Materials Compliance

At Emerson, we strive for a best-in-class supply chain across our businesses and around the world. We are committed to working with suppliers who​ adhere to the Emerson Supplier Code of Conduct and actively manage and demonstrate materials compliance with pertinent governmental laws and regulations, including REACH, Ro​HS and Conflict Minerals.

Hazardous Substances
Emerson’s European suppliers are required to comply with all relevant requirements of REACH and RoHS​. In addition, these suppliers must meet our contractual terms and conditions covering components used in products within the scope of RoHS.  Non-European suppliers are required to meet the requirements for RoHS and REACH as specified in the Emerson contractual terms and conditions. 

In order to comply with hazardous substances legislation globally, Emerson requires Full Material Declaration (FMD), unless otherwise agreed.


REACH is the European Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It went into effect on June 1, 2007.

REACH shifts the responsibility from public agencies to industry when it comes to assessing and managing the risks posed by chemicals and providing appropriate safety guidelines for their users. REACH impacts many sectors beyond the chemicals industry, requiring new forms of cooperation among companies and enhanced communication along the entire supply chain. It also requires the creation of tools and guidance documents to assist companies in the supply chain and public agencies in the implementation of REACH. 

REACH’s objectives are to ensure a high level of protection for human health and the environment, including the promotion of alternative test methods, as well as the free circulation of substances on the internal market and the enhancement of competitiveness and innovation.

​European Commission’s REACH page​​
European Chemicals Agency’s REACH page 

RoHS is the European Directive on The Restriction of Hazardous Substances (RoHS). The original RoHS Directive was adopted on January 27, 2003, and was revised on June 8, 2011. Today, this revised directive is often referred to as “RoHS II”. 

This directive restricts the use of certain hazardous substances in electrical and electronic equipment. The list of restricted substances includes: Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent chromium (Cr6+), Polybrominated biphenyls (PBB), Polybrominated diphenyl ether (PBDE), and added in 2015: Bis (2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP), Diisobutyl phthalate (DIBP). ​ 

RoHS II has introduced new obligations for conformity assessment, declaration and marking, and its scope has been extended to all electrical and electronic equipment (EEE). RoHS II is a CE marking directive, which​ means the producer has placed the CE mark on finished EEE products as a declaration that the product is RoHS II compliant and meets all of the requirements established by the European Union. 

​European Commission’s ROHS page

Conflict Minerals
The U.S. Securities and Exchange Commission adopted a final rule on August 22, 2012 to implement the “conflict minerals” provision of Section 1502 of the Wall Street Reform and Consumer Protection Act, better known as the Dodd-Frank law. The rule requires U.S. public companies to report annually on their efforts to determine whether or not their products contain metals mined from the Democratic Republic of Congo (DRC) or an adjoining country – and whether funds flowing to the mines supplying those conflict minerals – are benefiting, directly or indirectly, armed groups in the DRC region. 

The term “Conflict Minerals” includes:  Cassiterite (Tin ore); Columbite-tantalite, aka Coltan (Tantalum ore); wolframite (Tungsten) and Gold.  These are collectively known as “3TG minerals.”

The SEC’s final rule on Conflict Minerals applies to Emerson and, consequently, affects suppliers of products, parts and/or materials that are incorporated into Emerson’s products, regardless of where the supplier is located.

Emerson works aggressively with industry groups and other stakeholders to develop and implement policies and systems to reduce the risk that minerals in our supply chain come from mines that finance or benefit armed groups in the DRC region. In 2014, Emerson joined the Conflict Free Sourcing Initiative to be more active in making informed choices in the management of its supply chain.

An Emerson supplier is required to cooperate fully with Emerson in these efforts.  A supplier’s willingness to work with Emerson on our supply chain governance initiatives is critical to our future buying decisions and a company’s status as an Emerson supplier. Emerson requires its suppliers to:

  • Implement a Conflict Minerals policy in accordance with applicable SEC rules.
  • Send surveys to their suppliers to collect appropriate information to complete Emerson’s Conflict Minerals survey. Emerson uses the standard Conflict Minerals Reporting Template form to survey its suppliers and Emerson encourages its suppliers to do the same.
  • Provide timely updates to Emerson when requested to do so.


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