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.

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RMI Publishes CMRT Version 5.11

On April 27, the Responsible Minerals Initiative, RMI, released the newest version (v. 5.11) of the Conflict Minerals Reporting Template, CMRT. This is the 19th version, the fourth release at version 5, and the first update since CMRT v. 5.10, released on December 1, 2017.

The major updates to this version of the CMRT are the correction of bugs and errors, enhancements that do not conflict with IPC 1755, updates to the ISO short names for countries, states, and provinces, and regular maintenance updates to the smelter lists.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.responsiblemineralsinitiative.org. The next update to the CMRT is anticipated for November 2018.

The new CMRT provides an opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 5.01 contains potentially out-of-date information when compared to a current CMRT (v. 5.11).

Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after April 27, 2018. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.

The RMI has also released a pilot program for the collection of data pertaining to Cobalt. A follow-up article will focus specifically on this new effort and its implications.

REACH SVHC UPDATE – REACH 181

On January 15, 2018, ECHA added seven new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 181 substances. The new SVHC and common usage is found in the table below.

Screen Shot 2018-01-17 at 5.16.31 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.

Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including REACH updates.

United Arab Emirates RoHS

On April 28. 2017, the United Arab Emirates (UAE) version of RoHS took effect. The UAE version of RoHS is based upon EU RoHS and also adopts a very rigorous timeline with data submissions due to Emirates Authority for Standardisation and Metrology (ESMA) as early as January 1, 2018, depending on product category.

To declare under the UAE Directive, “Form A” is stipulated as the template for the UAE RoHS COC. “Form A” does not exist under UAE RoHS, but rather is an indication of “Module A” from 768/2008/EC, a product marketing decision by the European Commission. A description of “Module A” may be found here, beginning on page 17:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:218:0082:0128:en:PDF

ESMA, the agency tasked with collection and enforcement of UAE RoHS, is using a certification system (ECAS) by which companies would register products and issue a declaration of conformity. In return, any company (or its authorized representative) making a declaration would receive a “conformity acknowledgement” to retain for 10 years. To use ECAS, a company would register and then issue the declarations via the system. However, at the time of this article, there is no current way to use the system to declare UAE RoHS. There are fees associated with ESMA registration and product/DOC evaluation. Please see the ESMA site here: http://www.esma.gov.ae/en-us/Services/Pages/ECAS.aspx

Additionally, the UAE’s version of the RoHS directive calls for annual renewal of the DOC.

The current consensus is that any existing (acceptable) EU RoHS DOC is going to be acceptable for UAE RoHS. This is due to the harmonization between UAE and EU RoHS. However, this harmonization has its own issues as UAE is not a member state of the EU, likely would never be a member state of the EU, and is relying upon a foreign directive that has grown and changed in scope, exemptions, details, and substances. Hence, there may be issues that confront UAE RoHS in the future.

Finally, any additional questions regarding ECAS registration, product declaration, and UAE RoHS may be directed to customercare@esma.gov.ae, the contact for ESMA.

RMI (Formerly CFSI) Publishes CMRT Version 5.10

On December 1, the Responsible Minerals Initiative (RMI), formerly the Conflict Free Sourcing Initiative (CFSI), released the newest version (v. 5.10) of the Conflict Minerals Reporting Template, CMRT. This is the 18th new release, the third release at version 5, and the most recent update since CMRT v.5.01, released on June 21, 2017.
The major updates to the CMRT include corrections to all bugs and errors, enhancements in accordance with IPC-1755, updated ISO short names for countries, states, and provinces, updates to the “Smelter Reference List” and “Standard Smelter List,” and a change to .xlsx format.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for May 2018.
The new CMRT provides an opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 5.10).
Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after December 1, 2017. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.

Ukraine’s Version of RoHS Now in Force

On September 22, 2017, Ukraine’s version of RoHS entered into force as the Ukrainian Technical Regulation on the restriction of hazardous substances in electrical and electronic equipment.

Adopted to align with the existing EU RoHS, manufacturers importing electrical and electronic equipment (EEE) to Ukraine are compelled to certify compliance with Ukraine’s RoHS Technical Regulation. There is a grace period for medical devices and controlling & monitoring instruments which will be held to the regulation as of January 1, 2018.

Manufacturers must also retain records of non-compliant EEE, and product recall details. EEE must now be properly marked, and are required to alert Ukrainian governmental agencies if any EEE placed on the market does not meet the RoHS requirements. This notification may result in further actions to remedy the non-compliant items on the market.

From the perspective of impact, manufacturers may expect to see requests from customers and importers selling products on the Ukraine market. These requests will encompass a declaration of conformity (DOC) in the format indicated by Annex V of the regulation.

As with EU RoHS, the substances are the same (Lead, Cadmium, Mercury, Hexavalent Chromium, PBB, and PBDE). There is also a planned ‘phase-in’ for the restriction of phthalates. DEHP and BBP are restricted in certain applications, such as in toys, by January 1, 2018. DEHP, BBP, DBP, and DIBP are restricted excepting categories 8 & 9 by July 22, 2019, and are restricted in all EEE by July 22, 2021.
As new material content directives emerge and evolve, it is very important to have the ability to determine product compliance in a real-time environment. With access to the latest compliance information from your suppliers, a direct communication link to your suppliers, and real-time reporting tools Green Data Exchange can provide the solutions you need to maintain compliance and report to your customers, auditors, and regulatory agents.
Please continue to check the Q Point Technology Blog for recent news on material compliance regulations and other important news on compliance.

REACH SVHC UPDATE – REACH 174

On July 7, 2017, ECHA added one new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 174 substances. The new SVHC and common usage is found in the table below.

 

SVHC

CAS No.

Reason for Inclusion

Where Used

Perfluorohexane-1-sulphonic acid and its salts   355-46-4 (for the acid)

 

No specific CAS for the salts of the acid

 

vPvB (very persistent and very bioaccumulative) ·      Formerly used in firefighting foam and carpet treatment

·      Stain and water repellent

·      Some R&D applications as a process chemical

·      Paper and packaging

·      Non-stick cookware

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.

Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including REACH updates.