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Proposition 65

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

Six Chemicals Added to California Proposition 65 Substances List

prop-65

New Substances Added to California Prop 65 List

In December, California’s Office of Environmental Health Hazard Assessment (OEHHA) added six chemicals to the list of substances regulated under the state’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).

Effective December 17, 2021, the following four substances have been added to the list of chemicals known to the State of California to cause cancer:

  • 2-Ethylhexyl acrylate (CAS No. 103-11-7)
  • Tetrahydrofuran (CAS No. 109-99-9)
  • Methyl acrylate (CAS No. 96-33-3)
  • Trimethylolpropane triacrylate (Technical Grade)

Effective December 24, 2021, the following substance has been added to the list of chemicals known to the State of California to cause cancer:

  • Perfluorooctane Sulfonic Acid (PFOS) and Its Salts and Transformation and Degradation Precursors

And effective December 31, 2021, the following substance has been added to the list of chemicals known to the State of California to cause reproductive toxicity:

  • Perfluorononanoic acid (PFNA) and its salts

The full California Proposition 65 list of regulated substances can be found here.

GreenSoft Technology provides help with CA Prop 65

Compliance with CA Prop 65 requires businesses to have detailed knowledge of the chemicals that their products or business locations contain and expose to the California public.

Affected companies are required to inform Californians about exposure to substances on the CA Prop 65 chemicals list 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 day.

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.

GreenSoft Technology can help with this process. 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.

Contact us to learn more.

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Proposition 65

December 16. 2021 | Written by GreenSoft Technology, Inc.

Modifications to Proposed California Proposition 65 Warning Label Amendment

California Proposition 65 Short-Form Warning Label Proposal Sees Additional Changes

prop-65On December 13, California’s Office of Environmental Health Hazard Assessment (OEHHA) modified its existing proposal to amend the short-form warning label regulations under the state’s Safe Drinking Water and Toxic Enforcement Act of 1986 (California Proposition 65).

The original proposed rulemaking, published on January 8, 2021, would amend the safe harbor warning regulations to improve the short-form warnings to provide consumers more specific information, and to limit the use of the safe harbor short form warning to small products.

Below is an example of the original proposed modifications to the short-form warning label. As seen in the proposed “After” warning label below, companies would be required to list the names of chemicals that Californians are exposed to rather than using the generic warning label seen in the “Before” image.

 

prop-65-label
An example of the CA Prop 65 Clear and Reasonable Warning label before and after the August 2018 amendments.

The initial comment period for those proposed changes closed on March 29, 2021, and OEHHA then began reviewing the 160 written comments it received. After reviewing the comments, OEHHA announced modifications to its proposal on December 13.

The new modifications to the proposed regulation would, among other things:

  • increase the maximum label size for short-form warnings from 5 square inches to 12 square inches;
  • allow use of the short-form warning on the internet or in catalogs where the short form warning is used on the product label;
  • provide additional signal word options;
  • provide additional warning language options;
  • and provide minor clarifications on the wording of the warning.

Details on these proposed changes can be found here.

The proposed changes have initiated a new public comment period which will begin on December 17, 2021 and close on January 14, 2022. Interested parties may submit comments online.

GreenSoft can help with California Proposition 65

In November, GreenSoft Technology and RegTox Solutions held an Ask the Experts webinar on California Proposition 65, in which the proposed short-form warning label modifications were discussed.

View a clip from the webinar discussing the short-form warning label here. Or view the full-length webinar in our Webinar Archive.

GreenSoft Technology provides California Proposition 65 data services to help companies fulfill their California Proposition 65 obligations. Learn more about our California Proposition 65 data services here.

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EU RoHS

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

European Commission amends EU RoHS to add new Annex IV exemptions

3 New Exemptions Added To EU RoHS Annex IV List

eu-rohsOn November 15, the European Commission published an amendment to Annex IV of the EU RoHS Directive, which added 3 new phthalates exemptions.

Annex IV lists exemptions which specifically apply to medical devices and monitoring and control instruments.

The exemptions were entered into force as a matter of urgency and took effect retroactively on July 21, 2021.

The three new added exemption amendments are:

Exemption No. Exemption Description Expiry Date Link
45 Bis(2-ethylhexyl) phthalate (DEHP) in ion-selective electrodes applied in point of care analysis of ionic substances present in human body fluids and/or in dialysate fluids 21 July 2028 Link
46 Bis(2-ethylhexyl) phthalate (DEHP) in plastic components in MRI detector coils. 1 January 2024 Link
47 Bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP) in spare parts recovered from and used for the repair or refurbishment of medical devices, including in vitro diagnostic medical devices, and their accessories, provided that the reuse takes place in auditable closed-loop business-to-business return systems and that each reuse of parts is notified to the customer. 21 July 2028 Link

Updated EU RoHS Exemptions List available to download

GreenSoft maintains a compiled list of the EU RoHS Exemptions in order to perform EU RoHS Data Services for our customers and to keep our GreenData Manager software up-to-date. We also make this list available online to the public for your convenience and reference.

Our compiled EU RoHS Exemptions List has been updated to include these three new exemption amendments. You can download the updated EU RoHS Exemptions List here.

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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

Ozone Depleting Substances

December 7, 2021 | Written by GreenSoft Technology, Inc.

Why You Don’t Hear About the Ozone Layer Anymore

New Released Video Highlights The Success of ODS Regulations

ozone-videoOn November 24, Vox Media published a video about the success of the regulation of Ozone Depleting Substances (ODS).

After scientists discovered a hole in the ozone layer in the 1980s, countries across the world united to adopt the Montreal Protocol in 1987, which to date remains the only UN treaty that has ever been ratified by every country on Earth.

In the years after the production and consumption of ODS were regulated, the hole in the ozone stopped growing and has started shrinking. By 2065, the ozone layer is expected to have recovered completely. Given its unprecedented success, the Montreal Protocol is now considered to be one of the most successful environmental agreements of all time.

Watch Vox’s short educational video on the Montreal Protocol here.

GreenSoft Technology’s data services help companies comply with ODS restrictions

The Montreal Protocol initially controlled Chlorofluorocarbons (CFCs) and other ODS, and was amended in 2007 to include Hydrochlorofluorocarbons (HCFCs). GreenSoft Technology collects data on the presence of these and other chemicals in products and components so that manufacturers can be sure their products are safe and compliant.

As part of our Data Services, we contact your suppliers as many times as it takes to obtain complete and accurate data about the substances in your products, providing you with the data you need to comply with ODS restrictions and other regulations, including RoHS, REACH, SCIP, Conflict Minerals, TSCA, California Proposition 65, EU MDR, and more.

Learn more about our Data Services here.

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Webinar

November 16, 2021 | Written by GreenSoft Technology, Inc.

Watch on Demand: California Proposition 65 Webinar

Access & View New California Prop 65 Webinar Today!

ca-prop-65-webinarOn November 9, GreenSoft Technology and RegTox Solutions hosted an educational webinar on California Proposition 65.

Ask the Experts: California Proposition 65 is now available to view on-demand in our Webinar Archive.

Learn the background of the regulation and how to conduct a compliance analysis on your products. Topics covered in the webinar include:

  • Warning label requirements
  • Details on the impact of proposed short-form warning label changes
  • What data needs to be collected from your supply chain to comply with the requirements?
  • When is review by at toxicologist required?
  • Enforcement and penalties – How to avoid multimillion-dollar CA Prop 65 enforcement action settlements

Plus, hear the answers to attendees’ questions provided by webinar hosts and regulatory experts Randy Flinders, Compliance Specialist for GreenSoft Technology, and Tom Jonaitis, Founder of RegTox Solutions.

Access the webinar recording in our Webinar Archive.

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U.S. Toxic Substances Control Act (TSCA)

November 2, 2021 | Written by GreenSoft Technology, Inc.

EPA Proposes Extension for PIP 3:1 Deadline Under TSCA

Environmental Protection Agency Proposes Extension to PIP 3:1 Compliance Deadline

tscaOn October 21, the  US Environmental Protection Agency (EPA) announced a proposal to extend certain compliance enforcement dates for the PIP 3:1 substance regulated under the Toxic Substances Control Act (TSCA) to October 31, 2024.

The proposal was published to the Federal Register on October 27, which triggered the start of a 60-day comment period in which interested parties can submit comments.

Once the comment period ends on December 27, the EPA will then make a decision on the final rule. Because industry stakeholders have been pressuring the EPA for an extension to the PIP 3:1 deadline, it is unlikely that the EPA will receive any comments against the proposed rule during the comment period. It is therefore likely that the EPA will decide to proceed with the extension.

GreenSoft Technology is following the EPA’s actions on the TSCA substance regulations closely, and will post on our blog when the EPA makes a decision. The EPA’s proposal for further extending the compliance date for PIP 3:1 can be found online.

Current PIP 3:1 deadline was previously extended to March 2022

This is the second action taken by the EPA to extend the PIP 3:1 enforcement date. On September 3, the EPA announced the new enforcement date for the prohibition on the processing and distribution of PIP 3:1 has been extended to March 8, 2022. Previously the enforcement date was September 4, 2021.

Additionally, the EPA also announced its intention to issue a proposal for a new separate rulemaking on all five persistent, bioaccumulative and toxic (PBT) chemicals in the spring of 2023. The future changes aim to “address the hardships inadvertently created by the original applicable compliance dates in the January 2021 final rule to ensure that supply chains are not disrupted for key consumer and commercial goods.”

The EPA’s announcement of the deadline extension and plan for new rulemaking on PBT chemicals can be found online.

GreenSoft Technology helps with supply chain data collection

With the EPA substance rules and dates continuously changing, compliance with the TSCA can be a challenge. If companies have not already started, they should immediately begin collecting substance data on all parts within their products to ensure none of the restricted substances are present.

As part of our TSCA data services, GreenSoft Technology will contact your supply chain to collect data on the presence of PIP 3:1 and/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

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

Watch on Demand: UK RoHS Webinar

GreenSoft Technology Invites You To View the UK RoHS Educational Webinar!

UK-rohs-webinarOn September 30, GreenSoft Technology hosted an educational webinar on the UK RoHS regulations.

Introduction to UK RoHS is now available to view on-demand in our Webinar Archive.

Learn everything you need to know about the UK’s recently amended RoHS Regulations, which take effect in January 2023.

Tailored specifically for electronics manufacturers, this webinar provides 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
  • Requirements for Northern Ireland vs Great Britain – what are the differences?

Plus, we’ve compiled a Q&A and Resources document providing answers to questions asked by attendees during the webinar, as well as useful links to regulatory documentation.

You can access the Q&A and Resources document to download and view the webinar recording in our Webinar Archive.

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Webinar

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

Ask the Experts: California Proposition 65 Webinar

ca-prop-65-webinar

Register for the FREE November 9th California Proposition 65 Webinar!

Regulatory experts from GreenSoft Technology and RegTox Solutions are teaming up to bring you a free, educational webinar on California Proposition 65.  

 

Learn everything you need to know about CA Prop 65, including:  

  • Warning label requirements 
  • Details on the impact of proposed short-form warning label changes 
  • What data needs to be collected from your supply chain to comply with the requirements? 
  • When is review by at toxicologist required? 
  • Enforcement and penalties – How to avoid multimillion-dollar CA Prop 65 enforcement action settlements 

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

Hosts Randy Flinders, Compliance Specialist for GreenSoft Technology, and Tom Jonaitis, Founder of RegTox Solutions, have 45 years of combined experience working in product certification and toxicology.  

Don’t miss out on your chance to hear from the experts. Register now to save your spot! 

 

Registration 

Tuesday, November 9, 2021 

12:00pm Eastern/9:00am Pacific – Register 

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

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Maritime/Shipbuilding

September 24, 2021 | Written by GreenSoft Technology, Inc.

Material Declaration and Supplier Declaration of Conformity Collection

New data service: MD and SDoC collection

IHMGreenSoft Technology now offers Material Declaration (MD) and Supplier Declaration of Conformity (SDoC) collection for companies selling their products to maritime customers.

Per the EU Ship Recycling Regulation (EU SRR), ship owners and operators in the EU with ships of 500 gross tonnage (GT) or over are required to carry an Inventory of Hazardous Materials (IHM) onboard when calling at any EU Member State port or anchorage as of December 31, 2020.

When you sell products to ship owners and operators, they may request MD and SDoC forms from you in order to fulfill their IHM requirements, as well as meet future Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships requirements. GreenSoft Technology can help you generate these forms.

We’ll contact your suppliers as many times as it takes to obtain substance and compliance data, including Full Material Declaration (FMD) data when available. Then we’ll validate the collected data and generate MD and SDoC forms for your products per the International Maritime Organization (IMO) Resolution MEPC 269(68) guidelines.

Plus, with our Data Maintenance Services, we’ll collect and validate substance data for your MD and SDoC forms on a continual basis so that you will always be providing at least 6-month’s fresh data.

Contact us today or visit us online to learn more and get started.

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UK RoHS

September 23, 2021 | Written by GreenSoft Technology, Inc.

UK RoHS Compliance Date Postponed by UKCA Mark Transition Extension

Companies now have until January 2023 to meet the United Kingdom’s UKCA compliance requirements

uk-rohsOn August 24, the deadline for compliance with the UK Conformity Assessed (UKCA) product compliance requirements, including requirements called out in the UK Restriction of Hazardous Substances (RoHS) regulation, was extended to January 1, 2023. Previously the deadline was January 1, 2022.

Affected businesses will now have an additional year to apply the UKCA product safety marking to applicable products placed on the market in England, Scotland and Wales.

Due to this this deadline extension, products bearing the CE mark will continue to be permitted to be placed on the Great Britain market until January 1, 2023. (Northern Ireland remains aligned with EU CE mark requirements.)

Medical devices, however, will not need to display the UKCA mark until July 1, 2023.

The UKCA mark is intended as a replacement for the CE mark, which was used when the United Kingdom was a member of the European Union. The new UKCA mark covers most goods which previously required the CE mark.

Companies can learn more about the UKCA mark labeling requirements affecting their business on the UK government’s website. The deadline extension announcement can be found here.

Learn more about UK RoHS in our free educational webinar

GreenSoft Technology is hosting a webinar on UK RoHS on September 30.  Introduction to UK RoHS will provide detailed information on UK RoHS, including:

  • The UKCA mark requirements
  • 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
  • Requirements for Northern Ireland vs Great Britain – what are the differences?

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

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SCIP Database

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

SCIP Database Portal Now Public

ECHA implements public-facing SCIP database search capabilities

scip

On September 14, the European Chemicals Agency (ECHA) released the SCIP Database to the public.

Consumers and members of the general public may now access data from the over 4 million article notifications within the SCIP Database.

The SCIP Database is the EU’s first public database of Substances of Very High Concern (SVHC) contained in products. Consumers may search the data by article name or brand, product category, type of material or the chemical name.

The goal of the public-facing database is to help consumers make informed choices by enabling them to check whether a product contains hazardous chemicals. Additionally, waste operators can use the data to increase the re-use of articles and further develop recycling processes.

GreenSoft Technology’s SCIP solution protects your proprietary information

With the substance information and safe use details of products from over 6,000 companies now available to the public through ECHA’s SCIP portal, protecting trade secrets is especially important.

Submissions to the SCIP Database online portal require companies to disclose details on articles containing SVHCs within their product, including the location of articles with the product. This can include sensitive structural and design details of the product under notification, resulting in sensitive details being inadvertently disclosed to the public.

GreenSoft’s SCIP Database Solution utilizes generic article naming, eliminating the risk of publicly disclosing component and other supply chain details. GreenSoft’s SCIP Database Solution attaches product structural details to the SCIP dossier as ‘disassembly instructions’ which are not accessible to the public. This allows waste operators to receive this information without disclosing product structures to the public.

Contact GreenSoft Technology to learn more about how our SCIP Database Solution can enable you to fulfill your SCIP notification obligations while protecting your data from the public.

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U.S. Toxic Substances Control Act (TSCA)

September 7, 2021 | Written by GreenSoft Technology, Inc.

TSCA Deadline for PIP 3:1 Extended by EPA

TSCA Deadline for PIP 3:1 Extended to March 2022

tscaOn September 3, the US Environmental Protection Agency (EPA) announced the extension of certain compliance dates for the PIP 3:1 substance regulated under the Toxic Substances Control Act (TSCA).

The effective date for the prohibition on the processing and distribution of PIP 3:1 is now March 8, 2022. Previously the effective date was September 4, 2021.

Additionally, the EPA announced its intention to issue a proposal for a new separate rulemaking on all five persistent, bioaccumulative and toxic (PBT) chemicals in the spring of 2023. However, the current provisions of the January 2021 risk management rules, including the PIP 3:1 deadline extension, remain in effect while the EPA is working on this new rulemaking effort.

The changes aim to “address the hardships inadvertently created by the original applicable compliance dates in the January 2021 final rule to ensure that supply chains are not disrupted for key consumer and commercial goods.”

The EPA’s announcement of the deadline extension and plan for new rulemaking on PBT chemicals can be found online.

GreenSoft Technology helps with supply chain data collection

With the EPA substance rules and dates continuously changing, compliance with the TSCA can be a challenge. If companies have not already started, they should immediately begin collecting substance data on all parts within their products to ensure none of the restricted substances are present.

As part of our TSCA data services, GreenSoft Technology will contact your supply chain to collect data on the presence of PIP 3:1 and/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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