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EU – ECHA/Standards Meeting on SVHC in Articles Database

A special standards development meeting was hosted by IPC in Genoa, Italy on November 19, 2018 to discuss material declaration requirements relating to the ECHA SVHC in articles database that will be coming online in 2020. A representative from ECHA attended the meeting to discuss the information that ECHA currently foresees manufacturers will need to submit into the database.   Representatives from material declaration standards IPC-1754, IC-1752A and IEC 62474 attended the meeting.

Most of the meeting was spent with the ECHA representative describing their expectations on data requirements, answering questions, and standards developers discussing how current industry material declaration practices could support the database (and where there are significant gaps).

Background

The database is mandated by the revised Waste Framework Directive (WFD) published in June 2018.  Product manufacturers, importers, distributors, retailers and other actors manufacturing or selling products in the EU will be required to submit information about the SVHC content in their products into the central database starting in January 2021. A submission will only be required if the product contains an SVHC above the 0.1 mass percent of article threshold. However, many complex electronic products, subassemblies, and components contain one or more SVHC(s) and will need to be registered in the database.

Based on the proposed scenario document provided by ECHA in mid September, compiling the information will be a challenge for many companies and could potentially reveal confidential business information (CBI). Industry has been pushing back, suggesting that the proposed data submission requirements go beyond the requirements specified in REACH Article 33 and the WFD.

ECHA Presentation on Data Requirements

Most of the morning was spent with the ECHA representative presenting background information on the ECHA scenario and answering questions from participants.

The ECHA representative at the meeting presented an interesting argument trying to justify the information in the scenario document by taking words or phrases from the text of REACH Article 33 and describing the implications.  Such words/phrases included supplier of the article, substance,  concentration about 0.1%,recipient and sufficient information.

ECHA is recommending that an article-based approach is needed with a unique identifier and other information about the article with the SVHC information.  ECHA stated that:

“Aggregation of data can only be performed if the data is collected more detailed than the aggregation need”.

 

Moving Forward

ECD Compliance’s impression from the meeting is that ECHA is becoming aware of the challenges in compiling the proposed information given practical realities such as a global supply chain, multi-sourcing of parts, and confidential business information (CBI). As a result of the feedback and discussions that have taken place, ECHA is working on updating its scenario document. However, ECHA was also clear in stating that the mandate for the database is now cast in law and will move forward in a manner that meets the needs of consumers and recyclers. Given the short timeframe to develop the database, ECHA intends to repurpose an existing database, most likely the European Poison Centre database.

ECHA intends to specify its own format for submitting information into the database – despite several standards development groups promoting the use of an existing material declaration standard. ECHA will write a new module for their IUCLID chemical system to support the SVHC in articles submissions. Their intention is that the interface will allow automated (computer to computer) submissions into the database (this will be important given that current manual submissions into IUCLID can take a couple hours to complete).

Open Issues

The ECHA proposal that all database submissions must identify the article (first article) containing the SVHC and the concentration range is still an open issue.  Many REACH declarations and/or material declarations of supplier parts and subassemblies do not identify the exact location of the SVHC and only indicate that an SVHC is present. One suggestion raised during the meeting was an approach whereby SVHCs would be related to an assembly or functional unit of a product instead of the first article (this would be similar to the way that the China RoHS declaration works). However, there was no indication that this would be acceptable to ECHA.

Another issue is the unique identifier and how it is generated and used.

There was also good discussion on the reporting challenges posed by multi-sourced parts, whereby similar parts from different suppliers may have different SVHC constituents.  This creates a challenge for reporting – a manufacturer could declare a worst-case sum of all SVHCs across all parts, but this results in over reporting.

For safe use information, ECHA is thinking about creating a standard list of safe use phrases that could be used for submission into the database.

Impact on EEE Manufacturers

Given that many EEE products contain SVHCs, the EU SVHC in articles database will be a significant challenge and overhead for many EEE manufacturers.  Questions are still being raised as to whether the information in the database will have any practical usefulness to consumer and recyclers as mandated. However, it seems that one of the EU’s objectives in implementing the database is to prompt manufacturers to expedite removal of SVHCs from their products. With lead reportable as an SVHC in the database, we may see some product and component manufacturers try harder to eliminate the use of these exemptions.

For additional information on the upcoming requirements of the ECHA SVHC in articles database or how to collect the required information from suppliers, contact ECD Compliance.

Canada – Publishes Asbestos Restrictions

On October 18, 2018, Canada published the Prohibition of Asbestos and Products Containing Asbestos Regulations (SOR/2018-196). The tight restriction of asbestos use is not surprising, but the lack of a specific threshold for some aspects of the regulation is causing concern among some EEE manufacturers.

Paragraph 4 on import, sale or use and paragraph 5 on manufacture states that:

4 Subject to sections 7 to 21, a person must not import, sell or use

  • (a) processed asbestos fibres;
  • (b) a product containing processed asbestos fibres unless those fibres are the result of the degradation of asbestos integrated into a product, a structure or infrastructure; or
  • (c) a consumer product containing asbestos in greater than trace amounts.

5 A person must not manufacture

  • (a) subject to section 8, a product containing processed asbestos fibres unless those fibres are the result of the degradation of asbestos integrated into a product, a structure or infrastructure before the coming into force of these Regulations; or
  • (b) a consumer product containing asbestos in greater than trace amounts.

The complication is that bullet 4(b) suggests an absolute ban on processed asbestos fibres except due to degradation.  This creates a challenge with supplier declarations and in testing for compliance.

The restriction on consumer product specified in bullet 4(c) allows for trace amounts.  Environment Canada has published a separate guidance document[1] on the regulation to try to provide some clarification; however, the use of slightly different terminology in the guidance document versus the regulation creates some additional confusion.

The full text is available on the Justice Laws website[2]. The regulation comes into force on December 30, 2018.

Impact on EEE Manufacturer

Asbestos has been used in several EEE products that generate heat and it can occur in trace quantities in other products.  Given that the regulation doesn’t provide a precise threshold, some EEE manufacturers may decide to implement restrictions and supply chain requirements based on not “intentionally added”.

[1] Environment Canada Guidance on trace amounts of asbestos, https://www.canada.ca/en/environment-climate-change/services/management-toxic-substances/list-canadian-environmental-protection-act/asbestos/trace-asbestos-consumer-products-guidance.html#toc1

[2] Canada Asbestos regulation, https://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-196/FullText.html

UAE – Confirms that UAE RoHS Includes B2B Products

On November 15, 2018, the Emirates Authority For Standardization & Metrology issued an updated guidelines document confirming that the scope of UAE RoHS includes B2B (business to business) products. The guidance suggests that a simplified process for a certificate of conformity is being provided for B2B products; however, a very short interim period makes this process impractical except for products that were already lined up for certification through a Certification Body

Canada – Provides Chemicals Assessment Update to EEE Industry

During an annual joint Government/EEE Sector WG meeting held on Thursday, November 15, 2018, Environment and Climate Change Canada provided an update on chemical assessments and regulatory developments.  The update includes:

  • A general update on the Chemical Management Plan (CMP)
  • Chemicals Management Plan: post 2020
  • Update on Flame Retardants
  • Phthalates
  • Update on Mercury Regulations
  • Mercury Lamps: National Strategy
  • Basel Technical Guidelines for E-Waste
  • Zero Plastic Waste Strategy
  • Cyanides, and
  • Formaldehyde

Most of presentations were updates on the strategies and risk assessment activities currently underway.

In October, Environment Canada published a Notice of Intent (NOI) to amend The Prohibition of Certain Toxic Substances Regulations, 2012 (PCTSR) to further restrict five groups of substances: HBCD, PBDEs, PFOS, PFOA, LC-PFCA and to potentially prohibit DP and DBDPE (pending the outcome of a final screening assessment).

On the topic of phthalate substances, Environment Canada indicated that the risk assessment is expected in mid-2019 and they are not able to provide at this time any insight on whether restrictions might be implemented.

Environment Canada is implementing changes to the Mercury restrictions to align with the Minimata convention and restrictions in other jurisdictions. The consultation document on the changes was published last February. Environment Canada expects to publish the new regulation in 2020 with a 1-year delay in implementation.  They indicated that an exemption is planned for replacement parts.

EU – Power Supply Ecodesign Requirements

The European Commission is revising the ecodesign requirements for external power supplies, including broadening the scope to cover external power supplies that produce more than one output voltage. Once finalized, the regulation will replace the existing Commission Regulation (EC) No 278/2009 for ecodesign of external power supplies.  The current draft suggests a transition date for the new requirements starting April 1, 2020.

The proposed regulation specifies requirements for no-load power consumption, average active efficiency, and various information requirements. The energy efficiency requirements are segmented into the following four categories:

  • AC-AC external power supplies, except low voltage and multiple voltage output external power supplies
  • AC-DC external power supplies, except low voltage and multiple voltage output external power supplies
  • Low voltage external power supplies
  • Multiple voltage output external power supplies

The no-load power consumption requirements are summarized in Table 4 and the average active efficiency in Table 5 (unofficial). For official information, please see the draft regulation.

Table 4: no-load condition power consumption

 AC-AC external power supplies, except low voltage and multiple voltage output external power supplies AC-DC external power supplies, except low voltage and multiple voltage output external power supplies Low voltage external power supplies Multiple voltage output external power supplies
PO ≤ 49,0 W0,210 W0,100 W0,100 W0,300 W
PO > 49,0 W0,210 W0,210 W0,210 W0,300 W

Table 5: average active efficiency

 AC-AC external power supplies, except low voltage and multiple voltage output external power supplies AC-DC external power supplies, except low voltage and multiple voltage output external power supplies Low voltage external power supplies Multiple voltage output external power supplies
PO ≤ 1,0 W0,5 ∙ PO + 0,1600,5 ∙ PO + 0,1600,517 ∙ PO + 0,0870,497 ∙ PO + 0,067
1 W < PO ≤ 49,0 W0,071 ∙ ln(PO) – 0,0014 ∙ PO + 0,670,071 ∙ ln(PO) – 0,0014 ∙ PO + 0,670,0834 ∙ ln(PO) – 0,0014 ∙ Po + 0,6090,075 ∙ ln(PO) + 0,561
PO > 49,0 W0,8800,8800,8700,860

Information that needs to be included in the instruction manual and/or website includes:

  • Nameplate output power (W)
  • Root mean square (Rms) input voltage (V)
  • Input AC frequency
  • Rms output voltage (V)
  • Rms output current (mA)
  • Average active efficiency
  • Efficiency at low load (10%)
  • No-load power consumption (W)

 

EU – ECHA Workshop on SVHC in Articles Database

On October 22-23, 2018, the European Chemical Agency (ECHA) hosted a workshop in Helsinki to discuss next steps towards developing a database for declaring information on SVHCs in articles. ECHA has just over a year left to develop the database. Manufacturers, importers, distributors, and retailers selling products in the EU may start submitting information on SVHCs in their products starting January 2020.  The submission of SVHC in articles information becomes mandatory starting in January 2021.

The workshop was targeted for discussions with member state authorities and other stakeholders, including industry. The workshop agenda included:

  • Presentation of draft scenario and outcome of call for input
  • Break-out discussions on workability, assumptions and main open questions,
    • How to ensure the information flows:
      • How to ensure that each duty holder has the information they need?
      • How to get such information to the authorities?
      • How to avoid overlaps in the notifications?
    • Dissemination: how to make the database useful for consumers and waste operators:
      • What information is needed?
      • How to display the data?
    • How could the data be submitted:
      • Technical solutions
      • Protection of confidential business information
      • Which learnings from existing supply chains (tools)?
    • Next steps and invitation to join technical focus group(s)
      • (e.g. article identification and categorisation and/or an IT user group)
    • Implementation and workability
    • Harmonised transposition
    • Conclusions and next steps

During their opening presentation, ECHA introduced their vision for the database and provided a summary of the feedback that they received to their request for input.  Figure 1 illustrates ECHA’s thinking that suppliers throughout the supply chain will declare parts that contain SVHCs. These supplier declarations will then be used by downstream manufacturers to create their declarations. Industry has been trying to argue that this approach ignores several practical issues such as a global supplier chain, multi-vendor sourcing and confidentiality of suppliers.

In response to the call for input, ECHA received a total of 116 submissions from industry (associations and individual companies), waste operators, NGOs, academia, IT tool providers, and public authorities covering 12 EU countries, Norway, US, Canada, Mexico and Japan. ECHA provided a very high-level summary of information that was submitted and avoided many of the critical comments that were made. The full ECHA presentation is available from the workshop website[1].

A follow-up meeting to discuss the information to be submitted and the data format will be held during a material declaration standardization meeting in Genoa, Italy on November 19th.

EU – EU RoHS Methodology Identifying and Selecting Substances

A stakeholder consultation was launched on October 26, 2018 for RoHS project (Pack 15). This project includes the review and update of the RoHS substance selection methodology and the substance inventory.  It also includes the review of one new exemption request. For this stakeholder consultation, the consultant is requesting feedback on a draft substance selection methodology and substance usage data to compile a substance inventory.

A “Manual (draft) methodology to identify and assess substances for possible restriction under the RoHS Directive” has been posted for feedback. The core content of the methodology includes three parts:

  • Part I) IDENTIFICATION OF SUBSTANCES
  • Part II) PRE-ASSESSMENT OF SUBSTANCES, and
  • Part III) DETAILED ASSESSMENT OF SUBSTANCES

The substance inventory part of the consultation is asking stakeholders to provide information on EEE applications and quality used of specific substances that the consultants have specified. A spreadsheet listing the substances of interest and instructions on submitting usage information is provided on the project website.

EU –Revised Server Ecodesign Requirement

The EU Member States have approved a revised set of ecodesign requirements for computer servers and data storage products. The European Commission’s draft requirements circulated in the Spring 2018 had a strong negative reaction from industry due to the emphasis on low idle power requirements when the server is operating at a low utilization level.  Industry raised concerns about the proposal indicating that the low idle focus would prevent some servers that have high energy efficiency at high utilization levels from being sold in Europe.  Although data center statistics have shown that many servers operate at very utilization, the trend is to virtualize applications onto a hosting server that runs multiple applications and is optimized to operate at a higher CPU utilization (typically 65-90%). The revised draft regulation is available on the Europa website[1].

Indications were that the Commission had compromised of a blended requirement that is based on a combination of idle power and active power efficiency; however, the efficiency requirement in the updated draft regulation appears to be the same as the earlier WTO TBT notification. ECD Compliance is investigating to get additional information.

Scope

The scope of the implementing measure hasn’t changed from the earlier proposal.

  1. This Regulation establishes ecodesign requirements for placing on the market and putting into service of servers and online data storage products.
  2. This Regulation shall not apply to the following products:
    1. servers intended for embedded applications;
    2. servers classified as small scale servers in terms of Regulation (EU) No 617/2013;
    3. servers with more than four processor sockets;
    4. server appliances;
    5. large servers;
    6. fully fault tolerant servers;
    7. network servers;
    8. small data storage products;
    9. large data storage products.

Ecodesign requirements and timetable

Article 3 of the regulation specifies when specific technical requirements (in the Annex) come into effect.

  1. The ecodesign requirements for servers and online data storage products are set out in Annex II.
  2. From 1 March 2020 servers shall comply with the ecodesign requirements set out in Annex II points 1.1.1, 1.2.1, 1.2.2, 2.1, 2.2, 3.1, 3.3 and 3.4.
  3. From 1 March 2020 online data storage products shall comply with the ecodesign requirements set out in Annex II points 1.1.1, 1.2.1, 1.2.2, 3.2, 3.3 and 3.4.
    1. From 1 March 2021 servers and online data storage products shall comply with the ecodesign requirement set out in Annex II point 1.2.3.
    2. From 1 January 2023 servers and online data storage products shall comply with the ecodesign requirements set out in Annex II point 1.1.2.
    3. Compliance with ecodesign requirements shall be measured and calculated in accordance with the methods set out in Annex III.

Power Supply Efficiency

Annex II section 1.1 specifies requirements for Power supply (PSU) efficiency and minimum power factor requirements. Initial requirements come into effect in 2020 and stricter requirements come into effect in 2023 (Note: the requirements starting in 2026 have been removed from the regulation).

Material efficiency requirements

Annex II subsection 1.2 specifies material efficiency requirements addressing disassembly, secure data deletion and firmware upgrades (for a minimum of 8 years).  In particular, the major components of the server or storage product need to be easily removable for reuse and/or recycling. The initial proposal has been expanded to include (g) and (h): (a) data storage devices; (b) memory; (c) processor (CPU); (d) motherboard; (e) expansion card/graphic card; (f) power supply, (g) chassis, and (h) batteries.

Information to be provided by manufacturers

The information requirements are essentially the same as the July draft regulation.

[1] Revised server ecodesign regulation, http://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.documentdetail&Dos_ID=16742&ds_id=58881&version=2&page=1&AttLang=en

RoHS – International RoHS Standardization Forum

The International RoHS Standardization Forum took place on October 26, 2018 in Busan, Korea.  The topics presented at the forum were split between substance regulations and International Standards that support compliance to substance regulations. We provide a brief summary of the presentations.  For copies of the presentations, please contact your ECD Compliance prime.

IEC TC111 WG3 Past, Present and Future

This presentation focused on the analytical test methods that are available or under development for RoHS and REACH substance testing. The test methods are included in the IEC 62321-X series of test methods.  Some of the test methods are screening methods that are intended to be quick and inexpensive, usually covering several elements or substances with one test and often without damaging the product. Other methods utilize analytical chemistry whereby the sample is digested into a solution and then analyzed using methods such as gas chromatography (GC), mass spectrometry (MS), combustion-ion chromatography, inductively coupled plasma (ICP), colorimetric method, atomic absorption spectroscopy (AAS), etc. A list of current and under development test methods are provide in Table 6.

Table 6: IEC 62321-X Standards

PartIEC 62321 Determination of certain substances in electrotechnical products –Edition 1.0Status
1Part 1: Introduction and overview (2013-05-17)Published
2Part 2: Disassembly, disjunction and mechanical sample preparation (2013-06-25)Published
3-1
Part 3-1: Screening -Lead, mercury, cadmium, total chromium and total bromine using X-ray fluorescence spectrometry (2013-06-19)Published
3-2
Part 3-2: Screening -Total bromine in polymers and electronics by Combustion -Ion Chromatography (2013-06-19)Published
3-2
Part 3-2 Screening of fluorine, bromine, chlorine and iodine in polymer and electronics by Combustion -Ion Chromatography (C-IC).Revision under Development
3-3
Part 3-3 Screening of polybrominatedbiphenyls, polybrominateddiphenylethers and phthalates in polymers by pyrolysis (Py-GC-MS) or thermal desorption (TD-GC-MS) gas chromatography-mass spectrometry.Under Development
4Part 4: Mercury in polymers, metals and electronics by CV-AAS, CV-AFS, ICP-OES and ICP-MS (2013-06-19)Published
5Part 5: Cadmium, lead and chromium in polymers and electronics and cadmium and lead in metals by AAS, AFS, ICP-OES and ICP-MS (2013-06-25Published
6Part 6: Polybrominatedbiphenyls and polybrominateddiphenylethers in polymers by gas chromatography–mass spectrometry (GC-MS) (2015-06)Published
7-1Part 7-1: Presence of hexavalent chromium (Cr(VI)) in colourlessand colouredcorrosion-protected coatings on metals by the colorimetric method” (2015-09)Published
7-2
Part 7-2: Determination of hexavalent chromium (Cr(VI)) in polymers and electronics by the colorimetric method (2017-03)Published
8Part 8: Phthalates in polymers by gas chromatography-mass spectrometry (GC-MS), gas chromatography-mass spectrometry using a pyrolyzer/thermal desorption accessory (Py-TD-GC-MS)Published
9Hexabromocyclododecanein polymers by high pressure liquid chromatography-mass spectrometry (LC-MS)Under Development
10Polycyclic aromatic hydrocarbons (PAHs) in polymers and electronics by gas chromatography-mass spectrometry (GC-MS)Under Development
11Tris(2-chloroethyl) phosphate (TCEP) in polymers and electronics by gas chromatography-mass spectrometry (GC-MS) and liquid chromatography-mass spectrometry (LC-MS)Under Development

Each new test method goes through an International Intra-laboratory study to assess the reliability and repeatability of the test method.  Each of several labs from around the world are given samples to test according to the draft test method without knowing the content of the samples.  The results are compiled, and the accuracy and the reliability of the test method is assessed.  If the results are not sufficiently accurate and consistent, the test method goes back to the drawing board.

US CPSC Organo-Halogen FR Guidance Regarding Petition 2015 HP 15-1

An overview was provided of US Consumer Product Safety Commission (CPSC) ruling to ban Organo-Halogen flame retardants and the subsequent guidance to manufacturers, importers, distributors, retailers, and consumers.  The ban is intended to address exposure from additive, non-polymeric organohalogen FRs (OFRs) found in several products, including plastic casings surrounding electronics.

The rulemaking for the ban is currently under development (although unlikely to be enacted by the current US administration) and, in the interim, a guidance document was published in the US federal register Vol. 82 / No. 187 on Thursday September 28, 2017. The US National Academy of Sciences is currently investigating the feasibility of a ban and is expected to deliver their finding in Spring 2019.

The presentation also discusses four subnational regulations banning halogenated flame retardants in San Francisco, Maine, and Rhode Island, and Massachusetts, although none of those directly target electronics products.

Regulatory and standardization update on chemical substances in Europe

This presentation covered emerging changes to EU RoHS, challenges in REACH compliance, substance regulations and the circular economy, and critical raw materials (CRM) in the EU.

Topics for EU RoHS were the upcoming phthalate restrictions, exemption renewals, and seven additional substances under assessment – all of which have been previously covered in the ECD monthly reports. A brief summary of the European Commission’s recently launched roadmap for the RoHS Directive (RoHS 3).  A review of the Directive and a proposal for a recast (if appropriate) must be completed by July 2021.  The review includes: scope of the Directive, interface with other chemical, product and waste legislation, and is intended to consider effectiveness, efficiency, relevance, coherence with other legislation, and EU added value.

During the update on the EU REACH regulation, the hot topics included the “once an article, always an article” SVHC reporting requirements and the upcoming ECHA database on SVHCs in articles. There are still many aspects of SVHCs in the first article that are not practical to implement; the Commission and member states have acknowledged that “some level of aggregation needed, for practical reason”, but so far there has been no interest from member states to establish an expert group to deal with this issue.  The presentation indicated that several industry associations have developed detailed sectoral guidelines (ACEA, COCIR, ASD), but ECHA has made it clear that they will not endorse sectoral guidance.  The issue remains unresolved. An enforcement project b2b SVHC communication is currently wrapping up with a report expected by mid-2019.

An upcoming EU standard on declaration of critical raw materials is expected to be published in March 2019.

Recent Japanese Activity regarding Chemicals in Products & Phthalate analysis

This presentation provided an overview of the Japanese government sponsored chemSHERPA material declaration system. chemSHERPA supports two information formats; one for article information (AI) and one for chemical information (CI) for raw chemicals and mixtures.  chemSHERPA is based on the IEC 62474 material declaration format.

Other topics included screening and testing methods for phthalates, especially the necessity for fast and inexpensive screening methods given the high occurrence of phthalates use in the supply chain. An International Interlaboratory study on phthalates was conducted in 2018 with some optimistic results: FT-IR was only effective for high concentration levels (above 5%).  HPLC/UV screening successfully separated seven different phthalates, but screening time took up to 20 minutes. As a result of the business need for phthalate screening and the results of the IIS, a new work item proposal is planned for an IEC 62321-X standard for phthalate screening.

The updated development of China RoHS and its standardization

Director of the China Electronics Standardization Institute (CESI) presented an overview and update on the China RoHS 2.0 regulation.  The first batch of products included in the RoHS product catalogue, the restricted substances and the list of exemptions were published earlier in 2018; however, the exact requirements for demonstrating conformity assessment have been an unnerving, open question for manufacturers.

The presentation suggested that two ways to demonstrate conformity will be provided: (1) self declaration, or (2) voluntary certification for China RoHS or State Green product certification. The self declaration approach is welcome news for manufacturers, but there are still a few details unanswered.  For example, the current expectation is that manufacturers (or importers) will need to upload their declarations into a central repository – however, the details, including any supporting information that needs to be provided has not been specified.

IEC – Study recommends International Standard with Harmonized Ecolabel Criteria

An IEC/TC111 study recommends developing an IEC International Standard with harmonized ecolabel criteria (requirements for environmental assessment of EEE products). Ecolabels are commonly used by purchasers to specify environmental performance expectations in procurement contracts for certain types of EEE equipment, especially IT equipment.
Market demand for a simple mechanism to assess the environmental performance of electronic products during procurement has led to global proliferation of ecolabels and their corresponding environmental assessment standards. These ecolabel programs are often driven by governments, product purchasers (including government purchasing), retailers, consumer groups, NGOs and the manufacturers themselves.

Standards consisting of environmental assessment criteria are used by ecolabel programs to set the requirements that must be met to earn manufacturers the right to claim and display the ecolabel. Ecolabel standards typically address environmental aspects and/or impacts that cover the full range of life cycle stages, including product design, manufacturing, transportation, use phase and end of life.

Criteria may include product requirements for reduction of hazardous substances, alternative substances assessment, materials selection, design for end of life, product longevity and life-cycle extension, energy conservation during the use phase of the product, reduction of emissions, end-of-life management, product packaging, life cycle assessment, and product carbon footprint. The criteria may also address various corporate environmental performance measures such as implementation of an environmental management system (EMS), emissions during manufacturing and transportation, sustainability reporting, organizational carbon footprint, energy management and use of renewable energy, etc.

Conflicting Requirements

The study considered environmental assessment standards that were in use in USA, Canada, EU, China, Japan, and Korea. Standards that were assessed included IEEE 1680.x (EPEAT ecolabel), Blue Angel, EU flower, TCO, Nordic Swan, several Chinese ecolabel standards, and Japan Ecomark. The group found that the environmental improvement objectives were often similar, but detailed requirements were sometimes sufficiently different that they caused conflicts in the design requirements.