Category Archives: nl2014q4

EEE Environmental Compliance Challenges and Future Directions Discussed at Going Green – Care Innovation Conference

The 2014 Going Green – Care Innovation conference took place November 17, 2014 to November 20, 2014. The conference is held once every four years and brings together a critical mass of environmental managers, engineers, corporate executives, government representatives and academic researchers that are focused on environmental performance and compliance. The conference provided the best opportunity in 2014 for insight to the upcoming direction and priorities related to environmental management and tools.

This year’s conference theme was “Towards a Resource Efficient Economy”. The most notable environmental focus areas during the conference were: compliance to environmental legislation, end of life management (recycling), circular economy, eco-design including material selection and efficiency, eco-labels and green procurement.

The opening keynote “Challenges in the field of Resource efficiency, Eco-innovation and Circular economy – for the EU and within the new Commission” was delivered by Luisa Prista from the European Commission. It was the first of several presentations that highlighted the Commission’s forward looking emphasis on increased use of recycled materials in products and increased material recycling (particularly scare and environmentally sensitive materials) to meet the demand.

Ms. Prista noted that the new European Commission president, Jean-Claude Juncker, has received letters from several corporate executives emphasizing the need to invest and develop the circular economy. Consequently, the Commission is launching several pilot projects to develop capability and prove concepts where there are currently gaps. As with other similar previous EU initiatives, the general expectation is that the pilot programs will eventually lead to regulations once the concepts are proven and systemic capability begins to emerge.

Opening Panel Discussion

During a subsequent panel discussion Ms. Prista and executives from Siemens Healthcare, Philips, Electrolux, and Toshiba identified several other urgent priorities including:

  •  Supply chain information on material content
  • Collaboration in the supply chain
  • Better education and understanding
  • Common tools
  • Harmonization in regulations
  • Better understanding of regulations

Strategic Roadmap for International Environmental Standards provides Insight for Manufacturers

The IEC technical committee responsible for environmental standards for the EEE industry (IEC/TC111) recently updated its strategic roadmap to highlight areas that have emerging needs for international standardization. This roadmap provides EEE manufacturers and suppliers with insight into areas with emerging conformity requirements and where more well defined methods and/or guidance are needed. These requirements are typically driven by new regulations or divergent requirements that are causing trade barriers or supply chain issues.


In 2004, the International Electrotechnical Commission (IEC) created technical committee TC111 to develop internationally recognized standards to assist manufacturers in complying with emerging environmental regulations of Electrical and Electronic Equipment (EEE) and other voluntary initiatives. The use of harmonized standards reduces uncertainty and risk for international trade and helps enable communication and consistency across a global supply chain. IEC standards are recognized by the World Trade Organization (WTO) and member countries of the WTO have agreed to harmonize their national standards with IEC standards wherever possible.

The Role of IEC Environmental Standards

Several of the IEC/TC111 standards are commonly used for assessing compliance to regulations such as EU RoHS (and other global RoHS regulations), EU REACH (declaration of SVHCs), WEEE, and emerging carbon footprint and environmental footprint regulations. The standards provide tools for material declaration, assessing restricted substance controls, analytical testing, environmentally conscious design, etc.

For a list of all IEC/TC111 published standards and standards under development, see the RoHS news post IEC/TC111 – Environmental standardization for electrical and electronic products and systems.

IEC is often not the first standards organization to create a standard on a specific topic, but it can help harmonize approaches across national or regional standards.

What’s New in the Revised Roadmap

The standardization topics in the roadmap are organized into seven categories:

  • Chemical Substance
    • Standardized substance testing methodologies
    • Maintenance and improvement activities related to material declaration
    • Demonstration of due diligence for substance restriction conformity.
    • Definition of “low halogen” materials used in electrotechnical products.
  • Environmental Conscious Design (ECD)
    • Environmentally Conscious Design (the intention is to progress IEC 62430 to a dual logo ISO/IEC standard that is applicable to all products)
    • Product Category Rules (for full LCA of multiple environmental impacts)
  • Recovery/Recycling/Reuse
    • Treatment, collection and logistics of Waste Electrical and Electronic Equipment (WEEE)
  • Greenhouse Gases (GHG)
    • Methodologies and rules for Carbon footprint calculation of EEE
    • Electrotechnical specific secondary data
  • Resource efficiency
  • SMART Cities
  • Environmental Product Declarations and Eco labels
    • Environmental Performance Criteria that may be used in eco labels used for green electronics purchasing
    • Product Category Rules (for full LCA of multiple environmental impacts)

The IEC/TC111 roadmap is included in the Strategic Business Plan (SBP) which may be downloaded from the IEC website.

The standardization topics under Environmental Product Declarations (EPD) and Eco labels are newly added and have been gaining considerable interest.

Environmental Performance Criteria

The standardization area of “Environmental Performance Criteria” is in response to the plethora of eco label criteria emerging around the world. Environmental labelling programs and registries specify criteria for assessing environmental performance of a variety of electrical and electronic products. Programs exist for computers, monitors, imaging equipment, TVs, tablets, phones, and many other EEE products. These programs give purchasers an easy, predefined mechanism to set green procurement requirements. However, many of the environmental labelling programs have overlapping scope and sometimes establish inconsistent (or even incompatible) environmental criteria. Inconsistencies can create significant challenges for manufacturers and suppliers who try to optimize environmental performance of products and manufacturing operations simultaneously for all markets around the world.

An IEC International Standard on Environmental Performance Criteria would enable users, ecolabelling bodies and registries, manufacturers and supplies (from around the world) to leverage and build upon a harmonized set of baseline environmental performance criteria. A harmonized set of baseline criteria provides benefits to all stakeholders.

Product Category Rules (PCR) for Life Cycle Assessment (LCA)

An International standard for EEE product category rules has also been gaining interest. Conducting LCAs that provide meaningful information is challenging for the electronics industry.  With a complex supply chain and significant impacts from raw material extraction and part manufacturing in several environmental impact categories, the assumptions made with respect to setting scope, boundary conditions, cut-off rules, product use, electricity generation, and the use of primary vs. secondary data are very important in the usefulness and comparability of the results. This is particularly important as governments around the world tighten rules to avoid green washing with environment claims.

A baseline set of internationally harmonized PCR across the electrotechnical industry can provide a significant opportunity for the industry to better utilize the results of a LCA.  The International Standard may also provide rules and guidance for the development of supplemental sector specific PCR that may be needed for specific types of products. A baseline PCR across the entire EEE industry will also provide consistency for the supply chain which may be providing parts and materials to a number of different sectors.

ECD Compliance uses published and emerging International Standards to support manufacturers and suppliers in meeting current and future product environmental compliance and sustainability requirements. We can also provide a window for your organization into emerging environmental standards.  For additional information, contact ECD Compliance.

Future posts will examine some of these standardization areas in more detail.



New Substances for RoHS Directive Notified to WTO

The European Commission moved forward with its update of the List of Restricted Substances in the RoHS Directive, Annex II. The Commission has notified the World Trade Organization that the four phthalate substances will be added to the RoHS substance restrictions.  The restrictions take effect beginning in July 22, 2019 for all EEE except category 8 (medical devices) and category 9 (monitoring and control instruments) which will have an additional 2 years and need to comply by July 22, 2021. This provides most EEE manufacturers and the global supply chain with four and a half years to prepare.

Four Phthalate Substances to be Added to RoHS Directive

Substance NameCAS NumberMaximum Concentration
in homogeneous material
Bis(2-ethylhexyl) phthalate (DEHP)117-81-70.1%
Benzyl butyl phthalate (BBP)85-68-70.1%
Dibutyl phthalate (DBP)84-74-20.1%
Diisobutyl phthalate (DIBP)84-69-50.1%

The maximum concentration value for the phthalates will be 0.1% w/w in homogeneous material.

The four phthalates are already listed on the REACH SVHC Candidate List — this gives manufacturers that have REACH SVHC information from their suppliers a head start in assessing  the parts and materials that require substitution.  However, the different basis for calculating concentration level between REACH and RoHS (article vs. homogeneous material) will undoubtedly create some surprises.

Additional information on RoHS 2 compliance and RoHS 2 Technical Documentation is available. ECD Compliance provides services to assess your product requirements for compliance to environmental regulations and to implement compliance procedures.

The notified Directive is available on the WTO website.

Six Substances added to REACH SVHC Candidate List – December 17, 2014

The European Chemical Agency (ECHA) added six additional substances to the SVHC Candidate List on December 17, 2014. This brings the total number of substances on the Candidate List to 161. Manufacturers, importers and distributors have communication obligations in the EU if any of their products contain one of these substances above the reporting threshold of 0.1% w/w.

REACH SVHCs Added to Candidate List on December 17, 2014

Cadmium fluoride232-222-07790-79-6Carcinogenic (Article 57 a);
Mutagenic (Article 57 b);
Toxic for Reproduction (Article 57 c);
Equivalent level of concern having probable serious effects to human health (Article 57 f)
Cadmium sulphate233-331-610124-36-4; 31119-53-6Carcinogenic (Article 57 a);
Mutagenic (article 57 b);
Toxic for Reproduction (Article 57 c);
Equivalent level of concern having probable serious effects to human health (Article 57 f)
2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320)223-346-63846-71-7PBT (Article 57 d);
vPvB (Article 57 e)
2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)247-384-825973-55-1PBT (Article 57 d);
vPvB (Article 57 e)
2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)239-622-415571-58-1Toxic for Reproduction (Article 57 c)
Reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (reaction mass of DOTE and MOTE)--Toxic for Reproduction (Article 57 c)

In addition to the six new entries on the Candidate List, the existing entry Bis(2-ethylhexyl) phthalate (DEHP) was updated based on “Equivalent level of concern having probable serious effects to the environment (Article 57 f)”

The REACH Candidate List SVHCs are available on the ECHA website. Additional information on the REACH SVHC obligations for organizations that manufacture or ship products into the EU are available on the ECD Compliance REACH web page.

Products Containing Mercury Regulations published in Canada

The Canadian “Products Containing Mercury Regulations” were published in the Canada Gazette on November 19, 2014 and come into force on November 8, 2015. The Regulations will prohibit the manufacture and import of products containing elemental mercury or a mercury compound. Exemptions to the mercury prohibition are provided for applications that have no technical alternative – they are similar but not identical to the EU RoHS mercury exemptions. For products that contain mercury, specific labelling and marking requirements are specified in the regulations.


The Regulations apply to any product that contains mercury, including all electrical and electronic equipment (EEE) whether currently included or excluded from the scope of the EU RoHS Directive. In this regard, the Canadian Regulations have a broader applicability than the EU RoHS Directive; however, the exemptions also cover applications that are not relevant to EEE such as use of mercury in dental amalgam.

The regulations do not apply to products that are at end-of-life, waste, a food, drug, or cosmetic, veterinary biologic, pest control product, feed, fertilizer, or explosive, ores, concentrates and by-products of metallurgic operations, and on-road vehicles from the 2016 model year or earlier.

Prohibitions and Exemptions

A product that contains mercury may not be manufactured or imported unless it belongs to a product category that has a specified exemption or if a manufacturer or importer holds a permit issued under the Regulations.

The exemptions are similar to the EU RoHS exemptions but not identical. There are differences in the wording of the allowed applications and in the allowed mercury concentration. A careful comparison is needed to ensure that a product containing mercury meets the Canadian regulation.

The regulations specify additional requirements for products that are imported or manufactured with mercury (for example, under an exemption). The additional requirements include labelling, marking, information on safe use (including when a product such as a lamp breaks), and reporting of mercury quantity that is imported or manufactured.

For product uses that are not covered by an exemption, it is possible to request a permit from Environment Canada.

For additional information or assistance on the Canadian Products Containing Mercury Regulations, contact ECD Compliance.

EU – Restrictions are Focus of New Enforcement Project

The European Forum for Exchange of Information on Enforcement is developing a new enforcement project on compliance to REACH Annex XVII substance restrictions. According to the ECHA press release, the timing for the enforcement project is: “The scope and individual restrictions to be covered will be confirmed in early 2015. Inspections will then take place during 2016. The final report will become available in 2017.”

The Forum coordinates a network of EU Member State authorities responsible for REACH enforcement and is composed of one representative from each of the EU Member States.

USA – California Proposition 65 chemicals update

Several chemicals added to California Proposition 65 over the past year are coming into effect within the next few months.

One of the chemicals, the Phthalate DINP, may be used as a plasticizer in EEE. The addition of DINP to California Prop 65 has been controversial. The American Chemistry Council launched a lawsuit against the California Office of Environmental Health Hazard Assessment with respect to the addition; however, the Court will not rule before civil enforcers can begin filing notices. The deadline for manufacturers to provide the Prop 65 warning label on products that contain DINP and are potential exposure risks is December 20, 2014.

Other substances with deadlines in January-May 2015 include Trichloroethylene (TCE), Methyl Isobutyl Ketone (MIBK), Pulegone, N,N-Dimethyl-P-Toluidine.

EU – Second Stakeholder Meeting on Lot 9 Study on Enterprise Servers and Data Equipment

The 2nd stakeholder meeting for EU Ecodesign Lot 9 preparatory study on enterprise servers and data equipment was held in Brussels on October 13, 2014. Minutes and presentations from the meeting are available on the study website.

Much of the discussion raised by stakeholders during the meeting focused on the large variation in how equipment within the scope of this study is used and the impact of operating systems and software. Consequently, it’s difficult to develop well defined regulatory requirements on energy efficiency and other environmental performance criteria.

The next steps in the preparatory study (see Figure 1) include:

  • Submission of stakeholder responses to questionnaire on best available technologies (BAT) by November 14.
  • Draft final report in February 2015
  • Next Stakeholder meeting is planned for March 2015

Final report is scheduled for May 2015.


BNST Restriction in Lubricants in EEE Approaching in March 2015

BNST (Benzenamine, N-phenyl-, Reaction Products with Styrene and 2,4,4-Trimethylpentene) has been used in lubricants in motors and other sliding mechanisms in many types of electrical and electronic products.  The substance is added to lubricants as an additive that provides performance enhancements as an antioxidant, corrosion inhibitor, tarnish inhibitor, and scavenger and antiscaling agent. BNST containing lubricants may be found in some computer storage drives and other applications with a motor.

BNST was restricted in Canada under the Prohibition of Certain Toxic Substances Regulations, 2012 beginning on March 14, 2013; however, a 2 year exemption for use of BNST as an additive in lubricants has extended the use period for applications in the EEE industry.

Although the general exemption in lubricants expires on March 13, 2015, manufacturers and importers may apply for a permit to continue manufacturing and importing products and parts (such as motors) that contain BNST in the lubricant after March 2015. Even if BNST is being designed out of new products, there is still a significant challenge for OEMs that need to continue providing spare parts for the repair of existing products — there is no exemption in the regulation for spare parts. Environment Canada requires 60 working days to process a permit application; therefore they are requesting that all applications should be submitted by no later than December 1, 2014 in order to have the permit issued on time.

The permit application includes requirements for information on BNST use and plans for phasing out the substance from your products.  Environment Canada has stated that applications not meeting specific minimum requirements cannot be approved.

The Prohibition Regulation is available for download from the Canada Gazette.

For support on completing and submitting a permit application, contact ECD Compliance.



Slates/Tablets Become Eligible for EPEAT Registry – September 2014

With the addition of slates and tablets to Energy Star, these products have become eligible for the EPEAT registry of environmentally preferable products. Many governments and other large organizations specify EPEAT registration as a mandatory requirement in their IT purchasing specifications and RFPs; therefore, EPEAT registration can be an important declaration for manufacturers and distributors.

The IEEE 1680.1 standard specifies the mandatory and optional requirements for listing a computer product on the EPEAT registry. Within this standard, Energy Star is a mandatory requirement, therefore tablets and slates have, in the past, been ineligible for EPEAT.  The new Energy Star specification opens the door to additional procurement opportunities but it creates risks for manufacturers that do not register their products.

ECD Compliance assists manufacturers with conformity to EPEAT requirements and EPEAT verification.  For additional information on EPEAT services, see our webpage or contact ECD Compliance.