Category Archives: Regulations

EU – ECHA Provides Data Requirements for SVHC in Articles (SCIP) Database

On September 9, 2019, the European Chemical Agency (ECHA) provided the specification with information requirements for the WFD (Waste Framework Directive) Database that manufacturers will need to use to submit information on SVHCs in their products.  ECHA is now referring to this as the SCIP Database. Manufacturers whose products are sold into the EU and contain an SVHC — which is true for most EEE products and large machinery, vehicles, etc — will need to submit information about their products into the database or provide information to importers/distributors for submission. The submission duty becomes mandatory as of January 5, 2021.

In the latest document, ECHA has modified some of the terminology that was used in earlier proposals, but otherwise the technical data requirements are similar to an earlier draft specification from May 2019.

The information requirements require manufacturers to submit information about the overall product (complex object) and the first article/component containing the SVHC (ECHA is now referring to this first article as “Article as such”). ECHA has summarized the requirements as:

Besides administrative contact details, suppliers of articles need to provide the following information to ECHA:

      • information that allows the identification of the article;
      • the name, concentration range and location of the Candidate List substance(s) present in that article; and
      • other information to allow the safe use of the article, notably information to ensure proper management of the article once it becomes waste.

ECD Compliance has been providing comments to ECHA on the data requirements, material categories, and IT system on behalf of our clients.  We will continue to provide input as the database is developed and to participate in ECHA SCIP User Groups.

We are already working with our clients (manufacturers, suppliers and solution providers) to help setup supply chain communication, IT systems and data collection in preparation for the January 5, 2019 deadline to meet the obligation.  Starting the process as soon as possible is critical to success and on-going compliance with EU regulations.  Contact ECD Compliance to discuss how we can help your organization.

EU – REACH Annex XVII restriction of Phthalates

Commission Regulation (EU) 2018/2005[1] revised the Phthalates entry in REACH Annex XVII to cover most products. The restriction includes the four phthalates: DEHP, DBP, BBP, DIBP. There are some exclusions for certain products that are already subject to phthalate restrictions.

The regulation was published on December 18, 2018 with restrictions that start to come into effect on July 7, 2020.  An extended transition time is provided for motor vehicles and aircraft (until 2024). Exclusions with no time limit are also provided for measuring devices for laboratory use, medical devices, and packaging of medicinal products – details about the exclusions are provided in the regulation.

For products that are within the scope of the new restrictions, the concentration threshold for the sum of all four phthalates is 0.1% by weight of the plasticised material.

[1] REACH Annex XVII phthalate restriction, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R2005&from=EN

EU – Ten EU RoHS Exemptions Published

On February 5, 2019, the European Commission published the delegated directives for renewal of exemptions 7(c)-II, 7(c)-IV, 8(b), 15, 18(b), 21, 29, 32, and 37 and new exemption 42. The table includes the Index #, descriptions and expiry to replace the existing exemptions (previous wording of exemption is shown in the right-most column). The revised exemptions take effect starting March 1, 2020.

Manufacturers should take a close look at the renewed exemptions with respect to their products.  Several applications that were previously allowed to use the restricted substance are no longer exempted once the renewals take effect next year. Other applications are being phased out on an accelerated timeline.  ECD Compliance is working with manufacturers and suppliers to identify impacts and risks in the supply chain and manufacturing processes.

Table 2: Ten EU RoHS Exemptions Published

Delegated Directives Published on February 5, 2019Previous Annex III Wording for comparison
Index #Exemption DescriptionExpiry
In Annex III, entry 7(c)-II is replaced by the following:
7(c)-IILead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higherDoes not apply to applications covered by point 7(c)-I and 7(c)-IV of this Annex.
Expires on:
— 21 July 2021 for categories 1-7 and 10;
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher
In Annex III, entry 7(c)-IV is replaced by the following:
7(c)-IVLead in PZT based dielectric ceramic materials for capacitors which are part of integrated circuits or discrete semiconductorsExpires on:
—21 July 2021 for categories 1-7 and 10;
—21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
—21 July 2023 for category 8 in vitro diagnostic medical devices;
—21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead in PZT based dielectric ceramic materials for capacitors being part of integrated circuits or discrete semiconductors
In Annex III, entry 8(b) is replaced by the following:
8(b)Cadmium and its compounds in electrical contactsApplies to categories 8, 9 and 11 and expires on:
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Cadmium and its compounds in electrical contacts
8(b)-ICadmium and its compounds in electrical contacts used in:
—circuit breakers,
—thermal sensing controls,—thermal motor protectors (excluding hermetic thermal motor protectors),
—AC switches rated at:
—6 A and more at 250 V AC and more, or
—12 A and more at 125 V AC and more,
—DC switches rated at 20 A and more at 18 V DC and more, and
—switches for use at voltage supply frequency ≥ 200 Hz.
Applies to categories 1 to 7 and 10 and expires on 21 July 2021Cadmium and its compounds in electrical contacts
In Annex III, entry 15 is replaced by the following:
15Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packagesApplies to categories 8, 9 and 11 and expires on:
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages
15(a)Lead in solders to complete a viable electrical connection between the semiconductor die and carrier within integrated circuit flip chip packages where at least one of the following criteria applies:
— a semiconductor technology node of 90 nm or larger;
— a single die of 300 mm2 or larger in any semi­conductor technology node;
— stacked die packages with die of 300 mm2 or larger, or silicon interposers of 300 mm2 or larger.
Applies to categories 1 to 7 and 10 and expires on 21 July 2021.Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages
In Annex III, entry 18(b) is replaced by the following:
18(b)Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb)Expires on:
—21 July 2021 for categories 1-7 and 10;
—21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
—21 July 2023 for category 8 in vitro diagnostic medical devices;
—21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb)
18(b)-1Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps containing phosphors such as BSP (BaSi2O5:Pb) when used in medical phototherapy equipmentApplies to categories 5 and 8, excluding applications covered by entry 34 of Annex IV, and expires on 21 July 2021.
In Annex III, entry 21 is replaced by the following:
21Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glassesApplies to categories 8, 9 and 11 and expires on:
— 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
— 21 July 2023 for category 8 in vitro diagnostic medical devices;
— 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses
21(a)Cadmium when used in colour printed glass to provide filtering functions, used as a component in lighting applications installed in displays and control panels of EEEApplies to categories 1 to 7 and 10 except applications covered by entry 21(b) or entry 39 and expires on 21 July 2021.
21(b)Cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glassesApplies to categories 1 to 7 and 10 except applications covered by entry 21(a) or 39 and expires on 21 July 2021.
21(c) Lead in printing inks for the application of enamels on other than borosilicate glassesApplies to categories 1 to 7 and 10 and expires on 21 July 2021.
In Annex III, entry 29 is replaced by the following:
29Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC (*1)Expires on:
—21 July 2021 for categories 1-7 and 10;
—21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
—21 July 2023 for category 8 in vitro diagnostic medical devices;
—21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC
(*1) Council Directive 69/493/EEC of 15 December 1969 on the approximation of the laws of the Member States relating to crystal glass (OJ L 326, 29.12.1969, p. 36).
In Annex III, entry 32 is replaced by the following:
32Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubesExpires on:
—21 July 2021 for categories 1-7 and 10,
—21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments,
—21 July 2023 for category 8 in vitro diagnostic medical devices,
—21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes
In Annex III, entry 37 is replaced by the following:
37Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass bodyExpires on:
—21 July 2021 for categories 1-7 and 10;
—21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
—21 July 2023 for category 8 in vitro diagnostic medical devices;
—21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body
In Annex III, entry 42 is added:
42Lead in bearings and bushes of diesel or gaseous fuel powered internal combustion engines applied in non-road professional use equipment:
—with engine total displacement ≥ 15 litres;
or
—with engine total displacement < 15 litres and the engine is designed to operate in applications where the time between signal to start and full load is required to be less than 10 seconds; or regular maintenance is typically performed in a harsh and dirty outdoor environment, such as mining, construction, and agriculture applications.
Applies to category 11, excluding applications covered by entry 6(c) of this Annex.

Expires on 21 July 2024.
n/a

 

EU – REACH Candidate List Updated with Six SVHCs

On January 15, 2019, the European Chemical Agency (ECHA) added six additional substances to the EU REACH Candidate List. The new SVHC entries are listed in Table 1. The IEC 62474 Validation Team has reviewed the substances for potential uses in EEE – SVHCs that are potential EEE constituents are shown with their typical EEE applications.  There is now a total of 197 SVHC entries on the REACH Candidate List.

The full REACH Candidate List is available on the ECHA website[1].

Table 1: REACH Candidate List - Six New SVHCS

NameDescriptionEC no.CAS no.Typical EEE Applications
1,7,7-trimethyl-3-(phenylmethylene)bicyclo[2.2.1]heptan-2-one3-benzylidene camphor; 3-BC239-139-915087-24-8n/a
2,2-bis(4'-hydroxyphenyl)-4-methylpentane401-720-16807-17-6White crystalline powder, Raw material for epoxy resins, Raw materials for polycarbonate resin, Thermal paper, Chemicals, Surface coatings, Inks, Adhesives, Synthetic resin additives, Liquid crystal materials, Photosensitizers, Information recording agents, Engineering plastic materials, Electronic functional materials, Optical functional materials; may be used as substitute for BPA
Benzo[k]fluoranthene205-916-6207-08-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbers
Fluoranthene205-912-4206-44-0; 93951-69-0Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbers
Phenanthrene201-581-5January 8, 1985Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbers
Pyrene204-927-3129-00-0; 1718-52-1Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbers

[1] REACH Candidate List, http://echa.europa.eu/candidate-list-table

Canadian Mercury Regulations – Part 3 – Exemptions

In part 1 (Products Containing Mercury Regulations published in Canada) and part 2 (Canadian Mercury Regulations to Impose Tight Restrictions on Mercury in Batteries) of our series of articles on Canadian Products Containing Mercury Regulations we discussed the scope of the regulations and maximum concentration limits for batterieis and other products and how they compare to the EU RoHS Directive and the EU Battery Directive.  In this part 3 of the series we will look at mercury exemptions, harmonized standards for product testing and spare parts. There are still numerous applications, particularly with mercury containing lamps whereby mercury is critical to proper functioning of the product.

Prohibitions and Exemptions

Under the Canadian Regulations, a product that contains mercury may not be manufactured or imported in Canada unless there is an applicable exemption or if the manufacturer or importer holds a permit issued under the Regulations. The exemptions are listed in the Schedule to the Regulations and each entry includes the product category, the maximum total quantity of mercury in the product, and the end date of the exemption.

The exemptions are similar to the EU RoHS exemptions but not identical. In general, the Canadian exemptions are more flexible, allowing slightly higher levels of mercury content for lamps. For example, item 2(a) of the Schedule specifies that a compact fluorescent lamp for general lighting purposes (≤ 25 Watts) may have up to 4 mg of total mercury per lamp. The comparable exemption in the EU RoHS Directive (exemption 1(a)) allows up to 2.5 mg of mercury per burner (this was originally 5 mg but was reduced to 3.5 mg in 2012 and then 2.5 mg as of January 1, 2013).

The applications (product categories) specified in the exemptions do not align perfectly between the two regulatory instruments, so manufacturers will need to perform a careful comparison to ensure that a product containing mercury meets the Canadian Regulations.

A renewal of most of the EU RoHS exemptions will occur in 2016 and it’s possible that the EU maximum allowable mercury levels will decline further.

The Canadian Regulations provide exemptions for other product categories that are not exempted under the EU RoHS Directive. Other exempted products relevant to the electrotechnical industry include:

  • Scientific instrumentation for the calibration of medical devices or for the calibration of scientific research instruments;
  • Scientific instrumentation used as a reference for clinical validation studies;

Product Testing

For determining the level of mercury content in products, the Canadian Regulations references IEC 62321-4:2013, entitled Determination of certain substances in electrotechnical products — Part 4: Mercury in polymers, metals and electronics by CV-AAS, CV-AFS, ICP-OES and ICP-MS, which is also referenced by the EU RoHS harmonized standard for technical document (EN 50581).

Spare Parts

The Canadian Regulations provide an exemption for replacement parts – this is similar to the EU RoHS exclusion for spare parts.

Technical support on environmental product regulations

ECD Compliance provides manufacturers and suppliers with services to track global environmental product requirements and assess the impact to their products and markets, including the Canadian Products Containing Mercury Regulations.

China RoHS 2 – Expanded Scope takes Effect on July 1, 2016

After years of uncertainty surrounding China RoHS 2, China’s Ministry of Industry and Information Technology (MIIT) published the revised regulation on January 21, 2016. Starting July 1, 2016, companies that manufacture, import or sell Electrical and Electronic Products in China will need to comply with the new requirements. China RoHS 2 aligns more closely with EU RoHS than the original China RoHS but it still retains the unique labeling and documentation requirements and expands the requirements to many products that weren’t previously in scope.

The expanded scope combined with the short timeline for compliance will certainly be a challenge for many product manufacturers. Eliminating the exclusion for exported products also affects companies that have their products manufactured in China.

Manufacturers of products that are already EU RoHS compliant should have sufficient information on hand to compile the new China RoHS documentation; but products that aren’t yet EU RoHS compliant may present a challenge to their manufacturers.  For example, industrial monitoring and control instruments and products that fall into Category 11 “Other EEE not covered by any of the categories above” aren’t subject to EU RoHS requirements until 2017 and 2019 respectively, but both need to meet the China RoHS 2 requirements this year. The requirement to identify all presence of the six hazardous substance groups, including uses that are covered by EU RoHS exemptions, can create a particular challenge.

The Regulation

The regulation, officially titled “Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”, is generally aligned with the China RoHS 2 draft that was circulated in May 2015 with only a few minor surprises. As expected, the scope of the regulation is extended to all electrical and electronic products except for power generation, transmission and distribution equipment.

Definition of Electrical and Electronic Products

The definition of “Electrical and electronic products” refers to devices and accessory products which function by means of electric current or electromagnatic fields with rated working voltage up to and including 1500V DC and 1000V AC or which generate, transmit or measure such currents or electromagnetic fields. However, the definition explicitly excludes power generation, transmission and distribution equipment.

Hazardous Substances

The six original EU RoHS substances are still the basis for hazardous substances in China RoHS 2; although a seventh entry of “Other harmful substances as regulated by the State” leaves the door open to additional substances such as the four phthalate substances added to EU RoHS.

Labelling and Hazardous Substance Disclosure

A hazardous substances table that indicates presence of any of the six substances and where in the product they are located was carried forward from China RoHS to China RoHS2 (Article 13). The “environmental protection use period” (EPUP) label is also still required (Article 14). The regulation states that both the substance table and the EPUP label should be displayed directly on product; although the regulation provides an alternative if necessary.

With the expanded scope of China RoHS 2, many additional products will need to display the EPUP label and the hazardous substances table as of July 1, 2016. The details of the hazardous substances table and the environmental protection use period are specified in the China standard SJ/T 11364-2014.

Substance Restrictions

Similar to the substance restriction mechanism in its predecessor, China RoHS 2 includes a “Compliance Management Catalog” to implement substance restrictions, specify exemptions and provide timelines.

Compliance to China RoHS 2 will be based on a “conformity assessment system” instead of the CCC certification specified in the original China RoHS — details will be provided later. The regulation only states that MIIT working together with other organizations will “establish a creditable mechanism based on the result of the assessments”.

End of Life Information and Design for Environment

A number of subtle provisions have been added into the regulation for design for environment and to facilitate recycling. The exact expectations of these provisions aren’t specified in the regulation but may emerge over time in China national standards and the FAQ that’s expected sometime this year.

To provide some insight, we’ve pulled out a few examples of DfE implications from the regulation:

  • Article 13 states that the hazardous substances table should provide information on what parts of the product may be recycled and information on possible impact on inappropriate use or disposal on the environment or health.
  • Article 10 states that the producer/manufacturer shall adopt materials and technologies that protect the environment and human health, are easy to recycle and allow high product recyclability rates.

Product Packaging

In the draft regulation released in May 2015, MIIT had removed the requirements on product packaging that were included in the original China RoHS. However, packaging was added back into the final version of China RoHS 2, although somewhat ambiguously. The new requirement states that mandatory standards and laws related to packaging must be met and that packaging materials must be nonhazardous, recyclable/biodegradable, and comply with national or industry standards.

Exported Products

The China RoHS 2 regulation applies to EEE products manufactured in China, imported into China or otherwise sold in China. Unlike the original China RoHS, it does not provide an exemption for EEE products that are manufactured for export.

Impact on Manufacturers

Companies that manufacture their product in China or sell product into China will likely be impacted to some degree by the new China RoHS 2 regulation. Products that were previously out of scope will need to comply with all of the marking and labeling requirements as of July 1, 2016.

The China RoHS 2 regulation is available from the MIIT website (in Chinese). An English translation of the regulation has been made available by Foley & Lardner LLP: English reference translation of the new China RoHS 2 regulation.

 

EU – Commission Announces Circular Economy Package

The European Commission announced on December 2, 2015 that it is adopting an ambitious new Circular Economy Package. The Commission press release listed the key actions to be carried out under the current Commission’s mandate. Action items that are relevant to the EEE industry include:

  • Funding of over €650 million under Horizon 2020 and €5.5 billion under the structural funds;
  • Development of quality standards for secondary raw materials to increase the confidence of operators in the single market;
  • Measures in the Ecodesign working plan for 2015-2017 to promote reparability, durability and recyclability of products, in addition to energy efficiency;
  • A strategy on plastics in the circular economy, addressing issues of recyclability, biodegradability, the presence of hazardous substances in plastics, and the Sustainable Development Goals target for significantly reducing marine litter;

The broad range of actions making up the Commission’s circular economy package may have significant impact on the EEE industry and manufacturers over the upcoming decade. Impacts may include:

  • Ecodesign implementing measures that include design for reuse and recycling requirements in addition to the traditional energy efficiency requirements.
  • Requirements to make repair information available
  • Emphasis on implementing an environmental management system
  • Increased scrutiny of green claims
  • Product environmental footprint to measure and communicate environmental information
  • Increased Green Public Procurement (GPP)
  • Increased use of recycled plastics and recycled criterial materials
  • Development of quality standards for secondary raw materials
  • Increased exchange of information between manufacturers and recyclers

EU – REACH SVHCs added to Candidate List on December 17, 2015

The European Chemical Agency (ECHA), on December 17, 2015, added five new substances to the REACH SVHC Candidate List. The substances are listed in the table below. The Article 33 communication obligations specified in the REACH regulation (Regulation (EC) No 1907/2006) came into effect as soon as the SVHCs were added to the Candidate List,

SVHCs Added to the REACH Candidate List on December 17, 2015

Substance NameEC numberCAS number
1,3-propanesultone214-317-91120-71-4
2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327)223-383-83864-99-1
2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)253-037-136437-37-3
Nitrobenzene202-716-098-95-3
Perfluorononan-1-oic-acid and its sodium and ammonium salts206-801-3375-95-1, 21049-39-8, 4149-60-4

The substance, Dicyclohexyl phthalate, had been proposed for addition to the Candidate List during this update, but was withdrawn by the dossier submitter (Sweden) and postponed to a later submission date. The substance hexamethylene diacrylate (hexane-1,6-diol diacrylate) had also been proposed for the REACH Candidate List but did not get added. The full Candidate List is available on the ECHA website.

For additional information on developing or assessing an effective REACH SVHC compliance program, contact ECD Compliance.

IEC –Analytical Test Methods Published for PBBs and PBDEs

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.

EU – EcoDesign for enterprise servers and data equipment

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.”