Category Archives: Resource

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

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.


HCBD Alternatives Assessment Completed by U.S. EPA DfE Program – June 2014

The U.S. EPA published in June 2014 their final report on “Flame Retardant Alternatives for Hexabromocyclododecane (HBCD). Note: Hexabromocyclododecane is sometimes also abbreviated as HBCDD. The project was executed under the U.S. EPA’s Design for Environment (DfE) program, being launched in 2011 and having been completed this year. The DfE program concluded that the dominant use of HBCD is in expanded and extruded polystyrene foam (EPS and XPS) insulation under current manufacturing processes. HBCD is also used as a flame retardant for High impact polystyrene (HIPS) often in electronic audio/video products. This application accounts for a small percentage of the total HBCD used, but it is still a significant impact for electronic products using this substance.

HBCD is being phased out because of its high concerns in the area of human development, very high aquatic toxicity, high persistence and very high bioaccumulation in the environment. Many countries are in the process of implementing restrictions on the use of HBCD and it is likely to become one of the restricted substances under the RoHS Directive. HBCD is already on the REACH Annex XIV authorization list and therefore also listed as a REACH Candidate List SVHC.

Given the dominant use of HBCD in the building and construction industry, the DfE project focused on these applications. Therefore the results of the study itself are not particularly useful for the electrical and electronics (EEE) industry. Instead, the final report refers EEE manufacturers to the results from the earlier DfE study on “An Alternatives Assessment For The Flame Retardant Decabromodiphenyl Ether (DecaBDE)” — we provide more information on this topic later in the blog posting.

For HBCD in EPS and XPS, the report identifies three alternatives that tend to have lower human health and environment endpoint concerns than HBCD: a butadiene styrene brominated copolymer (CAS 1195978-93-8), a TBBPA-bis brominated ether derivative (CAS 97416-84-7), and TBBPA bis(2,3-dibromopropyl) ether (CAS 21850-44-2). Of these three alternatives, butadiene styrene brominated copolymer (CAS 1195978-93-8) appears to have the lowest human health and environmental impacts; however, the overall impact will also be influenced by the end application.

For the electronics industry, the U.S. EPA points manufacturers to the DfE study on alternatives to Decabromodiphenyl Ether (DecaBDE) because decBDE was commonly used as a flame retardent for HIPS prior to the decaBDE ban in the EU RoHS Directive. Therefore, the alternatives for replacing decaBDE in HIPS may also be applicable to replacing HBCD in HIPS (depending on the specific performance aspects that are required by your application). The alternatives that were considered for HIPS include: Antimony trioxide (as a synergist only); Bis (hexachlorocyclopentadieno) cyclooctane; Brominated Epoxy Polymer(s); Mixture of Brominated Epoxy Polymer(s) and Bromobenzyl Acrylate; Brominated epoxy resin end-capped with tribromophenol; Brominated poly(phenylether); Decabromodiphenyl ethane; Ethylene bis-tetrabromophthalimide; and Tris(tribromophenoxy) triazine.

The DfE report does not specifically recommend any of the alternatives given that each alternative has its own pros and cons. However, the report provides information about a variety of human toxicity and environmental impact endpoints for each alternative to help manufacturers identify and assess potential alternatives for use in their materials. The potential real impact of any of these chemicals also depends on the application and the use of the final product itself. Some of the alternatives have some significant human toxicity or environmental impacts and may not be any better than HBCD. The DfE report for decaBDE is available from the project website.

The DfE alternatives assessment report is available from the project website.

Contact ECD Compliance for additional information

April 10, 2014 – EICC/GeSI release Conflict Minerals Reporting Template Version 3.0

The EICC and GeSI industry associations have released their version 3.0 Conflict Minerals Reporting Template (CMRT).  The new template is intended to align with the new IPC-1755 conflict minerals declaration standard, but is not backward compatible with the previous version 2.03a CMRT which was used by many manufacturers for collecting their 2013 conflict minerals data.   The CMRT template is available through the EICC/GeSI conflict-free sourcing initiative .

RoHS 2 Technical Documentation

The technical documentation for compliance to RoHS 2 is the greatest challenge for manufacturers of products that were already RoHS compliant. We can provide a template for technical documentation and assist you to compile conformity documentation that aligns with the RoHS-2 harmonized standard.

For RoHS 2 compliance, manufacturers must carry out conformity assessment based on internal production control procedures that are in conformance with EU Decision 768/2008/EC and EU Regulation 765/2008/EC. The RoHS 2 Directive Article 7(b) specifies:

b) manufacturers draw up the required technical documentation and carry out the internal production control procedure in line with module A of Annex II to Decision No 768/2008/EC or have it carried out;

Products may not be sold on the EU market unless the manufacturer has drawn up the technical documentation.
The RoHS 2 Technical documentation File (TDF) must meet specific requirements

  • makes it possible to assess the products’ conformity and includes an adequate analysis and assessment of the risk(s).
  • Shall specify the applicable requirements for design and manufacture of the product.

Harmonized and referenced Standards for Technical Documentation

  • EN 50581: Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances
  • IEC/TR62476: Guidance for evaluation of product with respect to substance-use restrictions in electrical and electronic products
  • IEC 62321: Analytical Test Methods
  • IEC 62474: Materials Declaration

EN 50581 specifies that technical documentation shall include at least:

  • a general description of the product (product category and exemptions)
  • documents for materials, parts, and/or sub-assemblies
  • information showing the relationship between the technical documents identified and the corresponding materials, parts and/or sub-assemblies in the product;
  • list of harmonized standards and/or other technical specifications that have been used to establish the technical documents or to which such documents refer.

Restricted Substance Controls (RSC)

Products must be designed and manufactured using restricted substance controls (RSC) that ensure compliance to regulatory and customer requirements. Sources of non-compliance are still being found in many electronic products and within the supply chain. It is cost prohibitive to test every homogeneous material for restricted substances. As such, each organization must find a balance of supplier information, manufacturing and assembly controls, and analytical testing that is effective and cost efficient. Supplier information and manufacturing processes must be assessed for risk of non-compliance or contamination.

An organization’s Restricted Substance Controls should address key elements based on it’s business model, supply chain risk, and operations:

  • Design for Compliance
  • Supply chain compliance risk assessment
  • Procurement and Out-sourcing
  • Manufacturing and Assembly Operations
  • Use of restricted substance under exemption
  • Inventory Management
  • Repair and Return Operations
  • Management Responsibility and Authority
  • Monitoring, Measurement, Analysis, and Improvement

Restricted substance controls should be documented within the Conformity Assurance System.

For support on defining and implementing Restricted Substance Controls, contact ECD Compliance.