Date: July 2024

RoHS, REACH and WEEE Policy
In line with its Environmental Policy and its Positive Retail Roadmap1, VusionGroup products
comply with the EU REACH Regulation2, the EU RoHS Directive3, and the WEEE directive4. These areintended:-To reduce and restrict substances that are potentially harmful to humans or the environment
To regulate the management of waste arising from electrical and electronic equipment toreduce their environmental impact and promote recycling

Under the EU REACH Regulation, all chemicals manufactured in the EU or imported into the EU market
must be registered if the annual volume used exceeds 1 metric ton. VusionGroup ensures that all its
products fully comply with this chemical control policy by delivering the necessary information to the EUAgency ECHA5.
The EU RoHS Directive stipulates that electrical and electronic products sold in the EU market
may not contain lead, cadmium, mercury, Hexavalent chromium, polybrominated biphenyls (PBBs),polybrominated diphenyl ethers (PBDEs) and other controlled substances (including phthalates
DEHP/BBP/DBP/DIBP). The EU RoHS Directive thus seeks to limit the impact and exposure of consumers
and the environment to specific hazardous substances. It also reduces occupational exposure during
the manufacturing, recycling, or disposal of products or equipment. In line with this directive, the IoTtechnology of VusionGroup has always been eco-designed with authorized substances. The Group’sESLs6 are designed to be repaired, disassembled, and recycled. They are 100% refurbishable: the plastic
used is recyclable, the batteries are replaceable, the casings parts are reusable, and the gluelessassembly allows for easy recycling. Everything placed on the market is also energy efficient: the Groupis constantly striving to reduce its energy consumption and redesign its IoT solutions so that they can,eventually, run without a battery.
The WEEE Regulation complements the previous requirements by aiming to reduce electronic
waste generation, promote recycling, ensure proper handling and treatment of hazardous materials,
This sets out VusionGroup’s commitment to protect the environment by achieving a low-waste, lowcarbon and sustainable digital transformation of the retail sector.
2REACH: Regulation for Registration, Evaluation, Authorization and Restriction of CHemicals (EUchemical control policy)
3
RoHS: Restriction of the Use of Hazardous Substances in Electrical and Electronic Equipment
4
WEEE: Waste Electrical and Electronic Equipment
5
ECHA: European CHemical Agency
6 ESL: Electronic Shelf Labels
1VusionGroup S.A. – 55, place Nelson Mandela – CS 60106 92024 Nanterre – France
A limited company with share capital of €31,917,316
Registration number in the Nanterre Trade and Companies Register: 479 345 464
Tel: + 33 (0)1 34 34 61 61 - Fax: + 33 (0)1 55 69 78 00 www.vusion.com

and set targets for waste collection. The regulation also develops the extended producer responsibility,according to which producers can be made responsible for financing or organizing the prevention andthe management of waste from these end-of-life products. VusionGroup assumes its responsibilities forthe end-of-life of its products by financially supporting several eco-organisms across Europe.
Additionally, the Group, aware of the importance of proactive environmental action, has created theSecond Life Program in 2019 to refurbish ESLs. Indeed, in an ESL: more than 80% of the battery, 100%of the easylock mechanism, up to 99% of the casing can be recycled. Since the creation of the Program,
more than 7 million ESLs have been refurbished.
In conclusion, VusionGroup requires that all parts, components and raw materials provided bysuppliers and used in the production of the Group’s IoTs are RoHS and REACH compliant and respect
the WEEE regulation throughout their lifecycle. This commitment is not only about legal compliance but
also about meeting customer expectations and reducing environmental impact.

VusionGroup S.A. – 55, place Nelson Mandela – CS 60106 92024 Nanterre – France
A limited company with share capital of €31,917,316
Registration number in the Nanterre Trade and Companies Register: 479 345 464
Tel: + 33 (0)1 34 34 61 61 - Fax: + 33 (0)1 55 69 78 00 www.vusion.com