COMPLIANCE

Comer Industries operates in compliance with Regulation 1907/2006/EC (REACH) concerning the registration, evaluation, authorization and restriction of chemical substances, therefore it is continuously monitoring its products in order to assess the applicability and compliance with all the requirements of the Regulation.

For this purpose, Comer Industries has requested from all its suppliers detailed information regarding the presence of Substances of Very High Concern (SVHC) in the Candidate List with concentrations higher than 0.1% by weight on the weight of the article (w/w).

Based on this information, Comer Industries found the presence of:

• Lead CAS 7439-92-1 in some articles with a concentration higher than 0.1% (w/w) in some metal components such as plugs, greasers, fittings, bushings and valves assembled in complex objects belonging to the following product families:
  
  • Gearboxes
  • Planetary drives
  • Axles
  • Drive Shafts
  • Tactor Attachment Systems
  • PTO Drive Shafts

• Other Substances of Very High Concern in some articles with a concentration higher than 0.1% (w/w):
• Bumetrizole CAS 3896-11-5, Imidazolidine-2-thione CAS 96-45-7 in some protective elements of the PTO Drive Shafts and Drive Shafts.
• Dodecamethylcyclohexasiloxane CAS 540-97-6 and Bisphenol A CAS 80-05-7 respectively in some sensors and filters of Gearboxes.

Consequently, Comer Industries, as required by Directive 2018/851/EC – articles 9 (1)(i) and 9(2) – which amends Directive 2008/98 / EC, registered into SCIP Database the articles and the complex objects containing concentrations of SVHC in the Candidate List above the threshold of 0.1% (w/w) and is constantly working on updating it.

The RoHS (Restriction of Hazardous Substances) EU Directive limits the use of certain hazardous substances – such as lead, mercury, or cadmium – in electrical and electronic equipment to protect human health and the environment.

Even the impact of the RoHS Directive is very limited and restricted to a reduced number of components eventually integrated in some products, Comer Industries maintains appropriate procedures to assess the presence of these substances in the supplies, ensuring continued compliance with the Directive.

Following the entry into force of Legislative Decree 3 September 2020, No. 116, which transposes EU Directive 2018/851 and EU Directive 2018/852 relating to packaging and packaging waste, Comer Industries, as user of packaging solely for the transport of their products, prefers, in compliance with legal obligations, digital channels to communicate information relating to the environmental labelling of packaging.

In this regard, the table containing the information on the nature of the packaging materials used, on the basis of Commission decision 97/129/EC is reported below.

Conflict Minerals – such as Tin, Tantalum, Tungsten, and Gold (3TGs) – are sometimes sourced from regions where their extraction contributes to the financing of armed conflict and serious human rights abuses. Under Section 1502 of the U.S. Dodd-Frank Act, publicly listed companies are required to disclose the origin of these minerals and demonstrate that the extraction of 3TGs does not contribute to conflict or human rights abuses in the countries named in the Regulation. As part of the policy of responsible sourcing, Comer Industries is committed to ensure to source from conflict free smelters and to implement due diligence measures to identify the sources of 3TGs in the supply chain, following internationally recognized assessing and reporting standards as provided by Responsible Minerals Inititative (RMI).

The Carbon Border Adjustment Mechanism (CBAM) is a climate policy instrument introduced by the European Union to align the import of carbon-intensive products, such as steel, aluminium, cement, and fertilizers, with EU climate standards. The goal is to prevent carbon leakage and ensure fair competition for EU manufacturers.

Comer Industries core products, such as gearboxes, drive shafts, axles, are currently not directly subject to CBAM. However, some sourced components made from CBAM relevant materials fall within its scope.

In accordance with the Regulation, Comer Industries has put in place measures to:

• document and report all imported goods under the scope of CBAM according to the CBAM transitional mechanism;
• monitor the regulatory developments until the end of the transitional phase;
• ensure full compliance with all obligations during the future operational phase.

The Act on Corporate Due Diligence in Supply Chains (Lieferkettensorgfaltspflichtengesetz – LkSG, hereinafter the German Supply Chain Act) mandates that companies adopt responsible practices across their entire value chain, ensuring the safeguarding of human rights, environmental protection, and ethical conduct in all business operations.

Following an exhaustive due diligence process concerning human rights and environmental protection, Comer Industries has integrated the arrangements of the German Supply Chain Act, extending its monitoring and control mechanisms throughout the supply chain supporting its operations in Germany. Furthermore, the Company is actively working toward compliance with the upcoming European Corporate Sustainability Due Diligence Directive (CSDDD), to ensure full adherence ahead of its future application.