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Conflict Minerals

February 3, 2015 | Written by GreenSoft Technology, Inc.

American Institute of CPAs publishes FAQ on Conflict Minerals reporting

February 03, 2015｜Written by GreenSoft Technology, Inc.

The American Institute of CPAs (AICPA), the world's largest professional accounting association with over 400,000 members in 145 countries, published a new FAQ this week on conflict minerals reporting.

The detailed FAQ comes from AICPA's Financial Reporting Center, and explains the responsibilities and requirements for conflict minerals reporting from an accounting point of view.

As most of our readers know, environmental compliance requirements can seep their way into almost every department in a manufacturer's organization, so seeing the world's largest accounting association take note of conflict minerals legislation comes as no surprise. The FAQ will be a helpful tool for manufacturers whose accounting departments have an interest in ensuring environmental compliance.

The FAQ is divided into five small downloadable PDF documents. The first document is an overview and the next four documents contain the 13 frequently asked questions - divided into a few questions per document.

Click the following links to download each PDF file:

Conflict Minerals Reports Questions & Answers

AICPA FAQ .01-.02 Regarding Conflict Minerals Reports

AICPA FAQ .03-.09 Regarding Conflict Minerals Reports

AICPA FAQ .10-.12 Regarding Conflict Minerals Reports

AICPA FAQ .13 Regarding Conflict Minerals Reports

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China RoHS

February 2, 2015 | Written by GreenSoft Technology, Inc.

Sections of China’s RoHS Legislation Updated or On-Hold For Revisions

February 02, 2015｜Written by GreenSoft Technology, Inc.

china-rohsLast month, China's Ministry of Industry and Information Technology issued updates to part of China's RoHS legislation as well as a Stay of Execution for other parts.

The new labeling standard (SJ/T 11364-2014) took effect on January 2, 2015, and expands the product scope from electronic information products (EIPs) to all electric and electronic products (EEPs). The new standard replaces the previous standard (SJ/T 11364-2006). Currently product labeling for EEPs under China RoHS is voluntary, but as China RoHS undergoes continued revisions, EEP labeling may become a requirement.

Meanwhile, another part of the legislation, Electronic Information Products Pollution Control Regulations (SJ/T 11364-2014), is currently being revised by Ministry management. The ministry has issued a hold on the execution of this legislation until revisions are complete.

During revisions to China RoHS, two related legislations - Electrical and Electronic Products Labeling Requirements Restricting the Use of Hazardous Substances (SJ/T 11364-2014) and Electronic Information Products Pollution Control Marking Requirements (SJ/T 11364-2006) remain in effect.

For more information on China's RoHS regulation, visit the Chinese government website.

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Conference

January 28, 2015 | Written by GreenSoft Technology, Inc.

Here we are at DesignCon Santa Clara; come see us!

January 28, 2015｜Written by GreenSoft Technology, Inc.

Day 1 of DesignCon Santa Clara is about to begin, and we're excited to share our compliance solutions with attendees and exhibitors. There are two days of the show left, so come visit us in booth 1149 to learn how we can help with your product compliance as well!

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Canadian Environmental Protection Act

January 13, 2015 | Written by GreenSoft Technology, Inc.

Canada Approves Regulations on Products Containing Mercury

January 13, 2015｜Written by GreenSoft Technology, Inc.

canadaCanada has approved new regulations under the Canadian Environmental Protection Act of 1999 that limit the use of mercury in products.

The Products Containing Mercury Regulations go into effect November 8, 2015. The regulations prohibit the manufacture and import of products containing mercury or any of its compounds.

A long list of exceptions to the new regulations include items already covered under other regulations, and a transition grace period lasting until December 31, 2019 exists for some button cell batteries.

Items containing mercury will need to be labeled as such under the new regulations, and manufacturers and importers will have to report the mercury content in their products to the Minister annually starting in 2016.

GreenData Manager software and GreenSoft's data services teams are prepared to help companies with this new regulation in addition to the regulations that our services and software already cover. Contact your Project Manager or sales@greensofttech.com for more information.

For more information on the regulations, visit the Canadian government's environmental website. For the full text of the new regulation, click here.

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Korea REACH

January 8, 2015 | Written by GreenSoft Technology, Inc.

K-REACH Replaces Korean Toxic Chemicals Control Act in South Korea

January 08, 2015｜Written by GreenSoft Technology, Inc.

k-reachAs of January 1, 2015, the Act on the Registration and Evaluation of Chemicals (AREC) in South Korea, or "K-REACH," is now in effect. Full text of the legislation is available as a PDF download.

The Ministry of Environment (MoE) is responsible for implementing this legislation, which is much like the EU REACH legislation.

The K-REACH legislation establishes that the MoE will identify hazard and risks of chemical substances, and implement measures for safe management of products to protect the public health and environment, as well as provide investigation, research and training to small and medium sized industries related to the regulation.

Under K-REACH, any company or person who manufactures or imports chemical substances regulated by the MoE must report the use of the substances and the volume annually. Business entities have a duty to "reduce the use of hazardous substances or develop substances or technologies to replace the hazardous substances."

The scope of K-REACH applies to all chemical substance usage except those already regulated under a different act, such as pharmaceutical products regulated under the Pharmaceutical Affairs Act or narcotics regulated under the Narcotics Control Act.

To read the full text of the legislation, download the PDF. We will keep you updated on our blog with more news on K-REACH as it comes in, and our compliance data services and software can support your K-REACH compliance needs. Contact your sales rep or Project Manager to learn more.

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White Paper

December 23, 2014 | Written by GreenSoft Technology, Inc.

Detailed White Paper on the New RoHS-2/CE Mark Requirements

December 23, 2014｜Written by GreenSoft Technology, Inc.

We have published a new White Paper reviewing the technical document requirements for EU RoHS-2, which is now necessary to obtain a CE mark.

EU RoHS-2 Technical Documents for CE Mark also offers recommendations about the qualifications of compliance documents to prepare the technical documents for RoHS-2 based on our experience in collecting various RoHS compliance documents from suppliers.

The key to managing the technical documents for RoHS-2 is in the supplier declaration and/or contract agreement. GreenSoft provides different categories and subcategories to help classify the level of strength for each type of declaration.

In GreenSoft's experience, to compile the technical documentation to demonstrate compliance with substance restrictions (RoHS 2) to affix the CE Mark, you would need to have a combination of the supplier declaration such as the CoC document/PoC document, and the material composition declaration data/lab test report.

Access the full white paper from our White Paper Library.

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EU RoHS

December 23, 2014 | Written by GreenSoft Technology, Inc.

European Commission Notifies WTO of 4 New RoHS Substances

December 23, 2014｜Written by GreenSoft Technology, Inc.

The European Commission has notified the World Trade Organization (WTO) of four new substances that are to be added to the Annex II List of Restricted Substances under the RoHS-2 Directive.

The proposed date of adoption for the restrictions is February/March 2015, but electrical and electronic equipment (EEE) manufacturers will have a few more years to prepare, as the transition period will end on July 22, 2019 for all EEE products except medical devices and monitoring and control instruments. The transition period for medical devices and monitoring and control instruments ends July 22, 2021.

The four substances, which are normally used in plastics, are: Bis(2-ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), and Diisobutyl phthalate (DIBP).

Justification for the restriction of each substance is available on the official notification filed with the WTO.

Here at GreenSoft, our software team has incorporated the new rule of EU RoHS-2 proposed substances into our GreenData Manager software already, and our data team will contact suppliers to recollect the compliance data on the new proposed substances once the rule becomes official. If you need help in recollecting the compliance data on the new proposed EU RoHS-2 substances, please contact GreenSoft right away at +1-323-254-5961 or email to services@greensofttech.com.

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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

December 17, 2014 | Written by GreenSoft Technology, Inc.

6 New Substances Added to REACH SVHC Candidate List

December 17, 2014｜Written by GreenSoft Technology, Inc.

EU-REACHToday the European Chemicals Agency (ECHA) addedsix new substances to the REACH Substances of Very High Concern (SVHC) Candidate List, and one existing entry has been updated.

With the inclusion of the substances of the SVHC Candidate List, manufacturers and importers of products containing the substances now have six months from today to notify ECHA if they continue to use the substances.

The six newly added substances are:

  1. Cadmium fluoride
  2. Cadmium sulphate
  3. 2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320)
  4. 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)
  5. 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)
  6. reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (reaction mass of DOTE and MOTE)
And the updated substance is Bis(2-ethylhexyl) phthalate (DEHP).

Companies must notify ECHA by June 17, 2015, if they continued to use any of the substances and and meet both the following conditions:

  1. The substance is present in those articles in quantities totally over one ton per company per year, and
  2. The substance is present in those articles above a concentration of 0.1% weight by weight, unless exemptions apply.
Companies can notify ECHA of their continued use of the substances using ECHA's online form.

More details on the substances and explanations for the inclusion of the substances on the SVHC Candidate list is available here.

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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

December 8, 2014 | Written by GreenSoft Technology, Inc.

Remarks Due By Jan. 9 For EU Consultation of RoHS Exemptions

December 08, 2014｜Written by GreenSoft Technology, Inc.

The European Commission is currently accepting remarks as part of a consultation exercise on two RoHS exemption requests. The deadline for submissions is January 9, 2015.

Registered stakeholders, listed here, are invited to submit their comments by e-mail to rohs.exemptions@oeko.de or by mail to the address listed here.

The exemption requests are:

2014-1: Cadmium Anodes in Hersch cells for high-sensitivity oxygen sensors
2014-2: Lead in solders used to make electrical connections to temperature measurement sensors designed to be used periodically at temperature below -150C.

These requests for exemption from the substance restrictions of Directive 2011/65/EU (RoHS-2) will be evaluated on the basis of the criteria for exemptions in Art. 5 (1) (a) RoHS 2.

For more information on this open stakeholder consultation and prior stakeholder consultations that have since been closed, visit the EU website here.

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Conflict Minerals

December 5, 2014 | Written by GreenSoft Technology, Inc.

Packers quarterback and Enough Project speak on conflict minerals

December 05, 2014｜Written by GreenSoft Technology, Inc.
Football Star Supports Peace in Congo
Green Bay Packers quarterback and superbowl MVP Aaron Rodgers is hosting an event in support of peace for the Congo before his December 8th Monday Night Football game.

Those who successfully bid on the $10 tickets will be able to throw a football and take a photo with Rodgers on the field before the game against the Atlanta Falcons this coming Monday.

Rodgers is the celebrity face of the Enough Project's Raise Hope for Congo Campaign, and proceeds from Monday's event will go to that initiative. Learn more and bid for tickets online. 

Enough Project Responds to Criticism of Dodd-Frank Act
Meanwhile, two representatives from the Enough Project have written a piece in defense of the Dodd-Frank Act after an article in the Washington Post criticized the legislation.

9 Things You Need To Know About Conflict Minerals was published on thinkprogress.org today, and provides a detailed overview of the conflict situation in the Congo region and the influence of the Dodd-Frank Act legislation.

Ultimately, the authors argue that while the Dodd-Frank Act is not an all-encompassing solution to the conflict, it is the only legislation that requires companies to have a transparent supply chain through mandatory disclosure and this is essential for accountability.

The Enough Project's Policy Analyst, Holly Draginis, and Associate Director of Policy for Congo, Great Lakes Region, and LRA, Sasha Lezhnev, wrote the article after the Enough Project's U.S. and Congo-based teams visited mining communities in eastern Congo last month to get an updated assessment of the conflict situation.

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EU REACH

December 3, 2014 | Written by GreenSoft Technology, Inc.

Notification to ECHA Required for Continued Use of Candidate Substances

December 03, 2014｜Written by GreenSoft Technology, Inc.

ECHADecember 16 marks the deadline for manufacturers and importers to notify the European Chemicals Agency (ECHA) if they continue to use substances that were added to the REACH Substances of Very High Concern (SVHC) Candidate List six months ago.

As part of the REACH regulation, manufacturers and importers have to notify ECHA if both of the following conditions are met regarding a Candidate substance present in their articles:

A) The substance is present above a concentration of 0.1% weight by weight, and
B) The substance is present in quantities totaling over one ton per year.

The two exemptions in which notification to ECHA is not required are:

A) The producer or importer can exclude the exposure of humans and the environment to the substance during normal or reasonably foreseeable conditions of use of the article, including its disposal.
B) The substance has already been registered by a manufacturer or importer in the EU for that use.

Companies have six months after the inclusion of the substance on the Candidate List to notify ECHA. On June 16, four substances were added to the Candidate List:

1) Cadmium chloride
2) Sodium peroxometaborate
3) Sodium perborate; perboric acid, sodium salt
4) 1,2-Benzenedicarboxylic acid, dihexyl ester, branched and linear

The ECHA website provides a webform for companies to submit their notifications online. Companies will first need to register and activate a REACH-IT account before they can submit their notifications.

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EU REACH

November 25, 2014 | Written by GreenSoft Technology, Inc.

EU Court Dismisses Appeals on SVHC Status of Certain Substances

November 25, 2014｜Written by GreenSoft Technology, Inc.

For several years, three cases brought on by manufacturers appealing the SVHC status of certain substances have been ongoing, and this month the European General Court dismissed all three appeals and ordered the manufacturers to pay the costs.

The Cases
All three cases were filed on September 4, 2014. The first, case C-288/13 P, was filed by Rütgers Germany GmbG, Rütgers Belgium NV, Deza a.s., Industrial Química del Nalón SA, and Bibaína de Alquitranes SA. against the European Chemicals Agency (ECHA) appealing the inclusion of anthracene oil as a Substance of Very High Concern (SVHC) under REACH Article 59 and Annex XIII.

Case C-289/13 P was filed by Cindu Chemicals BV, Deza a.s., Koppers Denmark A/S, and Koppers UK Ltd against the ECHA and European Commission appealing the inclusion of anthracene oil, anthracene low as a SVHC.

And case C-290/13 P was filed by Rütgers Germany GmbG, Rütgers Belgium NV, Deza a.s., Koppers Denmark A/S, and Kippers UK Lt against the ECHA appealing the inclusion of anthracene oil (anthracene past) as a SVHC.

The Outcome
On November 17, all three appeals were dismissed and the companies that brought on the lawsuits were ordered to pay the costs. The full text of the decisions is available onlinehere.

This isn't the first time the EU courts have dismissed appeals to the SVHC list. In March 2013 and August 2014, the court made similar decisions to back the ECHA's SVHC list against appeals.

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