Conformity Magazine - December 2008 - (Page 26)

broke down the product into components or sub-assemblies, and identified the location of the hazardous substances. The resulting determinations and identifications provided very valuable information in the global effort to protect consumer health and the environment. Levels of Compliance These efforts communicated the hazardous substances contained in the products, thereby achieving the first step of self-declaration for the company. Yet, even today, some companies continue to ignore the legislation. They do not evaluate their product’s compliance, do not verify compliance assurance processes, and do not validate suppliers’ compliance. And some companies simply deny that they need to comply with the law. It is almost impossible to identify how many companies and products truly meet the law’s requirements. Yet, even if 50% of companies are declaring hazardous substances used in their products, or substituting those substances with non-hazardous materials, consumers and businesses are twice as well off than they were before. These products are being defined as either containing or not containing hazardous substances. We can therefore select products that are safer or “green,” thereby protecting our health and the environment. The sharing of information has begun. And, the majority of products being shipped into China are also being sold throughout the EU, in the Americas, and throughout the rest of Asia. As a result, more green products are now available globally. Further, other businesses are now aware of the China RoHS legislation and are asking questions. They are determining how much effort is enough for them to mitigate their risks. Whether these businesses comply today or in the future, going green has become a subject of discussion from the board room to distribution centers. But China RoHS is not without some controversy as it has not yet been fully implemented. As of this writing, the Catalogue remains a blank piece of paper. As a refresher, the Catalogue is a list of products that will be required to meet the maximum concentration value of the hazardous substances. This will be enforced by mandatory testing and certification (China RoHS CCC Certification) by the Chinese government. The Catalogue will be created by transferring products or product families from the Electronics Information Product (EIP) list that defines products “in-scope” for China RoHS. Yet, as of today, there have been no product families/ categories transferred from the Electronic Information Products List over to the Catalogue thereby requiring Chinese certification. This is not bad for businesses, as most businesses were concerned over potentially long queues to get their products into the laboratories. There was also the risk of the yet undefined cost of China RoHS certification. 2 Conformity DeCember 2008 But just the creation of the EIP list and promise of future certification requirements has driven compliance with China RoHS. Companies are preparing for the future certification by working with third-party testing laboratories to ensure that their products meet the requirements as defined by China. At the same time, third-party testing laboratories are forming partnerships with various global governmental entities to ensure that they can meet customer’s global compliance requirements with no loss of revenues, limited interruptions to their business, and limited impact to their supply chains. This includes testing, compliance assurance programs, education, and supply chain strategies. The Impact on Other “Green” Initiatives All of these efforts towards going green are complementing the other, ever-expanding global initiatives, including RoHS legislation in the EU and in Korea, the EU’s REACH Directive, California Proposition 65, and Norway’s Prohibition of Hazardous Substances (PoHS), just to name a few. But, while current RoHS legislation has limited its scope to the same four heavy metals and two flame retardants, pending legislation is expanding the focus. For example, the proposed Norway PoHS legislation will prohibit 10 substances from consumer goods including clothing, bags, construction equipment, and toys. The maximum concentration values, for some substances, will be as low as 25 parts per million at the homogeneous material level (similar to RoHS). But, there will be some material and product specific exemptions introduced. At the same time, the EU’s REACH Directive will require disclosure of substances of very high concern (SVHCs) for manufacturers and/or distributors defined on the SVHC Candidate List. The hazardous substances declaration list will thus expand to include carcinogens, mutagens, reproductive toxins, persistent bio-accumulative toxins (PBTs), and very persistent, very bio-accumulative substances (vPvBs). Suppliers will be required to declare these substances to their customers if the substances are over 0.1% in their products. But as soon as the selected substances become banned (as they are likely to be), they will need to know at the materials level if these are present and thus phase out their use. As major economies like China, the EU and California continue to implement their green solutions, other countries and regions are following suit, or expanding their existing legislation. One other area we should address is the concept of exemptions. The EU’s RoHS offered claims of exemptions for products that were not in the eight RoHS categories or which were specifically included in the two “other” categories, medical and monitoring and control equipment. China took the approach of creating the EIP, and products within the

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

Conformity Magazine - December 2008 Contents Editor's Note FCC Warns Regulatory Fee Payers About Potential "Phishing" Commission Prowls the Web to Enforce Its Regulations First DTV Rollout Initiated in Wilmington, NC New Standards List Released for the EU's Directive on the Safety of Toys ESD Association Call for Papers ESDA. JEDEC Announce Standards Development Cooperation Commission Releases Data on Local Telephone Competition The Future of ESD Testing ESD Open Forum Emerging Issues in Standards: China RoHS: One Year and Counting Challenges in Testing: Revisiting 10-Meter and 3-Meter Radiated Emission Measurements Design Fundamentals: Meeting the Shielding Challenges of Injection-Molded Plastics Focus On...Microwave Absorbers Buyer's Guide FDA Recalls Automated External Defibrillators FDA Revises Guidance on Medical Device Tracking Guidance Document Safety of Passive Implants Released FDA Offers Guidance on Marketing Diagnostic Ultrasound Systems EU Commission Issues Correction on Machinery Directive Standards Other CPSC Actions in the News Product Reviews IEC Standards Update UL Standards Update Looking Back: Items from Past Issues of Conformity Advertisers

Conformity Magazine - December 2008

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