Product Compliance

The TSR Business Unit offers as a service to customers a variety of standard letters attesting to the compliance status of their products with respect to various regulations across all regions of the world.  The determinations are made through a collaborative effort between the relevant experts within the production, quality, technical, and strategic marketing functions within the business unit and the professionals in the global Industrial & Environmental Affairs Group Function.

One can find descriptions of a selected group of regulations on these pages together with links to the standard letters which give the current status of our products.  Select the topic of interest from the list on the left side of this page to access the descriptions and the links relevant to that topic.  These standard letters are valid as of the date of issuance.  Please contact your TSR representative in the case of a missing declaration or if you need additional information about a given topic.

Substances of Very High Concern (SVHC)

With reference to the status of REACH for Tire & Specialty Rubbers (TSR), we can confirm that TSR has successfully submitted all necessary registration dossiers to ECHA for the substances that meet the requirements of the 2010 deadline (Phase I) or took care, that our raw materials (incl. monomers) have been registered. We are delighted to be able to inform you that we have successfully completed the second REACH registration (phase II) comprising the registration of substances in volumes of between 100 and 1,000 metric tons. Please be informed that our products do not contain Substances of Very High Concern (SVHC) indicated by ECHA for REACH, above relevant concentration limits.

Although these substances are not intentionally added, this does not exclude the presence of traces due to (among others) impurities in the components supplied by third parties and used in our production facilities. However, based on information from our raw material suppliers we conclude that these traces are less than the Classification & Labelling related threshold values.


⇒Statement SVHC for our X_Butyl® Grades





PAH : Compliance with EU 1907/2006, annex 17 and EU 2005/69/EC

Hereby we confirm that our Butyl and Polybutadienes comply with the requirements of European Directive 2005/69/EC (amending 76/769/EC) and with EU 1907/2006, annex 17

⇒Letter of confirmation : Compliance with EU 2005/68/EU and EU 1907/2006XVII




Directive EC No. 1907/2006, Annex XVII

Restrictions on the Manufacture, Placing on the Market and Use of Certain Dangerous Substances, Preparations and Articles

Restriction of Hazardous Substances (RoHS)

Regulation on End of Life Vehicles (ELV) :  Directive 2000/53/EC and amendments prohibits the use of lead, mercury, cadmium, or hexavalent chromium in materials and components of vehicles other than in cases listed in Annex II to that Directive and under the conditions specified therein.

Directive on Electrical and Electronic Equipment (EEE):  Directive 2011/65/EU, which supersedes Directive 2002/95/EC, restricts the use of certain hazardous substances in electrical and electronic equipment.  The restricted substances are listed in Annex II of the Directive, with exceptions given in Annexes III and IV, and they include lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), or polybrominated diphenyl ethers (PBDE) with maximum tolerated concentration values by weight of 0.1% (0.01% for cadmium).

⇒Compliance statement



Absence of Phthalates 2005/84/EC and GB/T 21911

Hereby we confirm that the in the EU Directive 2005/84/EC listed substance were not use for the production of the products of the BU-TSR.

⇒Letter of confirmation_EU 2005/84/EC and GB/T21911





Absence of dimethylfumarate (DMF) _EU 2009/251/EC

We confirm that no dimethylfumarate (DMF), CAS# 624-49-7, has been intentionally added to the production process of our Butyl and Polybutadienes. Therefore, we do not expect DMF to be present in our products.

⇒Letter of confirmation_EU 2009/251/EC

Absence of Perfluorooctane sulfonates_EU 2006/122/EC

As stipulated in European Directive 2006/122/EC we hereby confirm that no Perfluorooctane sulfonates, as metal salt or free acid, has intentionally been added to the final production step or is used during of its manufacturing of our products and that they are not known to be present above unavoidable ubiquitous traces in the final products.

⇒Letter of confirmation EU Directive 2006/122/EC

Absence of Asbestos

Hereby we confirm that asbestos has not been intentionally added to the production process of our Butyl and Polybutadienes. Therefore, we do not expect asbestos to be present in our products.

⇒Letter of confirmation_Absence of asbestos




Conflict Minerals

Neither synthetic rubber nor the raw materials which are used to manufacture synthetic rubber are in any way associated with smelting operations of minerals.

Therefore, the question of the Use of Conflict Minerals, which is specifically relevant to the electronics industry, is not relevant to our products. The US Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 specifically states that the rule does not apply to products for which conflict minerals are not necessary in the functionality or production thereof. lssuers of products which do not apply to the rule are "not required to take any action, make any disclosures, or submit any reports under the final rule.

⇒Informal letter





Hans-Juergen Mick

Phone: +49 221 8885 3199

Gilles Arsenault

Phone: +1-519-953-1715