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U.S. Toxic Substances Control Act (TSCA)

September 1, 2021 | Written by GreenSoft Technology, Inc.

Products to Watch Out for Ahead of TSCA Deadline

09/07/2021 Update: On September 3, the EPA extended the deadline for PIP 3:1 compliance from September 4, 2021 to March 8, 2022. Read more here.

Original 09/01/2021 blog post follows.

Must Remove TSCA-Restricted Substances by September 4th 2021

tscaThe deadline to remove substances restricted under the Toxic Substances Control Act (TSCA) from your products is September 4, 2021.

GreenSoft Technology has been evaluating products for TSCA compliance on behalf of our customers since the new rules banning five persistent, bioaccumulative and toxic (PBT) substances were announced by the US Environmental Protection Agency (EPA) in January 2021.

In that time, we have reviewed over 350,000 products, and we have identified multiple products containing one of the restricted substances: Phenol, isopropylated phosphate (3:1) (“PIP (3:1)”).

In addition to the products commonly known to contain PIP 3:1 listed in Figure 1 below, GreenSoft has found PIP 3:1 present in gaskets, fans, coatings, uninterruptible power supply (UPS) systems, and LCD display panels.

PIP-uses-table
Figure 1: Common electronic equipment usage of Isopropylated Phosphate (3:1) (PIP 3:1).

When the restriction of the five PBT substances was announced, GreenSoft performed an Impact Analysis and determined that two of the five substances, PIP 3:1 and DecaBDE, are commonly used in electronic equipment, with PIP 3:1 being the most commonly used.

Our latest evaluation of over 350,000 products confirms that PIP 3:1 has been found to be present in electronic components, including the parts mentioned above, which were not expected to typically contain PIP 3:1.

Manufacturers must remove PIP 3:1, and any other restricted PBT substance, from their products by the September 4 deadline or else face civil and criminal penalties of $37,500 per violation per day. Manufacturer representatives could even face up to 1 year of jail time for intentional violations.

GreenSoft Technology helps with supply chain data collection

As part of our TSCA data services, GreenSoft Technology will contact your supply chain to collect data on the presence of PIP 3:1, PIP 3:1 and DecaBDE, or all five PBT substances in your products.

We contact your suppliers as many times as it takes to obtain complete and accurate data, and provide you with compliance reports and substance analysis for your products which you can use to ensure your products are in compliance with TSCA.

Contact us to learn more.

 

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Webinar

August 27, 2021 | Written by GreenSoft Technology, Inc.

Introduction to UK RoHS Webinar

Register now to save your spot

The UK’s Restriction of Hazardous Substances (RoHS) regulation becomes mandatory in January 2022.

Learn everything you need to know about the UK’s recently amended RoHS Regulations in this free, educational webinar.

Tailored specifically for electronics manufacturers, this webinar will provide detailed information on UK RoHS, including:

•  The UKCA mark – UK’s version of the EU’s CE Mark

•  Implementation deadlines

•  Scope and product categories

•  Restricted substances and thresholds

•  Exemptions – what are the differences between EU RoHS and UK RoHS?

•  Drafting your UKCA Declaration of Conformity

Plus, you’ll get a chance to ask host Randy Flinders, Compliance Specialist for GreenSoft Technology, your questions during a live Q&A session.

Don’t miss out on your chance to learn about this regulation. Register now to save your spot!

Thursday, September 30

Two session times available:

  • 4:00pm CEST/10:00am EDT/7:00am PDT – Register
  • 8:00pm CEST/2:00pm EDT/11:00am PDT – Register

Everyone who registers will receive a copy of the webinar recording.

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SCIP Database

August 10, 2021 | Written by GreenSoft Technology, Inc.

Access Over 30 Frequently Asked Questions on the SCIP Database

scip-faqAccess the SCIP Database FAQs Today!

GreenSoft Technology has published a set of over 30 Frequently Asked Questions with information for manufacturers and suppliers to guide you through the most common issues companies encounter when dealing with the SCIP Database.

As of January 2021, companies placing articles on the EU market which contain reportable levels of Substances of High Concern (SVHCs) under EU REACH will need to submit their product information into the Substances of Concern in Products (SCIP) Database as part of the requirements under the EU Waste Framework Directive (EU WFD).

This process requires significantly more information than EU REACH SVHC communication obligations, and can be challenging for affected companies due to lack of familiarity with SCIP on the part of suppliers.

Additionally, submitting SCIP dossiers to the European Chemicals Agency (ECHA) SCIP online portal contains its own set of challenges. Companies must be familiar with TARIC Codes, SCIP Reference IDs, SCIP Legal Entities, and other portal-related tasks.

GreenSoft Technology has been collecting SCIP data and making SCIP dossier submissions to the online portal on behalf of our customers since the start of these new SCIP requirements. We have compiled the lessons we’ve learned into a helpful Frequently Asked Questions format to help companies prepare and submit to the SCIP Database.

Access the SCIP FAQ online.

Plus, learn about GreenSoft’s SCIP Database Solution here. We can manage your SCIP data collection and dossier submission process for you. Contact us to learn more.

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White Paper

July 20, 2021 | Written by GreenSoft Technology, Inc.

Technical Documentation for Environmental Compliance

Download the Free White Paper on Environmental Compliance Data Services Technical Documentation

WP-technical-docsGreenSoft Technology has published a new White Paper available to download in our White Paper Library.

Technical Documentation for Environmental Compliance reviews the different types of documentation that may be collected to comply with various regulations, including EU RoHS, EU REACH, and California Proposition 65.

When complying with such environmental regulations, it is necessary to collect documentation from suppliers of parts and materials used to manufacture your products. These documents can be used to perform due diligence on your products to ensure they comply with environmental regulations, but only if the documents meet specific requirements. This White Paper will review those requirements and explain what specific information your collected documentation should include.

Visit our White Paper Library to download this valuable resource that can be used to support your environmental compliance projects.

GreenSoft performs data collection from suppliers for you

As part of our Data Services, we can collect documentation on your parts and materials from your suppliers on your behalf. We validate that documentation for completion and accuracy, and we make sure all the required data points are included.

Our Data Services provide coverage for multiple regulations, including EU RoHS, EU REACH, SCIP Database, California Proposition 65, Conflict Minerals, EU Medical Devices Regulation (EU MDR), US Toxic Substances Control Act (TSCA), and many more, including custom requirements.

We guarantee a data quality of 99.9% accuracy, and provide our customers with a 100% project completion rate. All while managing the supplier communication and data validation for you.

Learn more about how our Data Services can help your company by contacting us.

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Webinar

July 13, 2021 | Written by GreenSoft Technology, Inc.

Watch on Demand: Regulatory Updates Webinar

Regulatory Updates Made to US TSCA, MDR, RoHS Exemptions, and California Prop 65.

Regulatory-Update-2021

 

Randy Flinders, Compliance Specialist for GreenSoft Technology, recently hosted a webinar reviewing changes and updates to four environmental regulations affecting electronics producers.

A recording of the webinar is now available to view on-demand in our Webinar Archive.

In the webinar, you’ll learn the latest status of critical regulations facing producers of electronic equipment, including:

Plus, you’ll be able to hear Randy’s answers to questions asked by attendees in the webinar.

And as an added bonus, we’ve made the Q&A and Resources document sent to attendees available for the public to download in our Webinar Archive. This valuable document provides links to regulatory texts and resources which can be used to support your environmental compliance projects.

Check out the webinar recording and download the Q&A and Resources in our Webinar Archive.

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EU REACH

July 9, 2021 | Written by GreenSoft Technology, Inc.

8 Substances Added to EU REACH

EU REACH SVHC List now contains 219 Substances

EU-REACHOn July 8, the European Chemicals Agency (ECHA) announced the addition of 8 new chemicals to the EU REACH Substances of Very High Concern (SVHC) List.

Some of the newly added substances are used in consumer products such as cosmetics, scented articles, rubber and textiles. Others are used as solvents, flame retardants or to manufacture plastics products.

Most of the substances were added to the SVHC List because they are hazardous to human health as they are toxic for reproduction, carcinogenic, respiratory sensitisers or endocrine disruptors.

The 8 new substances are:

Substance Name EC Number CAS Number Reason for Inclusion Examples of Use(s) Link
2-(4-tert-butylbenzyl)propionaldehyde and its individual stereoisomers - - Toxic for reproduction
(Article 57 c)		 Cleaning agents, cosmetics, in scented articles, polishes and wax blends. Link
Orthoboric acid, sodium salt 237-560-2 13840-56-7 Toxic for reproduction
(Article 57 c)		 Not registered under REACH.
May be used as solvent and corrosion inhibitor.		 Link

2,2-bis(bromomethyl)propane1,3-diol (BMP);

2,2-dimethylpropan-1-ol, tribromo derivative/3-bromo-2,2-bis(bromomethyl)-1-propanol (TBNPA);

2,3-dibromo-1-propanol (2,3-DBPA)

 

221-967-7,

253-057-0,

202-480-9

 

3296-90-0,

36483-57-5,

1522-92-5,

96-13-9

 

 Carcinogenic
(Article 57 a)

BMP: manufacture of polymer resins and in one component foam (OCPF) application.

TBNPA: polymer production manufacture of plastics products, including
compounding and conversion and as an intermediate.

DBPA: registered as an intermediate.

 

 Link
Glutaral 203-856-5 111-30-8 Respiratory sensitising properties (Article 57f - human health) Biocides, leather tanning, x-ray film processing, cosmetics. Link
Medium-chain chlorinated paraffins (MCCP)
(UVCB substances consisting of more than or equal to 80% linear chloroalkanes with carbon chain lengths within the range from C14 to C17)		 - -

PBT (Article 57d)

vPvB (Article 57e)

 

 Flame retardants, plasticising additives in plastics, sealants, rubber and textiles. Link
Phenol, alkylation products (mainly in para position) with C12-rich branched alkyl chains from oligomerisation, covering any individual isomers and/ or combinations thereof (PDDP) - - Toxic for reproduction (Article 57c)
Endocrine disrupting properties (Article 57f - human health and environment)		 Preparation of lubricant additive materials and of fuel system cleaners. Link
1,4-dioxane 204-661-8 123-91-1 Carcinogenic
(Article 57a)
Equivalent level of concern having probable serious effects to the environment (Article 57f -environment)
Equivalent level of concern having probable serious effects to human health (Article 57f –human health)		 Solvent Link
4,4'-(1-methylpropylidene)bisphenol 201-025-1 77-40-7 Endocrine disrupting properties (Article 57f - human health and environment) Not registered under REACH.
May be used in manufacture of phenolic and polycarbonate resin.		 Link

ECHA’s announcement of the additions can be found here. The full SVHC list can be found here.

The addition of these substances brings the total EU REACH SVHC List to 219 substances. The last prior addition was SVHC 211 in January.

The inclusion of substances in the EU REACH SVHC List brings immediate obligations for affected companies using the substances in their products above the stated threshold, including customer notifications and notifying ECHA through submissions to the SCIP Database.

GreenSoft can help with EU REACH compliance

The EU REACH SVHC List is typically updated twice per year, resulting in affected companies needing to re-evaluate their product compliance and possibly re-collect substance data from their suppliers.

GreenSoft helps manage this process for companies, including coverage for the SCIP Database, by performing data collection, data validation, substance calculations and report generation as part of our EU REACH data services.

Learn more about how our EU REACH data services can help your company with EU REACH compliance by contacting us.

 

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Five Entries Added to EU REACH SVHC List

EU REACH SVHC List now contains 240 Entries. Environmental compliance is required for companies using such substances. GreenSoft can help with SCIP Database submissions and more.

EU RoHS

May 18, 2022 | Written by GreenSoft Technology, Inc.

New Exemption Added to EU RoHS

New Substance Added To RoHS List Of Exemptions

eu-rohsOn April 20, the European Union announced the addition of a new exemption to the EU RoHS Directive.  

Exemption entry 45 is regarding the use of certain lead and hexavalent chromium compounds in electric and electronic initiators of explosives for civil (professional) use.  

The exemption applies only to Category 11 of the EU RoHS Directive. It takes effect on November 1, 2021 and expires on April 20, 2026.  

The announcement of the exemption by the EU can be accessed here: 

In Annex III to Directive 2011/65/EU, the following entry 45 is added: 

‘45  Lead diazide, lead styphnate, lead dipicramate, orange lead (lead tetroxide), lead dioxide in electric and electronic initiators of explosives for civil (professional) use and barium chromate in long time pyrotechnic delay charges of electric initiators of explosives for civil (professional) use  Applies to category 11 and expires on 20 April 2026’ 

GreenSoft Technology provides resources to understand EU RoHS exemptions 

EU RoHS exemption statuses are regularly changing as new exemptions are added, existing exemptions expire or get renewed, and extension requests are filed. This makes tracking the timing and status of EU RoHS exemptions a difficult task.  

GreenSoft Technology monitors EU RoHS Exemptions and provides an up-to-date compiled list available online. Download the latest list here. (Please note that entry 45 is not included in our current compiled list since the exemption does not take effect until November.)   

We are also hosting a Regulatory Update for Electronics Producers webinar on June 24th which will provide in-depth coverage of the current status of EU RoHS exemptions. Register now to attend.  

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EU RoHS Exemptions Timeline Update

EU RoHS Exemptions Updates: European Commission announces target adoption dates expected in third quarter 2024 for critical EU RoHS exemptions for electronics manufacturers

Webinar

May 10, 2022 | Written by GreenSoft Technology, Inc.

Watch on Demand: SCIP Lessons Learned Webinar

New SCIP Database Webinar Added

scip-webinarRandy Flinders, Compliance Specialist for GreenSoft Technology, recently hosted a webinar on the EU SCIP Database online portal.

It has now been 6 months since the SCIP Database online portal was launched by the European Chemicals Agency (ECHA), and in that time we’ve worked through various struggles with collecting, preparing and submitting data to the portal.

In the webinar, Randy explains the lessons we’ve learned since the launch of the SCIP Database portal, including:

  • How to create an account
  • How to generate an S2S Key
  • Best practices for grouping products into one SCIP notification
  • Complying with “Once-an-Article” requirements when making SCIP notifications
  • Common supplier SCIP data gaps and how to address them
  • What information will be available to the public
  • Common mistakes to avoid

A recording of the webinar is now available to view in our Webinar Archive. Check it out, and be sure to visit our website to learn more about our SCIP Database solution.

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Webinar

April 14, 2021 | Written by GreenSoft Technology, Inc.

Regulatory Update for Electronics Producers Webinar

Get the latest updates on TSCA PBT Restrictions, EU MDR, EU RoHS, and CA Prop 65

Regulatory-Update-2021Learn about changes and updates to environmental regulations affecting electronics producers in this free educational webinar.

Host Randy Flinders, Compliance Specialist for GreenSoft Technology, will provide the latest status of critical regulations facing producers of electronic equipment, including:

  • US Toxic Substances Control Act (TSCA) PBT restrictions (incl. PIP 3:1)
  • EU Medical Devices Regulation (MDR)
  • EU RoHS Exemptions
  • California Proposition 65

Plus, you’ll get a chance to ask your own questions during a live Q&A session.

Don’t miss out on this great opportunity to learn more environmental regulations affecting your products. Register now to save your spot!

Registration

Thursday, June 24

Two session times available:

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Market Access

April 8, 2021 | Written by GreenSoft Technology, Inc.

Two Products Removed from Market Due to EU RoHS & EU POPs Violation

Electric Kitchen Products Violate EU RoHS and EU POPs Regulations

eu-rohsImporters of two electrical kitchen products have been ordered to recall the products from the European market for failure to comply with the EU RoHS Directive and the EU Persistent Organic Pollutants (POPs) Regulation.

On March 30, 2021, economic operators directed importers to cease import of both a DSP brand electrical hot-plate and a Marado brand electric kettle. The action also calls for importers to recall existing product from end users.

According to the EU Safety Gate alert for the DSP brand electrical hot-plate, the plastic material of the product contains short chain chlorinated paraffins (SCCPs) and an excessive amount of bis(2-ethylhexyl) phthalate (DEHP) (measured values up to 0.48 % and 8.04 % by weight, respectively), while the metal solder in the product contains an excessive amount of lead (measured value up to: 0.18 % by weight), thereby putting the product in violation of the EU RoHS Directive and the EU Persistent Organic Pollutants (POPs) Regulation.

The EU Safety Gate alert for the Marado brand electric kettle states that the plastic material of the product contains short chain chlorinated paraffins (SCCPs) and an excessive amount of bis(2-ethylhexyl) phthalate (DEHP) (measured values up to 4.83 % and 2.85 % by weight, respectively), while the metal solder in the product contains an excessive amount of lead (measured value up to: 0.21 % by weight). As such, that product is also in violation of the EU RoHS Directive and the EU Persistent Organic Pollutants (POPs) Regulation.

As a result of the violations, EU importers were ordered to recall the products from end users and stop further sales of the products.

The EU Safety Gate alerts can be found online: electrical hot-plate, electric kettle.

GreenSoft’s data services can help prevent loss of market access for regulation violations

Compliance with the EU RoHS Directive and the EU POPs Regulation are requirements for affected companies that manufacture or distribute products in the European market. As demonstrated by the enforcement action above, failure to comply with EU RoHS or EU POPs can result of loss of market access and other serious consequences for manufacturers and distributors.

GreenSoft provides Data Services to help your company comply with the EU RoHS Directive and the EU POPs Regulation so that you can ensure you retain market access to the European market.

We will collect compliance data on parts and assemblies from your supply chain for you, and generate compliance and completion reports so that you can assess whether your products and parts are in compliance with EU RoHS or EU POPs and other regulations. For parts that are above the regulation thresholds, we can help in the sourcing of replacement parts.

Learn more about our Data Services or contact us today to get started.

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EU RoHS Exemptions Timeline Update

EU RoHS Exemptions Updates: European Commission announces target adoption dates expected in third quarter 2024 for critical EU RoHS exemptions for electronics manufacturers

California Proposition 65

April 5, 2021 | Written by GreenSoft Technology, Inc.

New Partnership Provides Complete California Proposition 65 Solution Offering

GreenSoft Technology has teamed up with RegTox Solutions for CA Prop 65 services

prop-65Compliance with California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) requires affected businesses to have detailed knowledge of the chemicals that their products or business locations contain and expose to the California public.

In order to know which chemicals are exposed to the public, a business must collect substance data on the products that it sells to the public in California or the products that it uses within its California business locations.

And in order to evaluate the exposure level of those substances to determine which warning label requirements are applicable, businesses must conduct an exposure analysis.

GreenSoft Technology has teamed up with RegTox Solutions to provide companies with a complete CA Prop 65 solution for data collection and exposure analysis.

As part of our California Proposition 65 Data Services, GreenSoft Technology will collect substance data from your suppliers on your behalf, and check it against the list of chemicals regulated under CA Prop 65 using our GreenData Manager compliance software.

Then RegTox Solutions will assess any CA Prop 65 flags identified by GreenSoft in order to assess compliance, and/or conduct an exposure assessment to estimate whether the use of substances results in exposure to any chemicals above the limits which trigger warning label requirements.

With GreenSoft Technology and RegTox Solutions’ combined efforts to collect and analyze your substance data for you, you can focus on your core business while resting assured that you are meeting all of your CA Prop 65 legal requirements.

Contact us to learn more.

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California Proposition 65

April 1, 2021 | Written by GreenSoft Technology, Inc.

Two Chemicals Added to California Proposition 65 Substances List

CA Prop 65 Now Includes Molybdenum and Indium Tin Oxide

prop-65California’s Office of Environmental Health Hazard Assessment (OEHHA) has updated the list of substances regulated under the state’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).

Effective March 19, 2021, the following two substances have been added to the list of chemicals known to the State of California to cause cancer:

  • Molybdenum Trioxide (CAS No. 1313-27-5)
  • Indium Tin Oxide (CAS No. 50926-11-9)

Molybdenum trioxide is used to manufacture molybdenum metal, which serves as an additive to steel and corrosion-resistant alloys.

Indium Tin Oxide (ITO) is an optoelectronic material that is widely used across multiple industries, including but not limited the following common applications:

  • Aircraft windshield defrosting films
  • Antireflection coatings
  • Architectural windows
  • Bragg reflectors for VCSEL lasers
  • Electronic ink applications
  • Electrowetting on dielectrics
  • Flat-panel displays
  • Gas sensors
  • Glass doors of supermarket freezers
  • Infrared-reflecting coatings
  • IR reflectors for low-e window panes
  • Liquid crystal displays
  • OLED displays
  • Optical coatings
  • Plasma displays
  • Polymer-based electronics
  • Smart windows
  • Sodium vapor lamp glasses
  • Thin film photovoltaics
  • Thin film strain gauges in gas turbines, jet engines, and rocket engines
  • Touch panels
  • Transparent conductive coatings

OEHHA’s notice about the two substance additions can be found online.

Affected companies are required to inform Californians about exposure to substances on the CA Prop 65 chemicals list, either through their products or at their business locations, before the potential exposure takes place. Penalties for being found in violation of CA Prop 65 can be as high as $2,500 per violation (per exposed person), per day.

GreenSoft Collects Chemical Information for CA Prop 65 Compliance for You

As part of our California Proposition 65 Data Services, we will collect substance data from your suppliers on your behalf, and check it against the list of chemicals regulated under CA Prop 65 using our GreenData Manager compliance software.

This will provide you with the data you need to comply with California Proposition 65 warning label requirements, while freeing up your time to focus on making and selling your products. Contact us to learn more.

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