Category Archives: Standards

Reporting REACH SVHCs using the is Article Flag in IPC-1754 Declarations

The EU REACH regulation applies significant requirements on product manufacturers to identify substances of very high concern (SVHCs) listed on the REACH Candidate List that are present in their products. Following a European Court of Justice ruling, the European Chemical Agency (ECHA) published a guidance document clarifying that the threshold level for reporting the SVHC is 0.1% of the first article in a product and not the finished product (as suggested in earlier ECHA guidance documents).  In the REACH regulation, article is defined as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.” According to the ECHA guidance, the first article is when a substance is applied such that an article is first created and not based on a complex object that is made up of individual parts that are themselves articles.

This creates challenges for product manufacturers and requires them to obtain additional information from their supply chain on whether a SVHC is present (above 0.1%) in the first article of which it is a constituent.  For compliance assessment, a key piece of information needed by downstream manufacturers is the mass percent of a SVHC in its first article.

To provide this information in a material declaration, the substance and mass relative to the first article needs to be provided.  The challenge is how to communicate this within a material declaration.

How does IPC-1754 support REACH SVHC assessment

The IPC-1754 declaration standard supports this information requirement by allowing materials and subproducts to be reported in the declaration. The data exchange format also provides an (isArticle) flag for materials, subproducts, and the product so that the supplier can identify any object in the declaration as to whether or not it is an article.  This may be either a material (that meets the defn of article) or a subproduct.

How to determine if the mass percent of a substance is above 0.1% of the article

When a substance is reported in a declaration it includes mass information – this may be either the mass of the substance or a mass percent (the mass of the substance divided by the mass of the material or subproduct (or product) that the substance is assigned to in the declaration hierarchy).  However, the recipient of the declaration may not know enough about the manufacturing of the product (or its parts) to identify the first article. It’s best if the supplier identifies this first article and passes sufficient information down the manufacturing chain for downstream manufacturers to assess compliance requirements.  For the recipient to be able to determine the mass percent of the SVHC in the first article, the supplier needs to include the first article as an object in the declaration (this could be a material, subproduct or the product) and it needs to be identified as an article.

Examples of a single SVHC in the product

Figure 1 illustrates a simple declaration hierarchy of an SVHC (S1) that is included in a material (M1) which is included in part (P1) (which is the first article). Material M1 is identified as not an article (isArticle=False) and subproduct P1 is identified as the first article (isArticle=True) therefore the recipient is able to calculate that the mass percent of S1 in the first article (P1) is 0.2g / 10g = 2% (which is above the 0.1% threshold that triggers the REACH communication requirements). The top-level product is a higher level article (may be referred to as a complex object) and therefore also has isArticle=True.

There are instances where a material may have a specific shape and meets the definition of an article (see second example in Figure 2). In this case, the isArticle flag for material M1 is set to True and the SVHC mass percent in an article is 0.2g / 1.0g = 20%.

Figure 1: Simple example of a declaration with an SVHC in an article (subproduct)

Figure 2: Example with a material that is an article

 

 

 

 

 

 

 

 

 

 

 

In both of these examples, the SVHC content is above 0.1% triggering REACH communication obligations, but there are cases where only a small amount of the SVHC is present and the selection of the first article will impact whether or not the SVHC is present above or below this threshold.  It’s up to the supplier that first incorporates an SVHC into an article to identify this to downstream manufacturers

When there are multiple SVHCs added at different stages of Manufacturing

There may also be products that include more than one SVHC. In some cases, the SVHCs may be applied at different stages during manufacturing, resulting in a complicated declaration hierarchy. One such example is illustrated in Figure 3.

  • The substance S1 (an SVHC) is included in a plating material (M1) which is applied to a lead frame (SP1) which then becomes a plated lead frame (SP2).
    • SP2 is the first article that includes S1, therefore the mass % of S1 in an article is the (mass of S1) / (mass of SP2).
    • If this mass % is above 0.1%, then S1 has REACH obligations.
  • The substance S2 (another SVHC) is a constituent of die attach material that is applied to the die (SP3) and the plated lead frame (SP2) to become the die assembly (SP4).
    • In this case, SP4 is the first article for substance S2 and is used as the basis of the mass % calculation to compare to 0.1%.
  • Overall, in this declaration hierarchy of the IC, subproducts SP4 and SP2 are both first articles for different SVHCs, which creates a complex declaration.

For the recipient of a declaration to properly assess REACH obligations, it’s necessary for the supplier to declare the material or subproduct (or product) that is the first article and identify that it as an article (by using the isArticle flag).

Note: in some cases (for simple products), the product may be the first article (e.g. the product provided by a supplier may be a single piece of molded plastic) or the product may be a mixture (e.g. wet paint) and there is no article.

IPC-1754 Substance Declaration Standard Published

The IPC-1754 standard titled “Materials and Substances Declaration for Aerospace and Defense and Other Industries”[1] was recently published by IPC.  It’s a new standard that establishes requirements for exchanging material and substance data for products between suppliers and their customers for Aerospace and Defense, Heavy Equipment and other industries.

This standard covers the process for exchanging data on substances that may be present in materials in the product and substances that may be used in production, operations, maintenance, repair or overhaul/refurbishment.

IPC-1754 was developed to meet the broad range of requirements of Aerospace, Defense and several other industries that were involved in the development of the standard. The standard includes several innovative features to support compliance assessment against a variety of substance regulations and other uses such as obsolescence management. Features to assess compliance to EU REACH and similar regulations (including the ability to identify articles in the declaration hierarchy) were particularly important.

Some of the new features include:

  • support for declaring chemicals used in manufacturing and maintenance processes (more on this in  future posts);
  • flags to identify articles (as defined in the REACH regulation), homogeneous materials, and to indicate that this is a full substance declaration (FSD/FMD)  and/or includes all materials;
  • support for declaring that some information is “unknown”;
    • The unknown capability was especially added to help suppliers in industries that are new to material and substance declarations to provide information to downstream manufacturers,
  • use descriptors (more information coming in future posts)

IPC-1754 enables an external authority such as an industry association to specify external lists that provide the basis for a declaration by a supplier to a downstream requester. This includes the declarable substance list, a query list, and optionally a use descriptor list established by the declaration Authority. The Query List (QL) provides a set of product statements (also referred to as queries)  — the supplier answers each statement with either a “true”, “false” or “unknown”.  An example of such a statement is that the product contains a substance in the Declarable Substance List (DSL). The supplier than answers true or false depending on whether a DSL substance is included or not.

ECD Compliance was extensively involved in developing IPC-1754. Our principal consultant is a co-chair of the committee.  For information on the IPC-1754 standard, how it can be used by your organization, or other support to use the standard, contact ECD Compliance.

A joint press release on IPC-1754 by IPC and the International Aerospace Environmental Group is available.

[1] Note: This is the approved title for IPC-1754. The title in the published standard is incorrect.  A title that is several revisions out of date was inadvertently inserted during publication.  IPC is aware of the issue.

 

 

IEEE 1680.1 – Revised Ecolabel Standard for Computers and Monitors

The draft for the revised IEEE 1680.1 “Standard for Environmental Assessment of Personal Computer Products, Including Notebook Personal Computers, Desktop Personal Computers, Slate/Tablets, Small Scale Servers, Signage Displays and Personal Computer Monitors” was completed by the Work Group in February 2017 and will be posted for balloting March 28, 2017.

The revised draft expands the scope of the standard to cover tablets and signage displays in addition to computers and monitors.  It also expands the scope of assessment criteria to include corporate social responsibility (CSR) and criteria that reach deep into the supply chain.

Anyone that is interested in voting/commenting on the ballot must register their interest in the IEEE Standards Association (SA) system by no later than Friday, March 24th.

Contact ECD Compliance for support on conformity to the IEEE 1680.X series of environmental assessment standards.

IEC 62474 – Updated to Align with “Article” Interpretation for SVHCs

The IEC 62474 Declarable Substance List (DSL) was updated (D11.00) on March 28, 2016 to reflect the September 2015 European Court of Justice (ECJ) interpretation of the term “article”. The ECJ ruling is important for OEMS and suppliers in determining whether a REACH Candidate List SVHC is above the 0.1 mass% threshold that triggers communication and notification obligations under the EU REACH regulation.

With the ECJ ruling addressed, the new “ReportingLevel” field, which was recently added to the database, was populated.  The ReportingLevel field is intended to simplify for users the interpretation of the more complex reporting thresholds. Some of the reporting thresholds are difficult to interpret because of how they are written in the regulation.

There were a couple of additional minor changes were made to declarable substance groups and reference substances.

A more comprehensive summary is provided in our IEC 62474 blog.

Contact us for additional information on how ECD Compliance can assist your organization in using IEC 62474 for environmental compliance.

 

USA – Conflict Minerals Reporting Template Version 4.01

The cfsi Conflict Minerals Reporting Template (CMRT) for 2015 conflict minerals reporting was revised on June 12, 2015 to version 4.01. This is a minor update compared to version 4.0 which was published in April. Version 4.01 includes an up-to-date smelter list and corrected a couple of errors in Version 4.0. The Version 4.X series for CMRT are intended for conflict minerals reporting through 2015.

The changes from Version 3.X to 4.0 are relatively minor compared to the substantial changes from Version 2.X to 3.0.

Principal Consultant of ECD Compliance named as IEEE 1680.1 WG Chair

On April 18, 2015, the IEEE Computer Society Standards Activity Board appointed Walter Jager, principal consultant of ECD Compliance, as the chair of IEEE P1680.1 working group (WG). P1680.1 is undertaking the update of the IEEE 1680.1-2009 standard on “Standard for Environmental Assessment of Personal Computer Products, Including Notebook Personal Computers, Desktop Personal Computers, and Personal Computer Displays”. The standard is used by the EPEAT registry internationally assisting governments and private sector purchasers in identifying computer products that have a reduced impact on the environment.

Paul Eastman, Sponsor Chair – SAB Special Projects, made the annoucement saying, “I am confident that the Working Group will move forward with speed and confidence under his leadership.

 

U.S. Executive Order — Federal Purchasing and Sustainability Requirements

On March 19, 2015, the U.S. President, Barack Obama, signed Executive Order 13693 for advancing sustainability objectives in the U.S. Federal Government. The Executive Order specifies requirements on Policy, Greenhouse Gas Emission Reductions, Sustainability Goals for Agencies, and Duties of various Federal government offices and officers. The Executive Order is available on the Whitehouse website.

Of specific interest to many EEE manufacturers that sell products to the U.S. government is subsection 3(i) that directs federal purchasing to sustainable products (excerpted below).

3(i) promote sustainable acquisition and procurement by ensuring that each of the following environmental performance and sustainability factors are included to the maximum extent practicable for all applicable procurements in the planning, award, and execution phases of the acquisition by:

(i) meeting statutory mandates that require purchase preference for:

(A) recycled content products designated by EPA;

(B) energy and water efficient products and services, such as ENERGY STAR qualified and Federal Energy Management Program (FEMP)-designated products, identified by EPA and the Department of Energy (DOE); and

(C) BioPreferred and biobased designated products designated by the United States Department of Agriculture;

(ii) purchasing sustainable products and services identified by EPA programs including:

(A) Significant New Alternative Policy (SNAP) chemicals or other alternatives to ozone-depleting substances and high global warming potential hydrofluorocarbons, where feasible, as identified by SNAP;

(B) WaterSense certified products and services (water efficient products);

(C) Safer Choice labeled products (chemically intensive products that contain safer ingredients); and

(D) SmartWay Transport partners and SmartWay products (fuel efficient products and services);

(iii) purchasing environmentally preferable products or services that:

(A) meet or exceed specifications, standards, or labels recommended by EPA that have been determined to assist agencies in meeting their needs and further advance sustainable procurement goals of this order; or

(B) meet environmental performance criteria developed or adopted by voluntary consensus standards bodies consistent with section 12(d) of the National Technology Transfer and Advancement Act of 1995 (Public Law 104-113) and OMB Circular A-119;

(iv) acting, as part of the implementation of planning requirements of section 14 of this order, until an agency achieves at least 95 percent compliance with the BioPreferred and biobased purchasing requirement in paragraph (i) of this subsection, to:

(A) establish an annual target for the number of contracts to be awarded with BioPreferred and biobased criteria and dollar value of BioPreferred and biobased products to be delivered and reported under those contracts in the following fiscal year. To establish this target, agencies shall consider the dollar value of designated BioPreferred and biobased products reported in previous years, the specifications reviewed and revised for inclusion of BioPreferred and biobased products, and the number of applicable product and service contracts to be awarded, including construction, operations and maintenance, food services, vehicle maintenance, and janitorial services; and

(B) ensure contractors submit timely annual reports of their BioPreferred and biobased purchases; and

(v) reducing copier and printing paper use and acquiring uncoated printing and writing paper containing at least 30 percent postconsumer recycled content or higher as designated by future instruction under section 4(e) of this order;

The requirements specified in this subsection replaces the previous Executive Order 13423 of January 24, 2007 which directed federal agencies to purchase IT products that were EPEAT registered.

Federal Acquisition Regulations (FAR) that provide specifications, standards, or labels that meet the requirements will need to be developed. This has the potential to bring many other types of EEE products within scope of sustainability requirements.

ECD Compliance will be tracking the implementation of this Executive Order and will provide updates when new information becomes available.

[1] Executive Order: https://www.whitehouse.gov/the-press-office/2015/03/19/executive-order-planning-federal-sustainability-next-decade

IEC 62474 Declarable Substance List Updated – April 8, 2015

An update to the IEC 62474 declarable substance list (DSL) and data exchange format was published on April 8, 2015. Regulatory changes prompted 5 new and modified substance entries. Nearly 30 other changes were implemented as part of a year-long DSL review to identify substances whos names have changed in regulatory usage and to implement common naming conventions.

Details of the update are provided on the IEC 62474 blog.

CEN/CENELEC – Standardization Roadmap for 2015

The European Standardization Bodies CENELEC and CEN (which are the EU regional counterparts to IEC and ISO respectively) have published their 2015 roadmap of new standardization activities. This roadmap reflects the mandates that the two SDOs (standards development organizations) have received from the European Commission (EC) to develop standards needed for future regulations. It provides manufacturers with insight to emerging regulatory areas for environmental compliance of products sold in the EU.

In the Environment section of the roadmap, standardization requests from EC/EFTA include:

  • M/424 – Water Framework Directive
  • M/478 – Greenhouse gas (GHG) emissions
  • M/503 – Ambient air quality legislation
  • M/513 – Gaseous hydrogen chloride (HCl) emissions
  • M/514 – Volatile organic compounds (VOC) emissions
  • M/518 – Waste Electrical and Electronic Equipment
  • M/526 – Adaptation to Climate Change

Elements of EU Work Programme for 2015 include:

  • 4. Waste recycling
  • 6. Air quality and industrial emissions
  • 4. Climate change and Resource Efficient Europe

Other standardization and activities relevant to the EEE industry and to be developed in 2015 include:

Resource efficiency – CEN and CENELEC will continue discussions with the European Commission with the aim of identifying possible standards that could contribute to the implementation of the Roadmap to a Resource Efficient Europe (COM(2011) 571), which is one of the flagship initiatives under the Europe 2020 Strategy. It is possible that some new standardization activities will be launched in 2015.

Substances of high concern – CEN will complete the development of a standardization roadmap in relation to substances of high concern in articles, based on consultations with industry representatives and other stakeholders. The aim of this exercise is to identify which new standards might be needed to support the implementation of relevant European legislation such as the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation, the Waste Directives, the POP (Persistent Organic Pollutants) Regulation, and the RoHS (Restriction of Hazardous Substances in electrical and electronic equipment) Directive.

Several standards already exist within the EEE industry to address substance of high concern; however, few such standards exist for other products. Therefore, CEN has been asked to look at possible standards across all products (not just EEE). The key risk for the EEE industry is if any of the standards conflict with the existing EEE standards and force the EEE industry to change its procedures for restricted substance control.

 

EnergyStar – Update on Large Network Equipment (LNE) Test Method

For the emerging large network equipment (LNE) Energy Star specification , the U.S. EPA and DOE are requesting stakeholders to provide comments and proposals on two test method issues that were discussed at the January 30th, 2015 meeting: the use of the snaked traffic topology, and the ambient temperature requirement. Additional information on the issues and the request for proposals is provided in the request letter posted on the Energy Star LNE website.

The U.S. EPA will also be hosting a series of working group sessions to discuss outstanding issues related to developing an LNE specification.

On January 30th, 2015, the U.S. Environment Protection agency (EPA) and the U.S. Department of Energy (DOE) hosted a meeting to discuss the ENERGY STAR® Large Network Equipment (LNE) program. In acknowledgement of the complexity of LNE products, during that call, EPA proposed hosting a series of phone – based working sessions over the coming months to discuss key outstanding issues. With this letter, EPA is outlining the topics and timing for those conference calls. EPA welcomes stakeholder feedback on additional topics for discussing during the working calls.