IEC 62321-6/Ed.1:2015 revising analytical test methods for presence of Polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDEs) in plastic parts was published by the IEC in June 2015. IEC 62321-6 replaces the previous informative test method specified in annex A of IEC 62321:2008. This test method is applicable to all EEE products and suppliers.

The standard, titled “DETERMINATION OF CERTAIN SUBSTANCES IN ELECTROTECHNICAL PRODUCTS – Part 6: Polybrominated biphenyls and polybrominated diphenyl ethers in polymers by gas chromatography-mass spectrometry (GC-MS)” specifies 3 test method; one is normative and the other two are informative.

The test methods are:

• The gas chromatography-mass spectrometry (GC-MS) (Normative);
• The ion attachment mass spectrometry (IAMS) technique (Informative) and
• The high-pressure liquid chromatography technique (Informative).

The informative test methods (IAMS and HPLC-UV) did not have sufficient accuracy and repeatability during Intra-laboratory testing trials and therefore could not be included as normative tests but they may still be useful to users and test laboratories. However, if a dispute arises over PBB/PBDE concentration, only the GC-MS method is considered a reliable test method for purposes of regulatory enforcement. Work is expected to continue in improving the accuracy of the informative test methods.

The test method standard is available from the IEC webstore and resellers.

The use of harmonized test methods has proven to be extremely important in ensuring that manufacturers, suppliers, and enforcement bodies are getting consistent results from analytical testing when performing regulatory assessments.

IEC 62321 is referenced by the European harmonized standard for RoHS technical documentation (EN 50581) as the test method that should be used for any test reports that are included in the technical documentation.

EEE Manufacturers that request test reports from suppliers should request and ensure that the revised test methods are being used (IEC 62321-1 through IEC 62321-6) instead of the original IEC 62321:2008.

The draft report on policy scenarios (task 7) for the EcoDesign (ErP) Directive lot 9 review on enterprise servers and data equipment was published in June 2015. The report emphasizes the same challenges that have been discussed throughout the lot 9 review – the difficulty in characterizing and specifying environment performance requirements of computer servers given the large variation in configuration, applications, and operating conditions.

Scope
The draft report included enterprise servers and enterprise storage within its scope, but excludes networking equipment because of the large variation in equipment. The report recommends that a future preparatory study should investigate networking equipment.

For the scope of enterprise servers, the report indicated that it is not excluding specific types of enterprise servers, such as server appliances, but does provide a caution to the European Commission… “However, it is strongly recommended to check the technical, economical and operational feasibility of particular eco-design measures for these products due to the fact that they could be custom made and utilized for high available or mission critical computing processes.”

Policy Recommendations
Five general policy measures and several sub measures were identified; however, there were few detailed technical recommendations other than the usual power supply efficiency which is also specified by U.S. Energy Star. The general policy measures and sub measures presented for further analysis and consideration by the European Commission are:

1.5.1. Product information before and during the operation

1.5.1.1. Active State Information Criteria
1.5.1.2. Idle State Information Criteria
1.5.1.3. Energy proportional design / Dynamic Range

1.5.2. Product hardware components and configuration

1.5.2.1. Power Supply Efficiency
1.5.2.2. Reduction of Idle Power

1.5.3. Energy requirement on the overall energy performance
1.5.4. Product software components and configuration
1.5.5. Product operating conditions and energy management

1.5.6. Resource efficiency requirements

1.5.6.1. Requirements on dismantling, re-use and recycling
1.5.6.1. Requirements for technical documentation
1.5.6.1. Critical raw material (CRM) voluntary declaration
1.5.6.1. Energy consumption of servers and storage with reused components

1.5.7. Energy labelling

Minimizing idle state power has been a common requirement in many other Eco-design implementing measures (regulations). However, for enterprise servers the report recognizes that optimizing idle power could result in an overall negative environment impact.

Low idle power is easier to meet in low performance servers than in high performance servers that are optimized for performance per Watt at high usage levels. Enterprise servers (if configured efficiently using virtualization, etc.) tend to have high usage levels and are not often in an idle state. Therefore, mandating low idle power could result in purchasing of more low performance servers versus fewer high performance servers.

The current challenge in specifying practical requirements for Enterprise servers is epitomized by the statement in subsection 1.5.3. (Energy requirement on the overall energy performance) that reads

“The Lot 9 study recommends that in case reliable measurement methods will permit to provide a quantitative ranking between products in the future, specific requirements on the overall energy performance could be envisaged.”

The Energy Star program has published the second draft of the Large Network Equipment (LNE) Specification Version 1.0 and the final draft of the LNE test method. The U.S. EPA is requesting stakeholder comments on these documents until July 24, 2015.

The specification focuses on reporting energy consumption data, power supply efficiency and energy efficiency features. The EPA is expecting that testing and reporting of energy consumption data will help towards developing additional energy efficiency requirements for version 2.0 of the specification. The changes in the specification from the first draft to the second draft are listed in a cover letter from the EPA:

• EPA proposed several significant changes to key definitions including LNE, modular and fixed, a new definition for module, and an expanded definition of product family for modular products. Physical Network Ports now also include fiber-optic ports.
• EPA proposes inclusion of fiber-optic ports within the scope of this specification up to 40Gb/s or greater link rate capability.
• EPA has clarified that power factor requirements only apply to ac input power supplies.
• EPA has clarified that active state efficiency requirements will not be included in Version 1.0 of this specification, rather certified products will be required to generate and report data that will support setting active levels in Version 2.0. The other pass/fail requirements such as power supply efficiency and energy efficiency features will ensure Version 1.0 delivers savings.
• EPA has proposed a family structure for modular products and stated the Agency’s interest in and considerations for a family structure for fixed products, though a fixed product family structure is not proposed in this draft.
• EPA has added standard language on the definition of a representative model(s) in a product family.

Additionally, the following are some key elements of the proposed changes in LNE Final Draft Test Method:

• DOE has added test procedures for High Port Count products, as well as configuration requirements pertaining to High Port Count testing.
• DOE has increased the center-point and widened the range of the allowable ambient temperature required during testing.
• DOE has changed the requirements for how to measure the power of products that have multiple PSUs.

The current draft Specification excludes the following products from the scope of LNE Energy Star certification:

• Small Network Equipment;
• Computer Servers, including blade switches sold within a Blade Server configuration;
• Storage Products, including Blade Storage;
• Storage Networking Products;
• Security Appliances;
• Access Point Controllers;
• DSLAM/CMTS equipment;
• Network Caching Devices; and
• Load Balancing Devices.

The Members of the European Parliament, on May 20 2015, vetoed a RoHS exemption for cadmium in illumination and display lighting applications, claiming that the exemption was no longer necessary.   Although the exemption is only used in very specific applications and will not affect most EEE manufacturers, it sets a disconcerting precedent that the parliament will no longer automatically approve all new exemptions and renewals that are approved by the Commission and the RoHS technical adaption committee (TAC).

RoHS Annex III exemption 39 “Cadmium in colour converting II-VI LEDs (less than 10 microgram Cd per mm2 of light-emitting area) for use in solid state illumination or display systems” was set to expire on 1 July 2014. A manufacturer (QD-Vision) submitted in December 2012 a renewal request to extend the exemption to 2019. After the public consultation and consultant’s assessment, the Commission and the TAC agreed to reword and extend the exemption as shown below:

In Annex III to Directive 2011/65/EU, point 39 is replaced by the following:

The current exemption (39) remains in effect while the three arms of the EU government reconcile the status of the exemption.

The European Parliament voted down the exemption by a strong majority (618 votes to 33 and 28 abstentions) arguing that alternate technologies that do not use cadmium are readily available.

This exemption only affects a small number of manufacturers. The more disconcerting impact for industry is that Parliament has served notice that it may be looking over the Commission’s shoulder during the current renewal of most Annex III exemptions.

The Germany Environment Agency (UBA) has published a report which suggests and argues that the REACH authorisation procedure could be extended to imported articles. The prevailing view from ECHA and the European Commissions has been that authorisation only applies to the use within the EU of Annex XIV (Authorisation List) chemicals. This has been a long standing sore point for EU manufacturers that feel disadvantaged compared to foreign manufacturers that are not subject to such requirements.

The UBA report is available from their website. They’ve provided the following introduction to their report

The EU might introduce an authorization scheme for imported goods such as clothing, sports gear and toys in the REACH Regulation, to aim at a better protection of humans and the environment against Substances of Very High Concern in articles. An UBA study claims that the necessary amendment of the EU chemicals regulation REACH would not breach international trade law. Another simple improvement could be achieved by introducing a standardized communication format to oblige manufacturers to indicate not only the name of the Substances of Very High Concern, but also the concentrations, total volumes and information about hazardous properties and safe use and disposal through the production chain.

The UBA report is another step towards making foreign manufacturers who import products into the EU accountable and on a level playing field with EU manufacturers. Given that the report was published in English rather than in German, it may be intended as part of a lobbying/publicity campaign. It would take several years to implement such regulatory changes. It’s too early to take specific actions based on this report; however, it further emphasizes the motivation to design out any SVHCs that remain as constituents in your products.