A full draft of criteria for the Sustainability of Network Equipment has been completed. A public review of the criteria is currently underway until December 31, 2020.
The criteria were developed by the Sustainable network equipment technical committee led by the TÜV Rheinland certification body and the U.S. based Green Electronic Council (GEC). It will be used for assessing the sustainability of network equipment under the GEC EPEAT ecolabel program and TÜV Rheinland’s Green Product Mark.
The Version 8.0 Energy Star Computers Program Requirements came into effect on October 15, 2020. The specification is available on the Energy Star website[1].
[1] Energy Star Version 8.0 computer specification, https://www.energystar.gov/products/spec/computers_version_8_0_pd
IEC Technical Committee TC111 WG3 is updating the IEC 62321-2 “Determination of certain substances in electrotechnical products – Part 2: Disassembly, disjunction and mechanical sample preparation” standard.
The update includes a refresh of Annex B on the risk of RoHS substances being present in materials and parts used in EEE products. This is the only Internationally recognized guidance on risk of RoHS substances in EEE and is used by several EEE manufacturers in their compliance programs. The revised draft Annex B will add material risk information for the four phthalate substances, and it updates the risk levels based on changes in the EEE supply chain over the past 15 years.
The European Commission launched a preparatory study earlier this year to assist in preparing the Ecodesign and Energy Labelling Working Plan for 2020-2024. The list of product categories and the new horizontal measures being considered may be useful information in anticipating upcoming requirements.
The Draft report on the task 2[1] identification of product groups and horizontal measures identifies:
Remaining product groups from working plan 2016-2019:
New product groups
New horizontal measures
[1] Ecodesign working plan task 2 report, https://www.ecodesignworkingplan20-24.eu/documents
The French Ministry of Ecology is conducting a public consultation on several draft regulations for the calculation and display of a repairability index on select electrical and electronic products. The draft regulations will be implementing legislation for the France Anti-waste and Promotion of Circular Economy Law, 2020-105.
The requirements are being implemented in a hierarchical series of legislative instruments
The first set of product categories proposed for the repairability index include:
Draft Decree on Repairability Index
The “Repairability Index of Electrical and Electronic Equipment, Draft Decree”[1] provides the over-arching requirements and obligations. Once in effect, the decree provides definitions and will impose regulatory obligations on producer, importers, distributors, and sellers with regard to calculating and displaying the repairability index for select EEE products.
The draft decree emphasizes that the requirements apply regardless of whether a product is sold in stores or through distance selling (e.g. online sales). It also does not make any mention about the location of these organizations; suggesting the obligations are applicable whether the organization is in France or foreign.
Summary of specifications:
The repairability index is calculated based on an equal weighting of the following five parameters:
The proposed Decree states that it will enter into force on January 1, 2021 and that as of January 1, 2024, a durability index is expected to supplement or replace the repairability index.
Display methods, signage and general parameters
The proposed “Order regarding the display methods, markings and general parameters for calculating the repairability index” (notification number 2020/0469/F – H00) specifies the display of the repairability index and provides general rules for the calculation of the index.
The repairability mark (on products or retail displays) includes a score out of 10 and a color-coded repair symbol (red (low) through green (high)) (Figure 1). The draft order describes the details of the mark and its presentation.
Figure 1: graphical ‘repairability index’ mark
The proposed Order describes the parameters (criteria and sub-criteria) for calculating the repairability and provides a template .
The draft Order also provides a list of ‘common tools’ for the purpose of scoring sub-criteria 2.2 on ‘tools required’.
Two lists of spare parts have been defined and are used in criteria 2, 3, and 4. The specific parts included on each list are specified in the product category specific order:
Product Category Specific criteria and rating systems
Specifications of criteria and sub-criteria for calculating the repairability index are provided in the product category specific orders. A sampling of the requirements for computer laptops and smartphones are provided below as indicative examples.
Computer laptops — proposed “Order of XXXX on the criteria, sub-criteria and scoring system for calculating and displaying the repairability index for laptop computers” specifies the details of each sub-criteria for laptop computers.
For the purpose of defining the scope of products that will need to display the repairability index, France is leveraging the scope of the EU regulation Commission Regulation (EU) No 617/2013 with regard to ecodesign requirements for computers and computer servers[1] and the associated definition of laptop computers.
Smart Phones — Draft “Order of XXXX on the criteria, sub-criteria and scoring system for calculating and displaying the repairability index for smartphones”
Criterion No1 – Documentation
1.1 Producer’s commitment on the duration (technical documents and instructions): Disassembly diagram, Wiring and connection diagram, Error and diagnostic codes, etc.
(producer, repairers, consumers)
Spare parts for criteria 2, 3, and 4:
Criterion No2 – Disassembly and access, tools and fasteners
*ND/NA = not removable or not individually accessible
2.1 Ease of disassembling the parts (number of steps to access): 16 and more, 11-15, 6-10, 1-5
2.2 Tools required to disassemble parts: ND/NA, Proprietary tools, Specific tools, Tool-free, common tools
2.3 Characteristics of the fasteners: Neither removable nor reusable, Removable, non-reusable, Removable and reusable
Criterion No3 – Availability of spare parts
Based on years of availability and column (producer, spare parts distributor, repairers, consumers)
3.1 and 3.2 Producer’s commitment on the period of availability (list 1 and list 2 parts)
3.3 and 3.4 Delivery time for parts (list 2 and list 1)
Criterion No4 – Price of spare parts
4.1 Ratio of the price of list 2 parts compared with the price of the new product
Criterion No5 – Specific criterion
5.1 Information on type of update: Corrective, Evolving or Mixed (consumers)
5.2 Free remote assistance: Up-to-date information on website, Remote diagnostic assistance and Remote repair assistance (repairers and consumers)
5.3 Possibility of resetting software: Operating system reset and Firmware reset (producer, repairers, consumers)
Impact on EEE Manufacturers
The product categories that will need to display a repairability index focused on a limited set of high volume products, but this may be expanded to a broader set of products. It’s also likely that the requirements will spread across the EU in light of the European Circular Economy Action Plan.
A limitation in the current repairability index is that it does not take into account the durability of products – durability of the components and the system can mitigate some of the need for repairability (as noted in the European standard EN 45552 “General method for the assessment of the durability of energy-related products”. Based on the draft decree, France is considering a future modification in the requirements to address this aspect.
[1] EU Regulation on computers and servers, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013R0617
[1] France Draft Decree, https://ec.europa.eu/growth/tools-databases/tris/en/index.cfm/search/?trisaction=search.detail&year=2020&num=468&mLang=en&CFID=5701851&CFTOKEN=7c34eb62578d4a6e-DFA2D618-9D36-76EE-856C43CF20CCA460
[2] France notification 2020/0469/F – H00, H00, https://ec.europa.eu/growth/tools-databases/tris/en/index.cfm/search/?trisaction=search.detail&year=2020&num=469&mLang=EN
The revised IPC-1752B: Materials Declaration Management Standard was published by IPC in early July 2020. The standard is a major revision to IPC-1752A which was in effect from 2010 until 2020. IPC-1752B includes technical changes that are not backward compatible to earlier versions of the standard. It supports SCIP data by using a combination of Class C and Class D declarations. The IPC-1752B standard is available on the IPC website[1].
[1] IPC-1752B standard, https://shop.ipc.org/search?keywords=1752B
ECHA launched a public consultation on the restriction proposal for Perfluorohexanoic acid (PFHxA), its salts and related substances in the EU. PFHxA substances are used in the manufacture of fluoropolymers (plastics which may be used in EEE) and clothing. They are used as manufacturing chemicals and typically would not remain in a finished product; however, the proposed threshold for PFHxA substances in polymers is very low (0.0001%) meaning that even residual amounts of the substances could be above the restriction level.
PFHxA substances are also used in semiconductor manufacturing operations. An exemption is proposed for this application.
Additional information on the proposed restriction and the consultation may be found on the ECHA website[1].
[1] PFHxA consultation website, https://echa.europa.eu/restrictions-under-consideration/-/substance-rev/25419/term
The May 18, 2020, the EU officially updated the reference standard for EU RoHS technical documentation to IEC EN 63000 from the previous standard EN 50581. The change was published in EU Decision (EU) 2020/659. EN 50581 remains valid until November 18, 2021.
Impact on EEE Manufacturers
The transition to IEC 63000 has been planned for the past couple years and should not have a material impact on conformity assessment– both IEC 63000 and EN 50581 specify very similar requirements.
Manufacturers with products that are in scope of EU RoHS should start to update their EU Declarations of Conformity to reference IEC EN 63000 (or IEC 63000) instead of EN 50581. An 18-month transition period is provided to make the changes.
A study by the German Environmental Agency (UBA) has found that the phthalate DPHP has become the primary substitute for DEHP. DEHP has been a REACH Candidate List SVHC since 2008 and was restricted by the EU RoHS Directive in EEE starting in 2019. It was commonly used as a plasticizer in wire sheathing and other soft plastic parts. The study, which conducted testing of phthalate levels in the environment between 2006 and 2017 found that the level of DEHP went from a mean of 2,710 nanograms per gram of dry weight (ng/g dw) to 991ng/g dw. Whereas DPHP has increased from 57ng/g dw to 550ng/g dw over the same time period.
The increased use of DPHP has gained it additional attention with regulators; the phthalate is undergoing evaluation this year to consider:
Impact on EEE Manufacturers
There is a possibility that DPHP may exhibit properties that makes it eligible as a candidate to become a REACH SVHC. Manufacturers should try to collect and maintain information on phthalates that are used in the product parts they procure.
The European Commission has focused their attention on two of the seven substances that are under consideration for EU RoHS restriction. The two substances being recommended for the RoHS Annex II list of restricted substances are: TBBPA and MCCPs (Table 1).
| Substance(s) | Synonyms | CAS Number |
|---|---|---|
| Tetrabromobisphenol A (2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol) | TBBP-A | 79-94-7 |
| Medium- chained chlorinated paraffins –Alkanes, C14-17, chloro (chlorinated paraffins containing paraffins with a chain length of C14-17 – linear or branched) | MCCP | 85535-85-9 |
The consultants presented the results of their evaluation during a stakeholder webinar on April 27, 2020. A summary of some key information is provided below and links to presentation materials are provided at the end of this article.
Tetrabromobisphenol A (TBBP-A)
The consultants indicated that the primary uses for TBBP-A in EEE include:
The general conclusion was that TBBP-A used as a resin in the production of printed circuit boards would be mostly consumed in the manufacturing process with residual TBBP-A remaining in the product generally below the 0.1% of homogeneous material threshold.
The focus of a restriction would be on TBBP-A as an additive flame retardant that remains in thermoplastic materials.
TBBP-A is also being assessed under the EU REACH regulation as a possible SVHC. The consultants are recommending that the results of the SVHC assessment be considered in any final RoHS restrictions
Medium-chain chlorinated parafins (MCCP)
The consultants presented the following MCCP uses and amounts:
MCCP was also recently assessed under REACH and found to meet the criteria for consideration as an SVHC.
Further Information:
Links to the presentations from the stakeholder webinar are provided at the bottom of the webpage on interim results of substance review[1].
[1] Presentation from RoHS substance review, https://rohs.exemptions.oeko.info/index.php?id=341
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