Green Data Exchange Custom Substance List Feature

Material content reporting poses a difficult challenge to many manufacturers. Specific regulations have changed in both the scope of materials covered (RoHS added 4 new substances) and the scope of how the regulation should be interpreted (REACH offers new definition of an ‘article’). In this ever-changing and compulsory setting, there are further complications from emerging regulations and customer requirements for specific material usage. These requirements are passed along to suppliers and some statement of compliance or quality agreement is generally sought.

Full material disclosure is only as good as the ability to search for and recognize specific substances quickly, identifying “at-risk” products and suppliers, and to use the data as proof to a customer who is asking for specific details on material use.

Green Data Exchange (GDX) now offers customized searching of substances and substance groups. You can use a pre-loaded list of substances to determine any usage of particular substances, whether regulated or not. This includes the ability to load a customer’s restricted materials list in order to check and maintain compliance to customer specific requirements. Finally, any restricted substance list can be added to GDX and assessed against existing material data.

Any custom substance list may be added. Lists can also be edited to add or remove substances as requirements change and adapt. Also, applications need not be limited to material content compliance. You can now use GDX to see where specific substances are in your products in order to determine information on potential tariffs, to compare potential replacement parts for material breakdown, to identify different manufacturing streams by substance, and much more.

The new feature works seamlessly with the existing GDX filters on the parts tab. This affords the ability to review restricted substances along with other part details like lifecycle information in order to determine if an action needs to be taken. You can also evaluate a specific product or product family against the restricted substance list by using the existing product compliance module and filters.

As new substances and regulatory substances lists emerge, GDX substance lists will be updated to reflect the latest changes. For example, the “REACH SVHC Candidates” list will be updated with the most recent SVHC Candidate List additions.

To learn more about this feature and others that GDX offers, please review our website.

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ECHA Plans Database on Articles Containing Candidate List Substances

On July 11, 2018, ECHA announced plans for a new database for declaration of information related to articles containing Candidate List Substances. Declarations would be submitted by companies “producing, importing, or selling articles that contain Candidate List substances.”

For use by waste operators and consumers, this new database is being established in accordance with recent updates to 2008/98/EC, the Waste Framework Directive. Changes to the Waste Framework Directive passed on May 22, 2018 and set new targets for reuse and recycling of municipal waste. The database should “help waste operators in treating waste and recycling materials.”

Intention of the database is to help inform consumers to make safer choices, driving safe substitutes to market and “improve the risk management of chemicals during waste recovery” and “promote non-toxic material cycles.”

Current plans indicate the creation of the database by the end of 2019 with companies submitting data by the end of 2020. Note that if you are already using Q Point’s Green Data Exchange, you are already collecting the data and information that you would need to declare information on the use of SVHC in your articles.

Q Point will continue to follow developments on the new database and will post updates to this blog. For companies looking to collect data on Candidate List substances and usage within their own supply chain, please see our website for more details on Q Point’s solution, Green Data Exchange. For more information on the database, please see ECHA’s press release here or information on the Waste Framework Directive here.

New Substances Considered for RoHS – RoHS Pack 15

The addition of seven new substances to the RoHS Annex II restricted substance list is being considered. Per article 6 of 2011/65/EU, restricted substances are to be periodically reviewed and Annex II is to be amended based upon “a thorough assessment.” Most frequently, this annex was updated to include 4 phthalates which will be enforced beginning in July 2019.

The “Study on the review of the list of restricted substances and to assess new exemption request under RoHS 2 – Pack 15,” conducted by Öko Institut & Fraunhofer Institute, sets out to update methodology for the “thorough assessment” of new restricted substances and then perform the assessment on the seven substances considered for inclusion.

The seven substances being considered are:

As an additional task to the assessment of the above substances, an evaluation of potential exemptions is being conducted.

 

To follow along with the project and to see relevant project documentation, please see http://rohs.exemptions.oeko.info/

 

As new substances are added to regulations, customers will need to determine their impact, both internally and upon the supply chain. Some stakeholders may begin inquiring about the presence and use of these substances within their supply chain immediately. In order to handle requests on emerging hazardous substances, you should be able to quickly request substance use information and check against existing data in a real-time environment. Green Data Exchange (GDX) will help you to respond to these requests today. By addressing any customer’s concerns over the use of emerging hazardous substances with fast and accurate responses, you can improve your own supplier performance score and obtain a competitive advantage over other suppliers.

 

In a review of recent history and new substance inclusion, Q Point notes that the process to include the 4 phthalates (the most recent change to RoHS) in Annex II began in 2012 and was not completed until June 2015, with an enforcement date of July 21, 2019. At this point, it is very likely that the Pack 15 substances are, at least, a couple of years away from enforcement. As new information is released, this blog will post relevant information and updates.

 

To learn more about solutions for material content restrictions, such as RoHS, please check out Green Data Exchange, GDX, at www.qpointtech.com

RoHS Exemption Renewals

Per the European Journal, published on May 18, several exemptions for the use of lead in electrical and electronic equipment have been renewed.

The renewals, made via Commission Delegated Directives (2018/736 and following), extend the exemptions as currently constituted until 2021 with delayed expiration for products under categories 8 & 9 (in vitro diagnostic devices & industrial monitoring and control instruments, respectively).

The exemptions now extended are:

6(a) Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight. Expires on: 21 July 2021 for categories 8 and 9; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

6(a)-I Lead as an alloying element in steel for machining purposes containing up to 0.35 % lead by weight and in batch hot dip galvanized steel components containing up to 0.2 % lead by weight. Expires on 21 July 2021 for categories 1-7 and 10.

6(b) Lead as an alloying element in aluminum containing up to 0.4 % lead by weight. Expires on: 21 July 2021 for categories 8 and 9; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

6(b)-I Lead as an alloying element in aluminum containing up to 0.4 % lead by weight, provided it stems from lead-bearing aluminum scrap recycling. Expires on 21 July 2021 for categories 1-7 and 10.

6(b)-II Lead as an alloying element in aluminum for machining purposes with a lead content up to 0.4 % by weight. Expires on 18 May 2021 for categories 1-7 and 10.

6(c) Copper alloy containing up to 4 % lead by weight. Expires on: 21 July 2021 for categories 1-10; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

7(a) Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead). Expires on: 21 July 2021 for categories 1-10; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

7(c)-I Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound. Expires on: 21 July 2021 for categories 1-10; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

24 Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors. Expires on: 21 July 2021 for categories 1-10; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

34 Lead in cermet-based trimmer potentiometer elements. Expires on: 21 July 2021 for categories 1-10; 21 July 2023 for category 8 in vitro diagnostic medical devices; 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.

As RoHS continues to update and evolve, it is important to determine compliance of an individual component in a real-time environment. With access to the latest compliance information from your suppliers, Green Data Exchange provides real-time compliance information. GDX users have the ability to streamline supplier management efforts, review material content and regulatory compliance across suppliers and products, and automatically generate reports. Learn more www.qpointtech.com

For continued updates on RoHS exemption renewals and revisions, please be sure to follow the Q Point Technology Blog.

Using GDX to Get Ahead of RoHS 2 + Phthalates

In June of 2015, four phthalates were added to Annex II of the RoHS Directive. The European Commission selected an enforcement date of July 22, 2019 (2021 for Categories 8 & 9). Electrical and electronic equipment containing the phthalates will not be placed on the market in EU after the enforcement date. For more details on the added substances and the enforcement dates see this link.

Because of the additional substances, it is important to update and gather new RoHS compliance documentation at the “RoHS 2 + phthalates” level in order to maintain compliance and access to the EU markets. Green Data Exchange (GDX) has informed suppliers and educated in-house compliance teams about the needed updates to the RoHS Directive. Many suppliers have already updated their RoHS declarations in GDX to account for phthalates and are adding more data daily. In using GDX, you are able to ensure your compliance to RoHS 2 + phthalates well ahead of the enforcement dates.

On the term “RoHS 2 + Phthalates”

Q Point has adopted the title of “RoHS 2 + phthalates” when referring to the RoHS (recast) Directive 2011/65/EU + Directive 2015/863 which amends Annex II to include the four phthalates.

Some organizations have referred to the amended version of RoHS containing phthalates as “RoHS 3.” We maintain this is a misnomer as the RoHS Directive coming into force in 2019 maintains 2011/65/EU. The only distinction is the amended Annex II of 2011/65/EU which was done by the passing of ED 2015/863.

If you have any questions on RoHS 2 + phthalates, would like to learn about GDX, or to request a demo, please visit our website or email us at gdx_support@qpointtech.com.

Using GDX to Address Expected Changes in REACH Declaration

A recent change to the REACH Directive states that “articles incorporated as a component of a complex product [are] covered by the relevant duties to notify and provide information.” This means that the REACH compliance of a finished good will be affected by the REACH compliance of individual components within the finished good. In a sense, all components with a specific form and function are now considered articles and are held to REACH compliance reporting requirements. Green Data Exchange is already able to support the expected changes to the REACH reporting requirements.

The GDX Product Compliance feature allows users to view a bill of materials (BOM) and instantly determine compliance. With GDX, you can view REACH Compliance at the individual component level as well as the BOM/product level.

Screen Shot 2015-10-21 at 12.27.27 PMShown is a sample of the Product Compliance view in GDX. Note that each article incorporated in the product is expressed with its own compliance. This roll-up allows for easy identification of overall product compliance as well as easy identification of parts with out-of-date compliance and even parts affected by non-compliance. The ability to “notify and provide information” on the REACH compliance of individual components, sub-assemblies, and finished goods is addressed in Product Compliance view, thus addressing the changes in the latest REACH interpretation.

From the Product Compliance view, you can determine the status of all sourced components in a single click and even request data from your supplier in that view.

Screen Shot 2015-10-21 at 1.21.55 PM

Review all sourced components used in an internal part number. This allows for the ability to determine the responsiveness and quality of data received from one supplier to the next for your part. This can be used to inform sourcing decisions and to identify specific parts for removal from sourcing.

Screen Shot 2015-10-21 at 1.22.28 PM

As REACH continues to update and evolve, it is very important to have the ability to determine individual component compliance in a real-time environment with access to the latest compliance information from your suppliers. Of similar importance is the ability to have a direct communication link to the contacts at your suppliers who author and provide the compliance data that you need. Green Data Exchange provides this today.