Manufacturers have new obligations including Conformity Assessment Procedures, Technical Documentation, Register of non-conforming products, and identifying marks.
December 19, 2012: ECHA adds 54 new SVHCs to the EU REACH Candidate List.
Manufacturers have an immediate obligation to be able to provide information on these SVHCs in their products above 0.1 percent of the article weight. The SVHC Candidate List now contains 138 substances. The International validation team for the IEC 62474 Declarable Substance List will begin assessing these substance to determine which substance may occur in electronics.
December 12, 2012: Review of RoHS substances
EU Commission kicks off the consultation to review additional substances for restriction in the EU RoHS Directive. The final report and recommendations are scheduled for publication by November 21, 2013. Several high priority substances have already been identified: The flame retardants Tetrabromobisphenol A (TBBP-A), Hexabromocyclododecane (HBCDD), and the phthalates Bis (2-ehtylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), and Dibutyl phthalate (DBP).
June 18, 2012: 13 substances added to REACH Candidate List of SVHC
The EU has added 13 substances to the SVHC Candidate List bringing the total to 84 substances which impose mandatory communication obligations for manufacturers, importers and distributors. The substances are: TEGDME; EGDME; Diboron trioxide; Formamide; Lead(II) bis(methanesulfonate); TGIC; ?-TGIC; Michler’s ketone; Michler’s base; dimethylammonium chloride (C.I. Basic Blue 26) [with ? 0.1% of Michler’s ketoneor Michler’s base]; dimethylammonium chloride (C.I. Basic Violet 3) [with ? 0.1% of Michler’s ketone or Michler’s base]; 4,4′-bis(dimethylamino)-4”-(methylamino)trityl alcohol [with ? 0.1% of Michler’s ketone or Michler’s base]; and ?,?-Bis[4-(dimethylamino)phenyl]-4 (phenylamino)naphthalene-1-methanol (C.I. Solvent Blue 4) [with ? 0.1% of Michler’s ketone or Michler’s base]
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.
July 1, 2011: Recast of the RoHS Directive (RoHS2)
Recast of the RoHS Directive (RoHS2) is published in the EU Official Journal. The new conformity assessment and technical documentation requirements and revised scope take effect on January 2, 2013. For additional information on the changes introduced by RoHS2 please click here.
June 20, 2011: Canada Consumer Product Safety Act comes into affect.
The Act provides broad obligations on manufacturers, importers and distributors to ensure that products are safe, preparation and maintenance of documents, and mandatory reporting of incidents.
June 20, 2011: ECHA publishes 7 additional substance on SVHC candidate list.
The added substances are: 2-ethoxyethyl acetate, Strontium chromate, DHNUP, Hydrazine, 1-methyl-2-pyrrolidone, 1,2,3-trichloropropane, and DIHP. The candidate list now includes 53 substances.
May 27, 2011: EU Council of Ministers approves RoHS recast (RoHS-2)
The recast of the EU RoHS Directive had been delayed for the past several months due to legal concerns with the interpretation of some of the definitions in the proposal. The European Council of Ministers formally approved the current draft on May 27, 2011 and the European Parliament approved minor changes to the draft that they had approved last November. These approvals allows RoHS-2 to move forward to publication in the Official Journal of the European Union.
May 25-27, 2011: Product carbon footprint (PCF) standards under development
IEC formally began work to develop carbon footprint standards for electrical & electronic products. The standards will specify product category rules enabling manufacturers to calculate carbon footprint of their products based on life cycle assessment (LCA). The need for standards is highlighted by the growing interest by governments and retailers in implementing carbon labeling programs (UK, France, Japan, and Korea to name a few). During the May workgroup meeting, a representative of the EU Commission presented aggressive timeframe for implementation of standards for the electronics industry.