Market Access

March 9, 2020 | Written by GreenSoft Technology, Inc.

Equipment Removed from EU Market

Product Failing to Meet Compliance Standards

eu-rohs

Last month an EU Member State enforcement action caused the removal of an electronic product from the European market for failure to comply with the EU RoHS Directive and the EU Persistent Organic Pollutants (POPs) Regulation.

A digital multimeter from the brand HoldPeak, model HP-37C, was found in violation of EU RoHS and EU POPs due to the plastic material of the cables containing an excess amount of short-chain chlorinated paraffins (SCCPs) and lead (measured values up to: 0.87 % and 0.26 % by weight, respectively).

As a result of the violation, the manufacturer was forced to withdraw the product from the market and warn consumers of the risks.

A notice of the enforcement action can be found here.

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 is required for affected companies that manufacture or distribute products in the European market. As demonstrated by the three enforcement actions above, failure to comply with EU RoHS or EU POPs can result in 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

EU REACH

March 6, 2020 | Written by GreenSoft Technology, Inc.

Updates to EU Reach SVHC Candidate List

Updates to EU Reach SVHC Candidate List

EU-REACHFive substances have been proposed to be added to the EU REACH Substances of Very High Concern (SVHC) Candidate List.

The substances will be considered by the European Chemicals Agency (ECHA) during the consultation period, and interested parties may submit comments on the proposed substances during this time. The deadline to submit comments is April 17.

ECHA is expected to announce the final decision about the inclusion of these substances in June, and the inclusion of the substances on the SVHC Candidate List will take immediate effect at that time.

The five substances proposed for inclusion are:

Name EC Number CAS Number Reason for Proposing Details
1-vinylimidazole 214-012-0 1072-63-5 Toxic for reproduction (Article 57c) Link
2-methylimidazole 211-765-7 693-98-1 Toxic for reproduction (Article 57c) Link
Butyl 4-hydroxybenzoate 202-318-7 94-26-8 Endocrine disrupting properties (Article 57(f) – human health) Link
Dibutylbis(pentane-2,4-dionato-O,O')tin 245-152-0 22673-19-4 Toxic for reproduction (Article 57c) Link
Resorcinol 203-585-2 108-46-3 Endocrine disrupting properties (Article 57(f) – human health) Link

ECHA’s announcement of these proposed additions can be found online. The last prior addition to the EU REACH SVHC list was in January.

EU REACH SCIP Database will require additional information on SVHCs from manufacturers

These proposed substance additions come while ECHA is in the midst of testing out the new EU REACH SCIP Database portal, which manufacturers will need to use to submit SVHC information starting next January.

Beginning January 5, 2021, producers and importers of articles in the EU will be required to provide detailed information on the presence of SVHCs higher than 0.1% weight-by-weight within their products, including:

  • Information that allows the article to be identified
  • The name, concentration range, and location of the SVHC in the article
  • Information on the safe use of the article, including during disposal
  • Material Category of the material containing the SVHC

Learn more about the SCIP Database portal here.

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 EU REACH 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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Virtual Conference

February 26, 2020 | Written by GreenSoft Technology, Inc.

Update: Chemical Watch conference has been postponed, but you can still view the presentation online

Update 16 March 2020: As a result of the evolving Covid-19 situation and the public health guidelines provided by the Netherlands authorities, the Chemical Watch organization has made the decision to postpone the Chemicals Management for Electronics Europe and Global Business Summit Europe conferences, scheduled to take place in Amsterdam on 23-24 and 25-26 March respectively. These events will now take place in autumn 2020.  

While we wait for more information and a new event date to be announced, you can view a recording of Randy presenting a seminar at a Chemical Watch conference in 2019 online in our Webinar Archive.


February 26, 2020|Written by GreenSoft Technology, Inc.

Next Month GreenSoft Tech will present on EU Reach and Environmental Compliance Data Services

GreenSoft Technology is heading to Amsterdam next month to attend the Chemicals Management for Electronics Europe Conference.

This two-day conference from Chemical Watch offers the latest information and advice on chemical management and restrictions in electronics.

We will be there exhibiting our GreenData Manager software and Data Services for environmental regulations such as EU REACH, including the new EU REACH SCIP database requirements. 

GreenSoft’s Senior Product Support Manager and technical lead, Randy Flinders, will be presenting a seminar session on EU REACH article analysis for electronic components.

Randy will provide information on the definition of an article under EU REACH and provide an example article analysis. Learn as Randy breaks down an example IC and calculates based on Full Material Declaration (FMD) data to find out if there is a reportable Substance of Very High Concern (SVHC) present in the article.

You can view a recording of Randy presenting a similar seminar at the last Chemical Watch conference online in our Webinar Archive.

We are offering a special 15% discount on tickets to the conference. Contact us to receive your 15% off discount code!

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SCIP Database

February 24, 2020 | Written by GreenSoft Technology, Inc.

ECHA has released an EU REACH database prototype

ECHA has released a SCIP database prototype for users to test

scip

The European Chemicals Agency (ECHA) has released a prototype of the EU REACH SCIP database portal for companies to become familiar with ahead of the January 2021 effective date.

Companies placing articles on the EU market which contain reportable levels of Substances of Very High Concern (SVHCs) will need to submit their product information into the SCIP database starting January 5, 2021.

The release of the portal prototype provides manufacturers and solution providers with the remainder of this year to develop a solution and gather the required product information.

Users can use the prototype portal to submit test data and provide feedback to ECHA to improve the final version, which will be launched later this year. The prototype database is for testing purposes only, and all data loaded into the database will be deleted when the final database goes live in fall 2020.

You can access the SCIP database prototype portal here.

Additionally, Chemical Watch is hosting a webinar about the SCIP database portal on March 5. Speakers from ECHA will share suggested steps on how to utilize the database. More information and registration for that webinar can be found here.

SCIP database expands data requirements for manufacturers

Manufacturers will be required to submit significantly more information to the SCIP database than the current SVHC communication obligations under Article 33 of EU REACH.

Suppliers of articles will need to submit the following information to the SCIP database:

  • Information that allows the article to be identified
  • The name, concentration range, and location of the SVHC in the article
  • Information on the safe use of the article, including during disposal
  • Material Category of the material containing the SVHC

The detailed information requirements for the SCIP database (published September 9, 2019) can be accessed here.

GreenSoft can help with your SCIP database requirements

As a leading provider of data services and GreenData Manager software to help manufacturers comply with regulations such as EU REACH, GreenSoft has been developing a data services and software solution for the new SCIP database.

At the start of this year, we started working with key customers on a pilot program to develop a SCIP database solution. After the pilot program period, GreenSoft will issue a wide-release of our EU REACH SCIP database solution to new and existing clients.

Contact us to learn more about our EU REACH solution and be alerted when our EU REACH SCIP database solution is available.

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Webinar

February 6, 2020 | Written by GreenSoft Technology, Inc.

New Automated Material Compliance Management Webinar

Discover how a new automated materials compliance management process can help with EU REACH requirements and more.

GDM-w-CDM-webinar

Learn how you can take advantage of an exciting new tool that reduces cost and response times of materials compliance reporting by providing automated tracking of raw materials used to construct components.

You can establish a company level Full Material Declaration (FMD) database, and meet new reporting requirements for the EU REACH SCIP database and the IMDS.

Plus, you can provide your customers with real-time compliance data right from your company website or web portal.

Register now for this free webinar to discover how!

Wednesday, March 11
2:00pm EDT/11:00am PDT

Register now!

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Regulatory Predictions

February 4, 2020 | Written by GreenSoft Technology, Inc.

Environmental Compliance Regulation Predictions for 2020

Randy Flinders shares his environmental compliance regulatory predictions for 2020

reg-predictions

EDACafe recently reached out to GreenSoft’s Technical Lead, Randy Flinders, to gain some insight into Randy’s thoughts on challenges facing producers of electronic products and components in 2020. 

Randy’s EDACafe editorial is a call to action for companies who may not be prepared for the explosion in product environmental reporting obligations he is predicting companies will begin to face in 2020.

“……the expansion of RoHS requirements globally, the establishment of the far-reaching SCIP database, and the ever-expanding sea of California bounty-hunter law firms looking for Prop 65 violations are all coming together into the perfect storm……”

When asked to comment on his predictions, Randy was quick to note the editorial only scratches the surface of this trend. “The EDACafe editorial mentions only some of the key requirements which are either expected to emerge or expand in 2020. For example, the current efforts in the automotive industry to improve the accuracy and quality of substance data loaded into the IMDS database will impact electronic component and assembly suppliers. These companies cannot afford to be left behind as the industry expands its data reporting requirements. Like it or not, they will be forced to react.”

Read the full editorial with Randy’s complete insight and predictions here.

Plus, be sure to register to attend the upcoming “Materials Compliance Reporting for Electronic Components in 2020 and Beyond” hosted by Randy. Or view a recording of one of the many educational webinars that Randy has hosted in our Webinar Archive.

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EU REACH

January 21, 2020 | Written by GreenSoft Technology, Inc.

4 New Substances Added to EU REACH SVHC List

The EU REACH SVHC Candidate List now Has 205 Substances

EU-REACH

The European Chemicals Agency (ECHA) has announced the addition of 4 substances to the EU REACH Substances of Very High Concern (SVHC) Candidate List. The SVHC Candidate List now contains 205 substances.

The substances added to the SVHC Candidate List effective January 16, 2020 are shown in the table below:

Substance CAS # Known Applications
Diisohexyl phthalate 71850-09-4 Used as a plasticizer in certain plastic and rubber compounds
2-benzyl-2-dimethylamino-4'- morpholinobutyrophenone 119313-12-1 May be found in coating products, inks and toners, polymers. (Not likely found in EEE)
2-methyl-1-(4- methylthiophenyl)-2- morpholinopropan-1-one 71868-10-5 Used as a photo-initiator for the curing of inks, paints, and resins. (Not likey found in EEE)
Perfluorobutane sulfonic acid (PFBS) and its salts - May be found in protective coatings, anti-static materials, and polycarbonates (as a flame retardant)

Companies may have legal obligations resulting from the inclusion of any substance in the SVHC Candidate List.   Any supplier of articles containing an SVHC above a concentration of 0.1 % (weight by weight) has communication obligations towards customers down the supply chain and consumers, as well as potential official notification requirements.

Additionally, as of January 5, 2021, producers and importers of articles in the EU will be required to provide detailed information on the presence of SVHCs within their products, including these new substances, to a new “SCIP” database currently being developed as part of the EU’s recast of the Waste Framework Directive.

For more information on the addition of these substances, download ECHA’s news release online. The full list of 205 SVHC Candidate List substances can be viewed here. The last prior addition to the REACH SVHC Candidate List was in July 2019.

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 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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California Proposition 65

January 17, 2020 | Written by GreenSoft Technology, Inc.

2 New Chemicals Added to CA Proposition 65 Substances List

Cannabis (Marijuana) smoke and Tetrahydrocannabinol (THC) have been added to the CA Proposition 65

prop-65

Two substances were added to the list of chemicals known to the state of California to cause reproductive toxicity under the Safe Drinking Water and Toxic Enforcement Act of 1986 (CA Proposition 65).

The Office of Environmental Health Hazard Assessment (OEHHA) added the following chemicals effective January 3, 2020:

- Cannabis (marijuana) smoke

-  Δ9-tetrahydrocannabinol (Δ9-THC)

Companies affected by California Proposition 65 are required to warn customers of potential exposure to any of the substances on the list of chemicals.

The two new substance additions will have no effect on electronics manufacturers, but GreenSoft monitors all updates to California Proposition 65 and will continue to alert you when chemicals are added to the list of regulated substances.

The last prior addition to the regulated substances list was September 2019.

GreenSoft helps companies deal with California Proposition 65 through our data services and GreenData Manager software. Contact us to learn more about how we can help your company comply with California Proposition 65.

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EU RoHS

January 16, 2020 | Written by GreenSoft Technology, Inc.

Products removed from the EU Market for failure to meet RoHS Compliance

Products failing to meet RoHS compliance standards have been removed from the EU Market

eu-rohs

There have been three enforcement actions by the European Commission in recent weeks to remove products from the European market for failure to comply with the EU RoHS Directive.

  • A wireless lamp sold by the brand ByON has been withdrawn from the market after lab tests showed that a solder in the lamp contains 30% percent by weight lead, which means the product does not comply with the requirements of the EU RoHS Directive. (Alert No. A12/1836/19)
  • A wireless headset manufactured in China by an unidentified brand was found to contain an excessive amount of lead (measured value up to 36.25% by weight) in the metal solder, and the black cord and artificial leather contained short chain chlorinated paraffins (SCCPs) (measured value up to 3.55% by weight). The headset has been withdrawn from the market for failure to comply with the EU RoHS Directive and with the EU Regulation on Persistent Organic Pollutants (EU POPs). (Alert No. A12/1726/19)
  • A charger cable for mobile devises manufactured in China was found to contain an excessive amount of lead (measured value up to 33 % by weight) in its plastic cable housing. The importer was forced to (1) destroy all product in stock, (2) recall the product from the end users, and (3) withdraw the product from the European market. (Alert No. A12/1695/19)

Compliance with the EU RoHS Directive is a requirement for affected companies to manufacture or distribute products in the European market. The EU RoHS Directive sets thresholds for what percent of a harmful substance can be contained in a product or component. As demonstrated by the three enforcement actions above, failure to comply with the EU RoHS Directive 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 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. For parts that are above the regulation threshold, we can help in the sourcing of replacement parts.

Learn more about our EU RoHS 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

SCIP Database

January 2, 2020 | Written by GreenSoft Technology, Inc.

GreenSoft Announces Pilot Program for EU REACH SCIP Database

A Pilot Program to Develop a Solution for EU Reach SCIP

scip

GreenSoft Technology has started working with key customers on a pilot program to develop a solution for manufacturers in anticipation of the upcoming EU REACH Substances of Very High Concern (SVHC) database known as SCIP.

In September 2019, the European Chemicals Agency (ECHA) released data requirements for the Substances of Concern in articles, as such or in complex objects/Products (SCIP)” database.

Companies placing articles on the EU market which contain reportable levels of SVHCs will need to submit their product information into the SCIP database starting January 5, 2021.

The SCIP portal website is expected to be available for testing by stakeholders in January 2020, giving manufacturers and solution providers one year to develop a solution and gather the required product information.

SCIP database expands data requirements for manufacturers

Manufacturers will be required to submit significantly more information to the SCIP database than the current SVHC communication obligations under Article 33 of EU REACH. As a leading provider of data services and software to help manufacturers comply with regulations such as EU REACH, GreenSoft has been developing a data services and software solution for the new SCIP database.

Larry Yen, President of GreenSoft, has issued the following statement regarding the EU REACH SCIP database:

“GreenSoft is aware of the burden that the new SCIP database requirement is placing on our customers. Due to our position in the supply chain between component/material suppliers and product producers, we are uniquely positioned to provide a comprehensive SCIP solution. We are pleased to be working directly with key industry-leading GreenSoft customers on a pilot program for the development and testing of GreenSoft’s SCIP compliance solution.”

After the pilot program period, GreenSoft will issue a wide-release of our EU REACH SCIP database solution to new and existing clients. Submit your email below to be alerted when our EU REACH SCIP database solution is available.

Or contact us to learn more about our EU REACH data services and GreenData manager software.

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Component Disclosure Module

December 11, 2019 | Written by GreenSoft Technology, Inc.

New GreenData Compliance Management Software!

Greensoft Technology Introduces the Component Disclosure Module

We have an exciting new video announcing the launch of our new GreenData Manager Component Disclosure Module software. 

Watch the video above to learn how GreenData Manager Component Disclosure Module software can reduce your manual burden of providing updated compliance declarations to customers every time a regulation is updated or materials change. 

The Current Challenge for Component Manufacturers

Component manufacturers face a unique challenge in dealing with the substance data of materials in order to provide compliance declarations to customers.

As regulations such as EU RoHSEU REACH (including the new EU REACH SVHC SCIP database), California Proposition 65, EU POPs, and others get changed and updated, your compliance team must continuously update and maintain your materials database. And when customers come back with repeat requests for updated compliance declaration reports, the process of providing customers with data can seem unending.

GreenData Manager Component Disclosure Module software can help by enabling you to manage your materials database, and generate Full Material Declaration (FMD) data on your packages or components to provide to customers. Plus, the intelligent change management system allows you to easily address updates and changes.

Watch the video above to learn more, or enter this link into your browser to watch the video on YouTube: https://youtu.be/FoG2Kse0pfM

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EU RoHS

December 5, 2019 | Written by GreenSoft Technology, Inc.

New Updates to the active EU RoHS Exemptions List

Two EU RoHS Exemptions have been updated by ECHA

eu-rohsIn November, the European Chemicals Agency (ECHA) issued two updates to the list of active EU RoHS exemptions.

Under Annexes III and IV of the EU RoHS Directive, producers of electronic equipment may be permitted to apply exemptions to substance restriction thresholds for certain specific uses and applications. However, exemptions have varying expiration dates, and many exemptions that were set to expire have been updated with new expiration dates, so keeping track of the various dates and exemptions is a time-consuming task.

The two newly updated exemptions are:

  • In Annex III to Directive 2011/65/EU, the following entry 43 is added:

Bis(2-ethylhexyl) phthalate in rubber components in engine systems, designed for use in equipment that is not intended solely for consumer use and provided that no plasticised material comes into contact with human mucous membranes or into prolonged contact with human skin and the concentration value of bis(2-ethylhexyl) phthalate does not exceed:

(a) 30 % by weight of the rubber for

(i) gasket coatings;

(ii) solid-rubber gaskets; or

(iii) rubber components included in assemblies of at least three components using electrical, mechanical or hydraulic energy to do work, and attached to the engine.

(b) 10 % by weight of the rubber for rubber-containing components not referred to in point (a).

For the purposes of this entry, “prolonged contact with human skin” means continuous contact of more than 10 minutes duration or intermittent contact over a period of 30 minutes, per day.

Applies to category 11 and expires on 21 July 2024.

Link

  • In Annex III to Directive 2011/65/EU, the following entry 44 is added:

Lead in solder of sensors, actuators, and engine control units of combustion engines within the scope of Regulation (EU) 2016/1628 of the European Parliament and of the Council (*1), installed in equipment used at fixed positions while in operation which is designed for professionals, but also used by non-professional users.

Applies to category 11 and expires on 21 July 2024.

Link

The exemption updates were published in the Official Journal of the European Union on 5 November 2019. The last prior batch of EU RoHS exemption updates was in February 2019.

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 to the public for your convenience and reference.

Our compiled EU RoHS Exemptions List has been updated to include the recent changes by the European Commission. You can download the updated EU RoHS Exemptions List here.

GreenSoft Keeps Track of RoHS-2 Exemptions So You Don’t Have To

Updates and exemptions to regulations occur regularly. With the status and timing of exemption extensions unknown, compliance can be a continually moving target.

Affected companies using parts or materials that utilize expiring exemptions should immediately begin finding replacements and phasing out the use of those parts or materials.

GreenSoft can help with this process, including the sourcing of replacement parts. We can help you collect the substance data on your parts and format the data to meet the due diligence and documentation requirements of RoHS-2 and EN 50581.

Learn more about our RoHS-2 Data Services or contact us today to get started.

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EU RoHS Exemptions Timeline Update

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