Conformity Magazine - March 2008 - (Page 30)

Included in the enforcement regulation are reporting templates. The Products Subject to Mandatory Recycling Report requires registration of each product, including mass, quantity, and estimated sales volume. Other mandatory reports include the Plan for Implementing Recycling (that requires, among other things, registration of the mandatory recycling rates, mandatory recycling standards, and the specific recycling group to which the product is registered), and the report on Actual Results of recycling, that requires the actual quantities produced and recycled vs. the mandatory recycling rate. Recycling Obligation Operational Plans must be registered with the Korean Environment Ministry within thirty days of a product being placed on the market. These plans may be refused if they are deemed to be deficient. Additionally, annual results on the effectiveness of operational plans (actual results vs. original operational plan) must be submitted. Automotive Restrictions Similar to the European End-of-Life Vehicles (ELV) Directive, automotive manufacturers are prohibited from using hazardous substances in their products. The hazardous substances include lead, mercury, and hexavalent chromium to a maximum concentration of 1000 PPM per homogeneous material, and cadmium to a limit of 100 PPM. The exemptions include such uses as lead in alloys, batteries and electronic solders; mercury in displays; and hexavalent chromium in nutand-bolt assemblies (until June 2008). In this respect, Korea RoHS has similarities to the exemptions of the European Union ELV Directive. The enforcement ordinance lists disassembly requirements and recycling and material treatment standards. For example, parts such as batteries, fuel tanks, and air bags which may be dangerous when shredded must be removed; 85% or more of the auto glass must be recovered, and liquids must be removed. Furthermore, recyclers are required to recover as many parts as possible for the purpose of re-use. Automotive manufacturers or importers must also register and implement recycling plans. The annual limits are set in the legislation and require registration with the OMIS. Similar to electronics, the recycling treatment instructions are required to be made available. The legislation includes requirements for instructions on how to segregate and safely dispose of hazardous substances, ozone-depleting substances, and substances hypothesized to cause “climate change.” Korea RoHS also sets out minimum facility requirements for recyclers. The minimum set of facilities is set out for the different phases of the automobile recycling process - the crusher, crushed byproducts recycler, and waste gas collection. Quarterly recycling performance reports must be registered with the Ministry of Construction and Transport. The reports must include statistics on quantities of vehicles imported or 30 Conformity marCh 2008 produced vs. recycling quotas, as well as quantity of material transferred to and between automobile shredders, shredded waste recyclers and waste gas recyclers. Also, the amount of material recycled and hazardous or ecologically-damaging material captured must be documented. Inspection & Enforcement The Korean government is enforcing Korea RoHS through public inspectors who will be authorized to inspect products and documentation. Fines for failing to comply are set out as follows, according to the infraction (stated in South Korean Won): • Fraudulent Reporting: Fine of 10,000,000 and imprisonment of not more than 1 year. May include corporate officers or the corporation itself • Violation of Restricted Substance Limits: Fine of 30,000,000 • Violation of Technical Guidance on the Improvement of Materials and Structure: Fine of 20,000,000 • Failure to Properly Report: Use of Restricted Substances, Recycling Implementation Plan, Document Collection of Electrical Waste: Fine of 10,000,000 • Failure to Collect Electrical Waste: Fine of 10,000,000 There are also increases to the recycling fee structure in cases where the producer or importer has failed to meet mandatory recycling quotas. This can range as high as a 30% increase in fees applicable to the volume of material exceeding the quota. Summary The unique requirements of Korea RoHS, if they are not properly implemented, have the potential to set serious barriers to the South Korean market. There is a great deal more information to be collected, obligations to be researched and properly adhered to, and documentation to be registered both with the South Korean government’s registry and with recycling companies. Importers and domestic manufacturers who would be affected are well-advised to develop a compliance plan that is specifically designed to meet the Korea RoHS requirements, or risk losing market-access until one is implemented. Bruce Calder is the General Manager, and Ian Smith a Senior Engineer, at Intertek-Ageus. Calder can be reached at bruce.calder@intertek.com, and Smith can be reached at ian.smith@intertek.com. FAST Link www.conformity.com/1540 http://www.conformity.com/1540

Table of Contents Feed for the Digital Edition of Conformity Magazine - March 2008

Conformity Magazine - March 2008 NewsBreaks Editor's Note Adelstein Renominated to the FCC Industry Canada Publishes FAQs On RF Fields FDA Gives Its Scientific Capabilities Poor Marks FDA Offers Guidance On its Product Review Process FDA Publishes Updates to List of Recognized Standards FDA Warns of Patient Risk From Electric Dental Handpieces Complying with the EMC Directive, Second Edition ESD Open Forum Emerging Issues in Standards - Korean "RoHS": Not Like RoHS at All The iNARTE Informer Challenges in Testing - Field-Induced Charged Device Model: What Really Happens Design Fundamentals - EMI Shielding Technologies for Consumer Electronics Equipment Focus On...Compliance Software Buyer's Guide Additional Standards Published for the EU's ATEX Directive Additional Standards for the EU's Medical Devices Directive Also Published China to Require Bar Codes to Enhance Product Safety CPSC Releases 2007 Self-Assessment CPSC Actions in News IEC Standards Update UL Standards Update Product Reviews Telcordia Standards Update From Our "You Can't Make This Stuff Up" Department Looking Back: Items from Past Issues of Conformity Advertisers

Conformity Magazine - March 2008

For optimal viewing of this digital publication, please enable JavaScript and then refresh the page. If you would like to try to load the digital publication without using Flash Player detection, please click here.