Substances of Very High Concern (REACH Article 33)

Under Article 33 of EU REACH (Regulation (EC) No 1907/2006) and the equivalent provision of UK REACH, we have to tell you when something we sell contains a substance on the Candidate List of Substances of Very High Concern at more than 0.1% by weight, and how to use it safely. This page is that information, kept in one place so you do not have to ask for it.

The substance

Lead. EC number 231-100-4, CAS number 7439-92-1. Added to the REACH Candidate List in June 2018, classified as toxic for reproduction.

Where it is in our products

Our machined brass is CZ121 (European designation CW614N), a free-cutting brass containing approximately 3% lead by weight. Lead is alloyed into the metal itself. It is not a plating, a coating or a surface treatment.

Free-cutting brass is the standard material for precision-turned parts. The lead is what lets the alloy be machined to the tolerances and the finish these products need.

This applies to the brass parts of:

Pens and pencils — Mechanical Pen, Mechanical Pencil, Fountain Pen, Journeyman Pen, Pocket Pen, the World Explorer editions, and the Triumph Heritage pen and pencil.
Desk pieces — Pen Holder, Pen Rest, Triumph Heritage Pen/Pencil Holder, and the fastener on the Triumph Heritage Pen Slip.
Key carry — Key Cache, Key Fob, Key Fob Set, Key Loop, and the Triumph Heritage Key Cache and Key Loop.
Cufflinks — Block Cufflinks in brass.
Belts — the Block Buckle, where the brass finish is chosen.
Bags and hardware — machined pullers and bag hardware, where the brass finish is chosen.

Where brass is one finish among several, this applies only to the brass version. Our stainless steel, black steel and titanium parts are not affected.

Using these products safely

Ordinary use — writing, carrying keys, wearing a belt — is what these products are made for and needs no special precaution. The following are the sensible limits.

Wash your hands after handling brass for a long stretch, and before eating.
Do not machine, file, grind, saw, sand or melt these parts. That is what generates lead dust and fume, and it is the one thing to avoid.
These are not children's products. Keep small components away from young children, and do not let anyone mouth or chew them.
Do not use brass parts for food or drink contact. (Our hip flasks are stainless steel or titanium for exactly this reason — never brass.)
At end of life, recycle brass as scrap metal. Do not put it in household waste.

Asking us for more

If you want this information for a specific product, or a written declaration for your own compliance records, email hello@wingback.co.uk with the product name. There is no charge, and we will reply within 45 days as REACH requires — in practice, considerably sooner.

Customers in California

Products containing our machined brass carry a California Proposition 65 warning on their product page. It is the same material and the same fact, stated in the form Californian law requires.

Wingback Ltd, Unit 2.03, Oxo Tower Wharf, London SE1 9PH, United Kingdom. Registered in England and Wales, company number 10948782. Last reviewed 21 August 2026.