In a previous post, we discussed the United Arab Emirates (UAE) proposed RoHS regulation that they had notified to the WTO. The UAE RoHS proposal restricts the same 10 substance groups and at the same threshold level that are currently restricted in EU RoHS Directive. However, a transition period for the 4 phthalate substances is not provided for most EEE product categories, with the exception of medical devices and monitoring and control instruments which have until July 22, 2021 (same date as in the EU RoHS Directive).

The EU has submitted a response to the UAE WTO notification requesting clarification on this lack of a transition period for the phthalate substances in most product categories. The EU response also highlighted that the Annex III and Annex IV list of exemptions are not perfectly up to date with the EU RoHS Directive exemptions and raised some of the conformity assessment anomalies that we discussed in our September article.

Contact ECD Compliance, for services to assess your environmental product compliance requirements, keep you up to date on the impact to your products and markets and to implement compliance procedures.

The IEC has started developing an International Standard on RoHS technical documentation. This will be an international version of the European standard, EN 50581:2012 “Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances” which was developed by the European CENELEC standards organization under mandate from the European Commission.

Technical documentation is one of the mandatory requirements imposed on manufacturers for compliance to the EU RoHS Directive and must be in place before an EEE product may be placed on the EU market (for foreign manufactured products, placing on the market usually occurs at the time of import). This EN 50581 standard is already in place for the EU RoHS Directive, but there is a strong desire to leverage this standard for use in other worldwide RoHS regulations. A new work item proposal to develop such a standard within the IEC was distributed earlier this year. The work item was broadly approved, including USA, Canada, China, Japan, Korea, and most EU countries.

The standard will be known as IEC 63000 and is being developed under IEC/TC111 (Environmental standardization for electrical and electronic products and systems). EN 50581 is expected to be leveraged heavily in the development of the International standard. The project team held its first meeting in Brussels on October 21-22, 2015 and will establish its first committee draft (CD) of the standard at an upcoming meeting on November 18, 2015.

Contact ECD Compliance, for additional information and services to develop or assess RoHS Technical Documentation or to stay up to date on International Environmental Standards.

On November 9, 2015, the US Court of Appeals refused the Securities and Exchange Commission (SEC) and Amnesty International requests for rehearing en banc of the court’s Aug. 18, 2015 decision in the Conflict Minerals Rule litigation. The request for rehearing is with regard to whether compelling companies to describe products as having “not been found to be DRC conflict free” violates the First Amendment.

However, the refusal by the Court doesn’t settle the issue and the saga continues. There are still several options available to the SEC and there is a lot of speculation underway as to what happens next. For example, the SEC could file an appeal with the U.S. Supreme Court. We’ll need to let the dust settle and look to see what the SEC does next.

The ruling itself is very briefly, only really saying “the petitions be denied”.

Contact ECD Compliance, for additional information and services to assess your environmental product compliance requirements, keep you up to date on the impact to your products and markets and to implement compliance procedures.

The European Chemicals Agency (ECHA) published an article announcing that new data has become available from the OECD on nanomaterials. The data covers 11 commercially viable nanomaterials.

New data on 11 commercially viable nanomaterials was made available in June as part of a seven-year testing programme by the Organisation for Economic Cooperation and Development (OECD). The information gives those companies who have registered or will register these nanomaterials in the EU, an opportunity to consider the data in their registration dossiers.

“If the information is relevant for the assessment of safe use of your substance, we encourage you to update your registration dossier to make sure the substances are used safely,” says Jenny Holmqvist, coordinator of nano activities in ECHA and Chair of the OECD steering group on the Testing and Assessment of Manufactured Nanomaterials.

“The OECD testing programme has made it possible to release an unprecedented volume of nano-specific data to the public,” says Jenny Holmqvist. The aim of the programme was firstly, to assess whether the existing test guidelines for substances need to be adapted to consider nano-specific issues, and secondly, to respond to the growing need for nano-specific data.

The 11 nanomaterials include:

• fullerenes
• single-walled carbon nanotubes
• multi-walled carbon nanotubes
• silver
• gold
• dendrimers
• silicon dioxide
• nanoclays
• titanium dioxide
• cerium dioxide
• zinc oxide

Contact ECD Compliance, for additional information and services to assess your environmental product compliance requirements, keep you up to date on the impact to your products and markets and to implement compliance procedures.

The standardized test method for determining if hexavalent chromium is present on metal coatings was revised and published on September 16, 2015. The boiling water extraction test has been revised and the spot test which was provided in the original IEC 62321:2008 standard has been removed because of its unreliability. IEC provides the following abstract of the standard:

IEC 62321-7-1:2015 describes a boiling water extraction procedure intended to provide a qualitative determination of the presence of hexavalent chromium (Cr(VI)) in colourless and coloured corrosion-protection coatings on metallic samples. In this procedure, when Cr(VI) in a sample is detected below the 0,10 g/cm2 LOQ (limit of quantification), the sample is considered to be negative for Cr(VI). Since Cr(VI) may not be uniformly distributed in the coating even within the same sample batch, a “grey zone” between 0,10 g/cm2 and 0,13 g/cm2 has been established as “inconclusive” to reduce inconsistent results due to unavoidable coating variations. In this case, additional testing may be necessary to confirm the presence of Cr(VI). When Cr(VI) is detected above 0,13 g/cm2, the sample is considered to be positive for the presence of Cr(VI) in the coating layer.

Contact ECD Compliance, for additional information and services to assess your environmental product compliance requirements, keep you up to date on the impact to your products and markets and to implement compliance procedures.

A European Technical Assistance Study for Enterprise Servers and Data Storage has started. The study, which is a follow-up to the Lot 9 preparatory study conducted over the past couple years, will include two stakeholder meetings, the first of which is scheduled for 13th November in Brussels. The Study focuses on existing standards and standards in development that could be leveraged for a regulation in this area:

This study provides the European Commission with technical assistance specifically for enterprise servers and data storage (DG Entr Lot 9). It aims to support tasks stemming from the regulatory process related to the EU Ecodesign Directive and Energy Labelling Directive and their implementing measures, and builds on the findings of the DG Entr Lot 9 Preparatory Study.

The goal is to prepare technical documents related to standardised measurement methods and to harmonised standards.

Contact ECD Compliance, for additional information on the study and how we can keep your organization aware of the latest developments that could impact to your products and markets.

Taiwan has issued a WTO TBT (Technical Barriers to Trade) notice that they are extending their proposed RoHS marking regulation to cover two additional products: network media players and projects. The proposed Taiwan RoHS regulation includes Taiwan specific marking and certification requirements.

Contact ECD Compliance, for additional information on the proposed regulation and for services to assess your environmental product compliance requirements, keep you up to date on the impact to your products and markets and to implement compliance procedures.