As a manufacturer of measuring systems and measuring machines (products), Mahr GmbH is considered a "downstream user" in the sense of the REACH regulation. The products are, therefore, generally not subject to registration under REACH.
The chemical substances and substance mixtures used in the production and assembly of our measuring systems and components that are subject to registration are essentially limited to very small quantities of lubricants, adhesives, paints and varnishes. The substances involved are subject to widespread applications, which are used in high tonnages in many industries. These must only be registered by our suppliers. From the relevant information it can be deduced that a pre-registration or subsequent registration of the relevant substances will be carried out by the upstream suppliers.

As a company that is aware of its social and ecological responsibility, we consider compliance with applicable laws and guidelines to be the basis of our integrity and a central component of our business.
Mahr GmbH is not listed on the US stock exchange and accordingly is not directly obliged to disclose or, as applicable, report on conflict minerals used. Mahr GmbH is not affected either by a direct link to the entire supply chain of US stock exchange-listed companies, as Mahr is not a supplier in the true sense. A supplier is an industrial operation or retailer which supplies companies with products, which the latter then sell on and/or process. Mahr GmbH develops, produces and distributes measuring equipment under its own brand name. These end products are needed for customers’ production, but are not incorporated into their products. A statutory obligation corresponding to Sec. 1502 Dodd-Frank Act is not currently present at European level.
Even without specific statutory obligations, Mahr GmbH is fully aware of its supply chain responsibility. Mahr GmbH understands supply chain sustainability and responsible procurement of raw materials to be an obligation which we assume voluntarily. We consistently follow and rigorously adhere to applicable directives and regulations.
With regard to the Dodd-Frank Act § 1502, the Mahr Group is currently in the process of integrating appropriate processes to avoid trade in conflict minerals originating in Central Africa. Due to our diversity of materials, intensive contact with our well-known suppliers would be necessary to reveal the penetration of the complete supply chain. We cannot at present guarantee that conflict minerals will not be used, but we assure you that we will monitor the issue in accordance with the objectives of the Dodd-Frank Act § 1502.

Manufacturers must subject lithium batteries and lithium cells to various safety tests before they can circulate them on the market. This also includes the so-called UN 38.3 test. This simulates transport conditions such as pressure, temperature, crushing, impact etc. In the "Manual of Tests and Criteria" of the United Nations in Part III, Section 38.3 this is described with 8 test modules, which in some documents and data sheets are also referred to as T.1 to T.8 test.

From January 1, 2020, manufacturers and distributors along the entire transport chain are obliged to provide a test summary of this "38.3 test" to every natural and legal person in the supply chain. The audit report has been compulsory since as far back as 2000, but this was never part of logistics cooperation. Since January 1, 2020, this has been part of the hazardous goods regulations and part of the supply chain. The basis for this is the revision of ADR/RID/ADN 2019, subsection 2.2.9.1.7 (g), which states that "manufacturers and distributors of cells or batteries manufactured after June 30, 2003 shall provide the test summary set out in the Manual of Tests and Criteria, Part III, sub-section 38.3, paragraph 38.3.5".

The same requirement also applies to maritime and air transport. Here, too, the IMDG Code / IATA-DGR stipulates that the 38.3 test must be provided by the confirmed test summary. Every client of a transport is obliged to make sure that a test summary is available - this is required by law. Each consignor must ensure, when placing the order, that the conditions for transport are met.

In the list of products linked below, we fulfil our obligation and link all the necessary test summaries of the battery manufacturers we use for the product. If you have any further questions, our technical consultants will be happy to assist you.

• Mahr test summary UN 38.3 (26 kB, XLS)