Confidential Document!

Sukano Polymers
To whom it may concern Corporation
295 Parkway East
Duncan
SC
29334
USA

Phone: +1 864 486 1478

Fax: +1 864 486 3681
Duncan, 11.08.2023

Declaration of Compliance

SUKANO®T ma S732 / Matting for BOPET

For our SUKANO®T ma S732 the compliance of the following mentioned regulations can
be confirmed under the specifically mentioned restrictions.

Commission Regulation (EC) No. 2023 / 2006

Our product SUKANO®T ma S732 respectively its manufacturing process is in compliance
with the relevant requirements of the Commission Regulation (EC) No. 2023 / 2006 on
Good Manufacturing Practices. Our integrated Quality Management System assures that a
constant quality of our SUKANO® masterbatches and compounds can be delivered to
our customers. Our products are produced by well trained staff, and for each of our
product a quality test procedure and product specifications are defined. The product
quality is checked on systematically taken random samples and each produced lot gets
approved by our quality control department if it complies with the defined specifications.
All test results are documented and systematically filed.

Framework Regulation (EC) No. 1935 / 2004

Our product SUKANO®T ma S732 complies with the relevant requirements laid down in
the Framework Regulation (EC) No. 1935 / 2004 as amended, and therefore allows
compliance of the finished materials and articles with this regulation, presuming
appropriate processing and use of the product under Good Manufacturing Practices
environment.

Commission Regulation (EU) No. 10 / 2011

The polymers, respective their monomers and the additives used in the formulation of our
product SUKANO®T ma S732 comply with the Commission Regulation (EU) No. 10 / 2011
on plastic materials and articles intended to come into contact with food, and
amendments in force, with the restrictions listed in the table below.

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Sukano Polymers
Corporation
Terephthalic acid SML(T): 7.5 mg / kg
295 Parkway East
Isophthalic acid SML(T): 5 mg / kg Duncan
Ethylene glycol SML(T): 30 mg / kg in combination with diethylene SC
glycol 29334
USA
Acetaldehyde SML(T): 6 mg / kg
Antimony trioxide SML: 0.04 mg / kg, expressed as antimony Phone: +1 864 486 1478
Our product may contain up to 300 ppm of Fax: +1 864 486 3681
antimony trioxide mostly embedded in the
polymer matrix
Aluminium SML: 1 mg / kg
Our product may contain up to 100 ppm of
aluminium mostly embedded in the polymer
matrix
Lead SML: ND
May be present as impurity, max. 1 ppm
Nickel SML: 0.02 mg / kg
May be present as impurity, max. 1 ppm
Annex II & point 6 of Annex IV Based on suppliers' information and the
knowledge of our manufacturing process,
the following can be stated: this product may
contain additional substances subject to
restrictions in Annex II at concentrations not
expected to lead to an exceedance of their
migration limits, provided that the product is
used at recommended dosage levels.
Additional substances for which genotoxicity
has not been ruled out, and which originate
from an intentional use, as stated by the
point 6 of Annex IV, are not known or
expected to be present in our product. The
product is however not analyzed for these
substances

Total migration limit GML: 10 mg / dm², respective 60 mg / kg food

Dual Use Additives

Our product SUKANO®T ma S732 contains the following dual use additives subject to a
restriction in food legislation as listed in the Regulations (EC) No. 1333 / 2008 and (EC)
No. 1334 / 2008, and subsequent amendments, and for which risk assessment indicates
that a significant migratory contribution from the packaging can be made even if the
product is used below the recommended maximum dosage:

Inorganic matting agent Identity can only be disclosed for testing purposes
upon request and under secrecy

Commission Regulation (EC) No. 1895 / 2005

Based on suppliers’ information and the knowledge of its manufacturing process, we
confirm that our product SUKANO®T ma S732 complies with the Commission Regulation

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Sukano Polymers
Corporation
(EC) No. 1895 / 2005 on the restriction of use of certain epoxy derivatives in materials and
295 Parkway East
articles intended to come into contact with food. Duncan
SC
Allergen Information 29334
USA
We herewith state that that based on suppliers’ information and the manufacturing
process of our product SUKANO®T ma S732, it is unlikely that substances listed in Annex Phone: +1 864 486 1478
II of the Regulation (EU) No. 1169 / 2011 and in the FDA Food Allergen Labelling and Fax: +1 864 486 3681
Consumer Protection Act of 2004 (FALCPA) are present in the product. We do not
intentionally add these substances to our product nor do our suppliers in the raw
materials used.

Nanomaterial
In our product SUKANO®T ma S732 one or more components are used that
were declared from our supplier to appear with nano-sized particles as
defined by the European recommendations 2011 / 696 / EU).

Swiss Ordinance 817.023.21 on Materials and Articles in Contact with Food

Our product SUKANO®T ma S732 complies with the requirements defined in the Swiss
Ordinance 817.023.21 on materials and articles that come into contact with food. Identical
restrictions and limitations as stated above for Commission Regulation (EU) No. 10 / 2011
apply.

German Federal Institute for Risk Assessment (BfR) Recommendations

Our product SUKANO®T ma S732 complies with the following German Federal Institute
for Risk Assessment (BfR) recommendations:

Chapter XVII
Chapter LII
For the use as additive in plastic articles coming into contact with food.
The migration limits of the German Ordinance on Commodities are identical to that of the
Commission Regulation (EU) No. 10 / 2011 above.

US FDA Status
Our product SUKANO®T ma S732 is in compliance with the US FDA Food Packaging
Regulation 21 CFR to be used as additive in plastic articles coming into contact with food
in accordance with the following paragraphs:

Polymer §177.1630
Inorganic matting agent §178.3297

The product can be used in food packaging material under conditions of use as described
in §176.170(c) A through H.

The product is approved for the use in food contact applications coming into contact with
all types of food according to the description in §176.170 (I-IX).

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Sukano Polymers
Corporation
European Directive 94 / 62 / EC on Packaging and Packaging Waste
295 Parkway East
Based on suppliers’ information, we confirm that all ingredients used in the formulation of Duncan
our product SUKANO®T ma S732 meet the requirements of the European Directive 94 / SC
62 / EC and its amendments on packaging and packaging waste. The given limits for the 29334
USA
heavy metals lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr VI+)
are never exceeded. Heavy metals such as Pb, Cd, Hg and Cr VI+ are neither intentionally Phone: +1 864 486 1478
added nor used in the manufacture of our mentioned product. Fax: +1 864 486 3681

Model Toxics in Packaging Legislation (formerly CONEG)

Based on suppliers’ information, we confirm that all ingredients used in the formulation of
our product SUKANO®T ma S732 do not contain the heavy metals lead (Pb), cadmium
(Cd), mercury (Hg) and hexavalent chromium (Cr VI+) as intentionally added substances.
Moreover, these metals are not intentionally used in the manufacture of our product. The
sum of the concentration levels of these metals in our product is therefore not expected
to exceed the set limit of 100 ppm by weight.

Additionally, based on raw materials’ information, we confirm that all ingredients used do
not contain any phthalates as intentionally added substances. Moreover, phthalates are
not intentionally used in the manufacture of our product. The sum of the concentration
levels of phthalates in our product is therefore not expected to exceed the set limit of 100
ppm by weight.

Furthermore, it must be stated that based on raw materials’ information and the
knowledge of our manufacturing process per- and polyfluoroalkyl substances (PFAS) are
not expected to be present in our product.

European Directive 2011 / 65 / EU on the Restriction of Hazardous Substances

Regulations (RoHS)
We confirm that our product SUKANO®T ma S732 complies with the European Directive
2011 / 65 / EU and its amendments, known as RoHS Directive. According to our suppliers’
information, all ingredients of our above-mentioned product are in compliance with the
mentioned Directive. Furthermore, we confirm that none of the substances listed in Annex
II neither appear as part of the formulation of our mentioned product nor are
intentionally added during manufacture.

European Directive 2012 / 19 / EU on Waste Electrical and Electronic Equipment

(WEEE)
We confirm that our product SUKANO®T ma S732 complies with the European Directive
2012 / 19 / EU and its amendments, known as WEEE Directive. The restricted substances
listed in Annex VII of the mentioned legislation do not appear in any ingredients of our
product. Furthermore, we confirm that none of these substances neither appear as part of
the formulation of our mentioned product nor are they intentionally added to the product
during manufacture.

Toy Standards
We confirm that our product SUKANO®T ma S732 complies with the restrictions of the
Toy Standard DIN EN 71 part 3 and part 9 as well as with the ASTM F963-08 Standard

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Sukano Polymers
Corporation
Chapter 4.3. However, it is to mention that no migration tests were done on our product
295 Parkway East
as they have to be done on the final end application. Duncan
SC
European Regulation (EC) No. 1005 / 2009 on Substances that Deplete the Ozone 29334
USA
Layer
Herewith, we confirm that our product SUKANO®T ma S732 does not contain any Phone: +1 864 486 1478
substances listed in the European Regulation (EC) No. 1005 / 2009 as ozone depleting Fax: +1 864 486 3681
substance.
According to suppliers’ information, ozone depleting substances do not appear in any of
the ingredients used in our mentioned product. Furthermore, we confirm that ozone
depleting substances are neither part of our formulation nor are they intentionally added
to our product during the manufacture.

California Proposition 65
The substances listed in the table below, which fall under the reporting requirements of
the State of California Safe Drinking water and Toxic Enforcement Act of 1986, known as
California Proposition 65 (status: April 21st, 2023), can be present in our product
SUKANO®T ma S732.

Substances CAS No. Comment

Acetaldehyde 75-07-0 Unavoidable degradation product.
May appear in trace amounts
Antimony trioxide 1309-64-4 Used as a catalyst, max. 300 ppm
Ethylene glycol 107-21-1 Used as monomer, max. 100 ppm

REACH Registration Status and Absence of SVHC Substances

Our product SUKANO®T ma S732 is a polymer / mixture and therefore excluded from
registration obligation in accordance with Regulation (EC) No. 1907 / 2006 (REACH). All
monomers, pigments and / or additives have been registered by the corresponding actors
up the supply chain or are exempted from REACH registration obligation.
Furthermore, we confirm that our product SUKANO®T ma S732 does not contain any
substances of very high concern (SVHC) as declared by the European Chemicals Agency
ECHA (status: June, 14th, 2023) as part of our formulation at levels of >0.1% nor are they
intentionally added.

Absence of Bisphenol A
Herewith, we declare that our product SUKANO®T ma S732 does not contain Bisphenol A
(4,4′-Isopropylidendiphenol, CAS: 80-05-7). This substance is neither intentionally added
to any of the ingredients used in this product, nor is it part of the product's formulation.

BSE / TSE Statement

To the best of our knowledge, all ingredients in our product SUKANO®T ma S732 are not
of animal origin and consequently do not present any risk of BSE (Bovine Spongiform
Encephalopathy) or any TSE (Transmissible Spongiform Encephalopathy) contamination.

Regulation (EC) No. 1223 / 2009 on Cosmetic Products

Herewith, it shall be stated that our product SUKANO®T ma S732 contains the following

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Sukano Polymers
Corporation
substances, banned or restricted to be used in cosmetic articles according to the
295 Parkway East
Regulation (EC) No. 1223 / 2009, Annex II and III: Duncan
SC
Substances CAS No. Comment 29334
USA
Acetaldehyde 75-07-0 Unavoidable degradation product.
May appear in trace amounts Phone: +1 864 486 1478
Antimony trioxide 1309-64-4 Used as a catalyst, max. 300 ppm Fax: +1 864 486 3681

Disclaimer
This regulation is valid for the above mentioned product only. It is not applicable to:
- a later change of the formulation of the masterbatch
- any treatment leading to a change of the masterbatch properties
- the compatibility with packed goods in relation to a possible change in smell or taste of
the foodstuff.

It is the responsibility of our customer to determine that their use of our product is safe,
lawful and technically suitable for their intended applications. Furthermore, it is the
customer's responsibility to check whether the intended use of the product infringes third
party intellectual rights. Sukano accepts no responsibility for the suitability of its products
for use in the application intended by the customer and offers no guarantee that its
products can be used in any specific combination or in any manufacturing process
without infringing third party rights. Because of possible changes in the law and in
regulations, as well as possible changes in our products, we cannot guarantee that the
status of this product will remain unchanged. We therefore recommend that customers
continuing to use this product verify its status periodically.

Sukano AG
Augustin Tchawou
Regulatory Affairs Manager

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