Global Restricted Substances Policy

Introduction

Otter Products, LLC, together with its affiliates and subsidiaries (collectively referred to as “Otter”), is dedicated to safeguarding the health and safety of its customers, employees, and the environment. Otter is committed to designing and manufacturing products that comply with or exceed the applicable regulatory requirements in the regions where Otter operates and sells its products.

Policy Statement

This policy outlines the substances that are restricted or prohibited from use in Otter’s products, packaging, and manufacturing processes. These substances include, but are not limited to, those listed further to the following regulations and standards:

  • The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation of the European Union (EU), which restricts the use of certain substances of very high concern (SVHCs) in articles and preparations.
  • The Restriction of Hazardous Substances (RoHS) directive of the EU, which limits the use of certain hazardous substances in electrical and electronic equipment.
  • The Waste Electrical and Electronic Equipment (WEEE) directive of the EU, which sets collection, recycling, and recovery targets for electrical and electronic equipment.
  • The California Proposition 65 (Prop 65) law, which requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects, or other reproductive harm.
  • The Toxic Substances Control Act (TSCA) of the United States, which regulates the introduction of new or existing chemicals and bans or restricts the use of certain chemicals, including perfluoroalkyl and polyfluoroalkyl substances (PFAS).
  • The Chinese RoHS regulation, which restricts the use of certain hazardous substances in electrical and electronic products sold in China.
  • The EU Biocidal Products Regulation (BPR), which regulates the placing on the market and use of biocidal products that contain or generate active substances.
  • The EU Regulation on Persistent Organic Pollutants (POPs), which bans or restricts the production, placing on the market, and use of substances that persist in the environment and accumulate in the food chain.
  • The EU Regulation on Mercury, which restricts the use and trade of mercury and mercury compounds and prohibits the export of certain mercury-added products.
  • Other regions and countries that have similar or additional regulations or standards on restricted substances.

Otter mandates full compliance with this policy by all suppliers, who must provide relevant information and documentation to verify adherence. Otter also expects its suppliers to communicate this policy to their own supply chains and ensure the same level of compliance. Additionally, Otter conducts periodic testing and audits of its products, packaging, and manufacturing processes to ensure compliance and identify areas for improvement.

This policy is subject to update. This version represents the known and applicable regulations and standards at the time of publication.

Contact Information

For inquiries regarding this policy or to report concerns, please contact [email protected].

Last Updated: December 2024