companies to disclose whether their products contain conflict minerals by conducting supply chain due diligence. While LINDY is not directly subject to these requirements, nor to the EU Regulation 2017/821 on conflict minerals—which applies mainly to importers and direct processors—we are committed to transparency and are prepared to provide relevant information on this issue..
Our extensive product range, which includes over 2000 cables and electronic items, is primarily manufactured according to our specifications in Taiwan and China. Due to the complexity of the supply chain, especially for electronic products, the sourcing of raw materials often extends beyond our direct control and involves multiple stages before reaching smelters or metal producers. To address this, we have conducted a supplier survey and compiled the results in our Conflict Minerals Reporting Template (CMRT).
Download our CMRT
Background Information:
Conflict minerals refer to the 3TG metals: tantalum, tin, tungsten, and gold. In our products:
• Tantalum is used extensively in electronics for capacitors.
• Tin is used in soldering on circuit boards and connectors.
• Tungsten is used, albeit less frequently, in chipsets.
• Gold is employed as a coating on connector contacts and in chipsets.
Conflict minerals, as defined by the Dodd-Frank Act, primarily originate from the Democratic Republic of Congo and surrounding countries, where illegal mining activities often finance local conflicts, including those led by rebel groups. Although the situation has improved since 2014 with the establishment of certified supply chains, particularly with EU support, challenges remain, especially with gold. Unlike the 3T metals, gold’s high value and ease of extraction make it particularly vulnerable to smuggling, and its supply chain is harder to regulate.
In alignment with Dodd-Frank Act, we actively encourage our suppliers to adopt responsible sourcing practices for conflict minerals, to help prevent the financing of violence and human rights abuses.
Download our Conflict Minerals document as a PDF
CORPORATE SOCIAL RESPONSIBILITY
Preamble
The Lindy Group and its member companies affirm their Corporate Social Responsibility (CSR) as an integral part of their global business operations . This Code of Conduct (hereinafter referred to as ‘CoC’) outlines the principles guiding our approach, focusing on areas such as working conditions, environmental sustainability, social responsibility , transparency, fostering trust through cooperation and dialogue . Developed and agreed to by the German Central Association of the Electrical and Electronics Industry (ZVEI) and its member companies, the content of this CoC reflects the core values of ZVEI, as articulated in its vision and mission statements and strongly aligns with the principles of a social market economy.
1. Basic Understanding of Social Responsibility in Corporate Management
A mutual, basic understanding of social responsibility in corporate management forms the foundation of this CoC. This means Lindy assumes responsibility by considering the consequences of its business decisions and actions on economic, technological, social and environmental levels and brings about an appropriate balance of interests. Lindy is committed to contributing to the well-being and long-term development of a global society at every point it can and in the locations where it is in business. This commitment is rooted in universally recognized ethical values and principles , including integrity, honesty and respect of human dignity.
2. Where the CSR applies
2.1 This COC is in effect for all Lindy Group companies and business units worldwide. 2.2 Lindy commits to promoting and requiring adherence to the content of this CoC at every point it can for its suppliers and in other parts of the value chain.
3. Core Values for Social Responsibility in Corporate Management Lindy will proactively work to ensure that the values mentioned below are put into practice and adhered to, both now and in the future.
3.1 Adherence to Laws
Lindy will abide by the laws in effect and other legal requirements of the countries where it is in business. For countries that have a weak institutional framework, the company will carefully examine what good company practices from their home country should be applied to enable supportive, responsible company management.
3.2 Integrity and Organizational Governance 3.2.1 Lindy gears its activities towards universally held ethical values and principles, especially integrity, honesty, respect of human dignity, openness and non-discrimination based on religion, ideology, gender and ethnicity.
3.2.2 Lindy rejects corruption and bribery as stated in the relevant UN Convention. It uses suitable means to promote transparency, trading with integrity, responsible leadership and company accountability.
3.2.3 Lindy pursues clean and recognized business practices and fair competition. In regard to competition, it focuses on professional behaviour and high standards of quality for work. It fosters partnership and trusting interaction with the supervisory authorities.
3.3 Consumer Interests to the extent consumer interests are affected, Lindy abides by regulations that protect the consumer, as well as appropriate sales, marketing and information practices. Groups that are in special need of protection (e.g. protection of minors) will receive special attention.
3.4 Communication
Lindy will communicate in an open way and is oriented towards dialogue about the requirements of this CoC and about its implementation among employees, clients, suppliers and other stakeholders. Every document and all information will be duly produced. They will not be unfairly changed or destroyed. They will be properly stored. Confidential company information and partner’s business information will be handled sensitively and will be kept in confidence.
3.5 Human Rights
Lindy is committed to promoting human rights. It respects human rights stated in the Charter of the United Nations, especially those named in the following:
3.5.1 Privacy Protection of privacy.
3.5.2 Health and Safety
Ensuring health and work safety, especially the guarantee of a safe and health-promoting work environment, avoiding accidents and injuries.
3.5.3 Harassment
Employee protection against bodily punishment and against physical, sexual, psychological or verbal harassment or abuse.
3.5.4 Freedom of Conscience
Protection and guarantee of the right to freedom of conscience and freedom of expression.
3.6 Working Conditions
Lindy abides by the following core work standards from ILO (International Labour Organisation):
3.6.1 Child Labour
The prohibition of child labour, i.e. the employment of persons younger than 15 years old, as long as the local legal requirements do not specify a higher age limit and as long as no exceptions are permitted.
3.6.2 Forced Labour
The prohibition of forced labour of any kind. Lindy rejects forced labour in any form and implement strict due diligence to ensure, to the greatest extent possible, that there is no forced labour in our operations or supply chains, particularly as defined by the Uyghur Forced Labor Prevention Act (UFLPA).
3.6.3 Wage Compensation
Work standards concerning compensation, especially in regard to the level of compensation as stated in the laws and requirements that are in force.
3.6.4 Employee Rights
Respecting the rights of the employee to freedom of association, freedom of assembly and collective bargaining, as long as this is legally permitted and possible in the respective country.
3.6.5 Prohibition of Discrimination
Treatment of all employees in a non-discriminatory fashion.
3.7 Hours of Work
Lindy abides by work standards concerning the longest permitted time of work.
3.8 Civic Commitment
Lindy contributes to the social and economic development of the countries and regions where it is in business and promotes appropriate, volunteer activities information by its employees.
3.8 Environmental Protection
Lindy acts in accordance with the applicable laws that affect its respective operations and products and is guided by international standards to minimize negative impacts on the environment and continuously improve our environmental and climate protection activities.
3.10 Handling Conflict Minerals
Lindy is committed to ethical sourcing practices in accordance with the standards of the Responsible Minerals Initiative. The company ensures transparency and accountability in the sourcing of minerals, avoids conflict areas and adheres to the principles of sustainability.
3.11 Responsible Sourcing
Lindy is committed to responsible sourcing and compliance with international regulations, including the UFLPA and the standards of the Responsible Minerals Initiative. These efforts are consistent with our adherence to the ZVEI Code of Conduct, which ensures the protection of human rights and ethical practices in the supply chain.
4. Implementation and Application
Lindy will make every appropriate and reasonable effort to implement and to apply the principles and values described in this CoC both now and in the future. The CoC is valid in its current version (published on www.lindy.com). Lindy reserves the right to amend the CoC and to adapt and interpret it accordingly in the event of changes to laws, customs or other standards.
January 2025