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 email@example.com.
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.
Shown 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.
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.
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.