China RoHS Compliance
- China RoHS Compliance Requirements and Responsibilities
- Marking and Labelling Requirements
- Environmentally Friendly Use Period (EFUP)
- Materials Declaration
- China RoHS Packaging Compliance
- Certification
Conflict Minerals
ECD compliance can assist your organization with training and services for your conflict minerals supply chain assessment and disclosure requirements.
A provision for conflict minerals (tantalum, tin, gold, and tungsten) disclosure was included as section 1502 of the U.S. Dodd-Frank Act in 2010 and final rules were approved by the U.S. Securities and Exchange Commission (SEC) on August 22, 2012.
The disclosure rules are intended to provide public scrutiny to the chain of custody of 3TG metals (tantalum, tin, gold, and tungsten) used by manufacturers. In particular, organizations that are required to report under the SEC rules, must perform a "country of origin" inquiry on their use of such metals and report on whether the source of the metals are from mines that are funding conflict in the Democratic Republic of Congo. The first disclosure reports must be filed by May 31, 2014 (for the 2013 calendar year).
Organizations that do not have SEC reporting requirements may still be called upon by their customers (who may have SEC reporting obligations) to report their conflict mineral status.
The UN and the OECD have had special task groups assessing this situation for several years. In fact, the OECnt titleD produced a guidance documed "OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" that highlights the need to control the supply chain through the smelters, which act as a pinch point for the industry. The GeSI and EICC industry associations have developed tools and smelter audit programs to assist manufacturers, but there have been numerous challenges in implementing these programs.
For training and assistance with your conflict minerals program, contact ECD Compliance.
REACH Compliance
ECD Compliance can help your organization implement a compliance system for REACH SVHCs based on engineering assessment, chemical knowledge, and supply chain information.
REACH Regulation (EC) No 1907/2006) is a European chemicals regulation that applies to nearly all products that are manufactured or imported into the European Union. It is a complex regulation consolidating over 40 previous legislations, while adding various new requirements. Organizations that manufacture or import products containing an SVHC have compliance obligations.
The first SVHC candidate list was officially published on October 28, 2008 with 15 substances. As of June 2014, the SVHC candidate list has grown to 155 entries with additional substances added twice a year. When new SVHC are added, there are immediate communication requirements for manufacturers and importers
REACH SVHC Communication Obligations
REACH Article 33 "Duty to communicate information on substances in articles" has been the key obligation driving manufacturers, importers, and distributers to determine whether SVHC exist in their products. If a candidate list SVHC is in the article at greater than 0.1% weight over weight, the manufacturer or importer has communication obligations to recipients.
Reporting obligations require, at a minimum, identification of the chemical and information on safe use. For organizations that are not in the EU, but whose products may end up in the EU, their customers will need the information for downstream reporting.
EPEAT™ Environmental Registry
The EPEAT™ registry enables product manufacturers to identify their environmentally preferable products to customers.
Many government departments and a growing number of large corporations will purchase only those IT products that are on the EPEAT™ registry. EPEAT™ provides a simple method for procurement organizations to specify an overall environmental performance level (bronze, silver, gold). This allows them to cover a broad range of corporate and product environmental criteria with a single specification in their RFQs.
The EPEAT™ registry includes PCs, laptops, monitors, printers, scanners, and televisions and is expanding to include servers and mobile phones. The EPEAT™ ratings are based on environmental performance criteria that consider materials selection, design for end of life, energy use, product longevity, corporate performance, packaging, consumables and air quality (for applicable products) .
Conformity to the EPEAT™ requirements is complex including many subtleties in the wording of criteria requirements and clarifications that need to be taken into account. ECD Compliance (ECD Technology Ltd.) can assist manufacturers in understanding these subtleties and helping to develop solutions if needed. Integrity of the EPEAT™ registry is maintained through periodic verification of products on the registry. Non-conformances are made public so it's important for manufacturers to know that their solutions meet the requirements for all criteria being claimed.
Technical support from ECD Compliance (ECD Technology Ltd.) can help reduce time to conform with the EPEAT™ requirements and to increase conformity assurance.
ECD Compliance staff are experienced in working with manufacturers to:
- Understand the subtleties in the criteria and consult on potential solutions;
- Assess product conformity to ensure that it meets the EPEAT™ desk review requirements and/or identify any gaps that need to be addressed before a product is put on the registry;
- Ensure that the necessary verification requirements are available; and
- Perform EPEAT™ verifications.
We have a EPEAT™ certified qualified verifier (QV) for all product types on the registry.
Contact ECD Compliance (ECD Technology Ltd.) for EPEAT™ conformity and verifications.
Environmental regulations (requirements, updates, and Q&A support)
How regulatory requirements impact your products and markets
We provide your organization with clear information on requirements of worldwide environmental regulations and standards and how these requirements impact your products and operations. ECD Compliance conducts onsite and web-based seminars and workshops to assist you in ensuring that your products meet regulatory requirements and market expectations.
Regulations that typically impact Electrical and Electronic Products (EEE) include:
- EU RoHS (RoHS 2) and similar regulations in other jurisdictions such as China RoHS, Korea RoHS, Japan J-MOSS, California RoHS
- EU REACH and similar regulations in other jurisdictions such as K-REACH, China REACH, JAPAN REACH
- Ecodesign directive (ErP and formerly EuP) and similar energy efficiency regulations in other jurisdictions (U.S. and Canada)
- Conflict Minerals (Dodd-Frank Act)
- North American chemical regulations including US TSCA and Canadian CEPA
- California proposition 65.
Updates on global environmental regulations and standards
We provide an update service with regular briefings on emerging regulatory changes and standards and how these changes are applicable to your products and markets. The service provides key information for your business and minimizes time spent searching and sorting. The service includes Q&A support on questions as they arise.