Market Access

September 7, 2023 | Written by GreenSoft Technology, Inc.

15 Product Recalls from European Market Due to EU RoHS Violations

eu-rohs-violation-recallsFifteen products forced to be removed from European market due to EU RoHS violations

In the third quarter of 2023, importers of 15 products were ordered to recall their products from the European market for failure to comply with the EU RoHS Directive. Several of the products were also found to be non-compliant with the Persistent Organic Pollutants (POP) Regulation.

The EU RoHS Directive imposes restrictions on the presence of specific substances and prohibits certain chemicals in items sold within the European Union. Products discovered to be non-compliant with EU RoHS must be removed from the European market due to environmental concerns.

The products recalled in the third quarter of 2023 include headphones, antenna power supplies, USB devices, and other consumer electronic devices such as an alarm clock, an eyelash curler, and a remote-control toy.    

The recalls were announced via the following EU Safety Gate alerts:

Electric Neck Fan

Electric-Neck-FanDescription:

The product has an excessive concentration of short chain chlorinated paraffins (SCCPs) (measured value: 3.6 % by weight). SCCPs persist in the environment, are toxic to aquatic organisms at low concentrations and bio-accumulate in wildlife and humans, posing a risk to human health and the environment. Prolonged exposure to them through the skin may cause cancer. The solders and the PVC material in the cord have an excessive concentration of lead (measured value up to 54.9 % by weight). Lead poses a risk to the environment. The cord material has an excessive concentration of bis(2-ethylhexyl) phthalate (DEHP) and dibutyl phthalate (DBP) (measured values: 1.7% and 1.3% by weight, respectively). These phthalates may harm the health of children, causing possible damage to their reproductive system. The solders in the product have an excessive concentration of cadmium (measured value: 0.14% by weight). Cadmium bio-accumulates and poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Persistent Organic Pollutants (POP) Regulation

Alert Number/Link:

A12/01559/23

Bluetooth Headphones

Bluetooth-HeadphonesDescription:

The white plastic in the cable, the solder in connection to battery and the solders on the PCB of the product have excessive concentrations of lead (measured values up to 0.26%, 31.8% and 75.9% by weight, respectively). Lead poses a risk to the environment. The white plastic material in the cable has excessive an concentration of bis(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP) and short chain chlorinated paraffins (SCCPs) (measured values up to 1.69%, 1.67 % and 6.49 % by weight, respectively). The black leather material of the product has an excessive concentration of bis(2-ethylhexyl) phthalate (DEHP) (measured value up to 19.3%). These phthalates may harm the health by causing possible damage to the reproductive system. SCCPs persist in the environment, are toxic to aquatic organisms at low concentrations and bio-accumulate in wildlife and humans, posing a risk to human health and the environment. Prolonged exposure to them through the skin may cause cancer.

Regulation Violation(s):

EU RoHS 2 Directive

Persistent Organic Pollutants (POP) Regulation

Alert Number/Link:

INFO/00093/23

Mini USB Fan

Mini-USB-FanDescription:

The solders of the product have an excessive concentration of lead (measured value up to 54,6% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01701/23 

USB Charger

USB-ChargerDescription:

The solders on the product have an excessive concentration of lead (measured value up to 35,4% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01703/23

Digital Alarm Clock

Digital-Alarm-ClockDescription:

The solders of the product have an excessive concentration of lead (measured value up to 60,3% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01704/23

USB Flash Drive

USB-Flash-DriveDescription:

The solders in the product have an excessive concentration of lead (measured value: 59.6% by weight). Lead poses a risk to the environment. The pink plastic material of the product has an excessive concentration of 24.26% by weight of DEHP bis(2-ethylhexyl) phthalate. This phthalate may harm the health by possibly causing damage to the reproductive system.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01718/23

Remote Control

Remote-ControlDescription:

The solders on the Printed Circuit Board (PCB) have an excessive concentration of lead (measured value up to 26.4% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01700/23

Induction Headlamp

Induction-HeadlampDescription:

The solders and plastics of the product have an excessive concentration of lead (measured value up to 58.6% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01702/23

Star Lamp/Projector

Star-Lamp-ProjectorDescription:

The solders of the product have excessive concentrations of lead and cadmium (measured values up to 71,9% and 0,16% by weight, respectively). Lead and cadmium pose a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01705/23

Remote Control Toy

Remote-Control-ToyDescription:

The solders on the Printed Circuit Board (PCB) have an excessive concentration of lead (measured value up to 67% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01699/23

Antenna Power Supply

Antenna-Power-SupplyDescription:

The metal components of the product contain an excessive amount of lead (measured value up to 48%). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01761/23

Loudspeakers

Loudspeakers

Description:

The solders have an excessive concentration of lead (measured value up to 58,65%). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01805/23

Eyelash Curler

Eyelash-CurlerDescription:

The solders in the product have an excessive concentration of lead (measured value: 74% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01840/23

Antenna Power Supply

Antenna-Power-SupplyDescription:

The product contains an excessive concentration of lead (measured value up to 67,2%) and cadmium (measured value up to 0,06%). Lead and cadmium pose a risk to the environment.

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01887/23

Wireless Headphones

Wireless-HeadphonesDescription:

The product does not comply with the requirements of the Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS 2 Directive).

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01904/23

As a result of the violations, the importers of all 15 products were required to withdraw the products from the European market.

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

Compliance with EU RoHS and EU POP is mandatory for affected companies that manufacture or distribute products in the European market. As demonstrated by the enforcement actions above, failure to comply with this regulation can result of loss of market access and other serious consequences for manufacturers and distributors.

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

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

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Conference

September 6, 2023 | Written by GreenSoft Technology, Inc.

RBA & RMI Annual Conference and AIAG’s Hybrid IMDS & Product Chemical Compliance Conference

 

Join GreenSoft Technology at two of the biggest industry events of the year for Electronic Manufacturers

GreenSoft Technology will be exhibiting at two important industry conferences this coming October: the RBA and RMI Annual Conference and AIAG’s Hybrid IMDS & Product Chemical Compliance Conference are both taking place on October 17 and 18.

RBA and RMI Annual Conference 2023

The Responsible Business Alliance (RBA) and Responsible Minerals Initiative (RMI) are respected resources for companies from a range of industries dedicated to corporate social responsibility in global supply chains and responsible mineral sourcing.

This year, the RBA and RMI annual conferences have been combined to create one comprehensive event that will bring together representatives of industry, government and civil society. The theme of this year’s conference is “The Supply Chain of the Future,” and it will include issues critical to the entire global supply chain, such as human rights, the environment, minerals sourcing, emerging issues and regulations, supply chain resiliency, and more.

The event will be held in-person in Santa Clara, CA and the conference sessions will be broadcast live online as well. GreenSoft Technology will be on-site in Santa Clara to talk about our Conflict Minerals solutions with attendees, including our Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) Data Collection Services and Conflict Minerals Module for GreenData Manager (GDM) software.

Register now to attend the RBA and RMI Annual Conference, and learn more about our Conflict Minerals solution online.

AIAG's 2023 Hybrid IMDS & Product Chemical Compliance Conference

Founded by the three largest North American automotive OEMS, the Automotive Industry Action Group (AIAG) is a not-for-profit organization where auto industry members collaborate to develop common global standards for Quality, Supply Chain, and Corporate Responsibility issues.

Extended to two full days this year, the 2023 Hybrid IMDS & Product Chemical Compliance Conference will focus on "Transitioning IMDS from Materials Compliance to the Circular Economy."

Along with sustainability-specific topics, presentations will explore Product Carbon Footprint (PCF) reporting, LCAs, updates to the battery legislation and digital products passport, TSCA, Responsible Sourcing, Recyclate and PFAS, along with numerous IMDS updates, including what's new in version 14.0, and what's coming next in version 15.0.

The event will be held both in-person in Novi, MI and virtually. GreenSoft Technology will be on-site in Novi to showcase our complete IMDS solution for Auto Manufacturers, including our Full Material Declaration Data Collection Services and Component Disclosure Module for GreenData Manager (GDM) software.

Learn more and register for the event online.

 

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EU Battery Regulation

August 24, 2023 | Written by GreenSoft Technology, Inc.

New EU Battery Regulation Released

 

EU-Battery-RegulationEU Battery Directive repealed and replaced with new EU Battery Regulation

On July 28, the European Commission published a new Battery Regulation, and announced the upcoming repeal of the previous EU Battery Directive.

Regulation (EU) 2023/1542 is effective August 18, 2023. The previous EU Battery Directive 2006/66/EC will be repealed on August 18, 2025.

The new Battery Regulation has a similar scope and similar product categories as the previous EU Battery Directive; however, the new Battery Regulation includes additional substance restrictions and labeling requirements.

The full text of the new regulation can be found here.

Mercury, Cadmium, and Lead substance restrictions

As in the old version, batteries shall not contain more than 0.0005% of Mercury (CAS No 7439-97-6) or its compounds by weight, and portable batteries shall not contain more than 0.002% of Cadmium (CAS No 7440-43-9) and its compounds by weight. However, the new EU Battery Regulation also includes restrictions on Lead (CAS No 7439-92-1) and its compounds.

While the previous EU Battery Directive contained marking requirements for Lead, it did not restrict the usage of Lead. Under the new EU Battery Regulation, portable batteries, whether or not incorporated into appliances, shall not contain more than 0.01% of Lead by weight, effective August 18, 2024. For portable zinc-air button cells, the restriction takes effect on August 18, 2028.

Updated product labeling requirements

As with the prior EU Battery Directive, under the new EU Battery Regulation all batteries containing more than 0.002% Cadmium or more than 0.004% Lead must be marked with the chemical symbol for the metal concerned: Cd or Pb.

Additionally, as of August 18, 2025, affected products must be marked with a symbol indicating separate collection of batteries. And starting February 18, 2027, all batteries must be marked with a QR code that provides access to the following information:

  1. For LMT batteries, industrial batteries with a capacity greater than 2kWh and electric vehicles batteries, the battery passport in accordance with Article 77;
  2. For other batteries, the applicable information referred to in paragraphs 1 to 5 of this Article, the declaration of conformity referred to in Article 18, the report referred to in Article 52(3) and the information regarding the prevention and management of waste batteries laid down in Article 74(1), points (a) to (f); and
  3. For SLI batteries, the amount of cobalt, lead, lithium or nickel recovered from waste and present in active materials in the battery, calculated in accordance with Article 8.

Further labeling requirements in the new EU Battery Regulation include:

  • Beginning August 18, 2026, batteries shall bear a label containing the general information on batteries, including the manufacturer, battery category, and the hazardous substances present in the battery other than Mercury, Cadmium or Lead;
  • Rechargeable portable batteries, LMT batteries and SLI batteries shall bear a label containing information on their capacity; and
  • Non-rechargeable portable batteries shall bear a label containing information on their minimum average duration when used in specific applications and a label indicating ‘non-rechargeable’.

Identifying hazardous substances in products

GreenSoft Technology, Inc. provides Data Services and GreenData Manager software to help companies identify the presence and amounts of hazardous substances in their products, including Mercury, Cadmium, and Lead.

Our data collection team will contact your suppliers on your behalf to obtain data on the substances contained in your products and components, and validate that data for completeness and accuracy. We’ll provide reports in a variety of formats, or generate reports yourself using GreenData Manager software, so that you can easily show compliance with the EU Battery Regulation and other global environmental regulations.

Contact us to learn more.

 

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California Proposition 65

August 22, 2023 | Written by GreenSoft Technology, Inc.

Three Chemicals Added/Updated on the California Proposition 65 Substance List

 

proposition-65Anthracene and Dimethyl Hydrogen Phosphite added, 2-Bromopropane updated, on the Proposition 65 regulated substances list

In August, California’s Office of Environmental Health Hazard Assessment (OEHHA) added two new substances to the list of chemicals regulated under the state’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65), and updated one substace existing on the list.

Effective August 11, 2023, the following two substances have been added to the list of chemicals known to the State of California to cause cancer:

• Anthracene (CAS RN 120-12-7)

• Dimethyl hydrogen phosphite (CAS RN 868-85-9)

Anthracene is commonly used as a precursor for dyes, pigments, and fluorescent compounds. And dimethyl hydrogen phosphite serves as a reagent in organic synthesis in the production of agrochemicals, pharmaceuticals, and specialty chemicals, and is used as a flame retardant and smoke suppressant.

Additionally, the type of toxicity for 2-bromopropane (CAS RN 75-26-3) was updated to include "cancer" in addition to "female and male reproductive toxicity". 2-Bromopropane is primarily utilized as a solvent in industrial cleaning and degreasing, as well as a chemical intermediary for synthesizing pharmaceuticals and specialty chemicals.

California law requires that certain substances identified by the International Agency for Research on Cancer (IARC) be listed as known to cause cancer under California Proposition 65. The IARC recently concluded that 2-bromopropane is “probably carcinogenic to humans” and that anthracene and dimethyl hydrogen phosphite are “possibly carcinogenic to humans.” Additionally, the IARC concluded that there is sufficient evidence of carcinogenicity in animals for all three substances.

The full California Proposition 65 list of regulated substances can be found here. The announcement of the three new substance additions/updates can be found here.

GreenSoft Technology provides help with Proposition 65

The inclusion of substances in the California Proposition 65 regulated substances list brings about immediate obligations for affected companies. In order to comply with the obligations under California Proposition 65, businesses must 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 Proposition 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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EU RoHS

August 18, 2023 | Written by GreenSoft Technology, Inc.

Two New Exemptions Added to EU RoHS Annex IV

 

EU-ROHS-ExemptionExemptions for Mercury and Lead added to Annex IV of the EU RoHS Directive

In July, the European Commission published two new exemptions under the EU RoHS Directive.

On July 11, the following entry 49 was added to Annex IV to Directive 2011/65/EU:

“49: Mercury in melt pressure transducers for capillary rheometers at temperatures over 300 °C and pressures over 1 000 bar. Applies to category 9 and expires on 31 December 2025.”

And on July 24, the following entry 41a was added to Annex IV to Directive 2011/65/EU:

“41a: Lead as a thermal stabilizer in polyvinyl chloride (PVC) used as base material in amperometric, potentiometric and conductometric electrochemical sensors which are used in in vitro diagnostic medical devices for the analysis of creatinine and blood urea nitrogen in whole blood. Applies to category 8 and expires on 31 December 2023.”

Both exemptions are entered into force on the twentieth day following their publications. Details on entry 49 can be found here, and details on entry 41a can be found here.

Updated EU RoHS Exemptions List available to download

EU RoHS exemptions have varying expiration dates, and when expiration dates near, many exemptions are renewed with updated expiration dates. With the status and timing of exemption extensions unknown, keeping track of the various expiration dates and current exemptions is a time-consuming task.

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 two new exemptions. You can download the updated EU RoHS Exemptions List here.

 

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Export Controls

July 27, 2023 | Written by GreenSoft Technology, Inc.

Identifying Germanium and Gallium in Electronics

 

Identifying-Germanium-and-GalliumGreenSoft Technology analyzed our parts database to identify the most common parts containing Germanium and Gallium

Recent international developments have sparked concerns in the electronics industry regarding the implementation of export controls on certain substances. Among the affected substances are Germanium and Gallium.

Classified as "Heavy Metals,” Germanium and Gallium are widely used in various electronics applications, including military technologies.

With these developments potentially causing supply chain disruptions, GreenSoft Technology has conducted an in-depth study to help electronics manufacturers prepare for potential challenges.

We analyzed our Full Material Declaration (FMD) database, which contains information on millions of components, to identify parts that contain Germanium and Gallium.

Our study revealed that 7,061 parts from 308 manufacturers in our FMD Database were found to be at-risk due to the presence of Germanium or Gallium. 2,203 parts from 159 manufacturers contain Germanium; and 5,328 parts from 227 manufacturers contain Gallium.

Identifying the most common parts containing Germanium

Germanium is a lustrous, grayish-white metalloid with excellent semiconductor properties. It is often used as a dopant in semiconductors to enhance their electrical properties. Germanium is commonly found in electronic components like transformers, inductors, opto-electronics, modules, and PCBs. Its use as a semiconductor material makes it essential in diodes, transistors, and other electronic devices. Additionally, due to its semiconducting properties, Germanium is frequently used for aerospace and defense applications in infrared optics, night-vision systems, and various military sensors.

The analysis of our FMD Database revealed 5 types of parts most likely to contain Germanium:

Transformers: Out of the millions of parts in our FMD database, 442 transformers were found to contain Germanium. Germanium enhances the efficiency of power transformers used in electrical circuits.

Inductors: The search identified 329 inductor parts containing Germanium. Inductors utilize Germanium’s properties to store and release energy in electronic circuits.

Opto-Electronics: Our analysis found that 289 opto-electronic parts contained Germanium. Germanium plays a key role in the production of opto-electronic devices, such as infrared sensors and photodetectors.

Modules: We identified 249 modules containing Germanium. Germanium's inclusion in modules is generally based on its ability to function as a key component in specific circuitry or signal processing tasks.

Printed Circuit Boards (PCBs): Our search found that 227 PCBs contained Germanium. Germanium assists in the smooth operation of PCBs, which are essential components in electronic devices.

Other parts found to contain Germanium include ICs, Crystal/Oscillators, Switches/Relays, Connectors, Memories, Other Active Parts, Resistors, Other Mechanical Parts, Adhesives, Cables/Cable Assemblies, Filters, Discrete Semiconductors, and Capacitors.

Identifying the most common parts containing Gallium

Gallium is a soft, silvery metal with a low melting point, making it ideal for certain electronic applications. Gallium is predominantly found in opto-electronics, ICs, modules, connectors, and switches/relays. Its wide use in opto-electronic devices stems from its light-emitting properties. Gallium-based compounds are also used for aerospace and defense applications in radars, electronic warfare systems, and high-frequency communication technologies.

Our research found that Opto-Electronics were the most common parts found to contain Gallium by a wide margin. The analysis of our FMD Database revealed 4 types of parts most likely to contain Gallium:

Opto-Electronics: Gallium is extensively used in light-emitting diodes (LEDs) and other opto-electronic devices. 3,781 opto-electronic parts in our database were found to contain Gallium.

Integrated Circuits (ICs): 549 IC parts in our database were found to contain Gallium. Gallium is used in ICs as a semiconductor material, playing a crucial role in the construction of integrated circuits that power electronic devices.

Modules: Our analysis found that 477 modules contained Gallium. Gallium is used in modules to enhance the functionality of opto-electronic devices, such as light-emitting diodes (LEDs), contributing to various applications, including fiber-optic communication and high-speed data transmission.

Connectors: We identified 239 connector parts containing Gallium. Gallium enhances the performance of electronic connectors used in various devices.

Other parts found to contain Gallium include Switches/Relays, Other Mechanical Parts, Other Active Parts, Discrete Semiconductors, Memories, Cables/Cable Assemblies, Enclosures/Structure Support, Transformers, Resistors, Fasteners, Filters, Crystals/Oscillators, PCBs, Capacitors, and Other Passive Parts.

Navigating Supply Chain Disruptions

With a significant number of parts containing Germanium and Gallium at risk due to export controls, electronics manufacturers should take proactive measures to mitigate potential supply chain disruptions.

Identifying which components in your supply chain are likely to contain Germanium and Gallium is crucial for manufacturers to strategically plan for any contingencies that may arise from international export controls.

GreenSoft Technology’s Data Services solution can assist companies in identifying Germanium and Gallium in their products by collecting chemical data from their supply chain. Our data collection team will contact your suppliers on your behalf to obtain data on the substances contained in your products and components, and validate that data for completeness and accuracy.

Additionally, GreenSoft Technology can help source replacement suppliers, and generate compliance reports for various global environmental regulations. We also offer GreenData Manager software so you can manage your company’s substance database and easily generate substance and compliance reports.

Contact us to learn more.

 

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EU REACH

June 19, 2023 | Written by GreenSoft Technology, Inc.

Two Entries Added to EU REACH SVHC List

 

eu-reach-svhcEU REACH SVHC List now contains 235 Entries

On June 14, the European Chemicals Agency (ECHA) announced the addition of 2 substances to the EU REACH Substances of Very High Concern (SVHC) Candidate List.

The 2 substances, as well as their reasons for inclusion and common uses, are listed in the table below.

The EU REACH SVHC Candidate List now has 235 entries. However, some entries are groups of chemicals, so the overall number of impacted chemicals is higher.

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 notification requirements and notifying ECHA through submissions to the SCIP Database. GreenSoft Technology can help with this process as part of our Data Services.

The 2 new substances are:

Substance name EC number CAS number Reason for inclusion Examples of use(s)
Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide 278-355-8 75980-60-8           Toxic for reproduction (Article 57c) Inks and toners, coating products, photo-chemicals, polymers, adhesives and sealants and fillers, putties, plasters, modelling clay.
Bis(4-chlorophenyl) sulphone 201-247-9 80-07-9  vPvB (Article 57 e) Manufacture of chemicals, plastic products and rubber products.

ECHA’s announcement of the additions can be found here. The full SVHC-235 list can be found here. The last prior addition to the SVHC list was SVHC-233 in January 2023.

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 Technology 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 Data Services help your company with EU REACH compliance by contacting us.

 

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PFAS

June 16, 2023 | Written by GreenSoft Technology, Inc.

Identifying PFAS Chemicals in Electronics: A Crucial Step in Preparing for PFAS Regulations

 

Identifying-PFAS-Chemicals-in-ElectronicsGreenSoft Technology analyzed our parts database to identify the most common parts and substances containing PFAS

In recent years, there has been a growing concern regarding the presence of perfluoroalkyl and polyfluoroalkyl substances (PFAS) chemicals in various products, including electronics.

Due to their persistence and adverse health effects, PFAS “forever chemicals” have gained traction in the media, and regulatory bodies across the globe are enacting new regulations to ban or regulate the use of PFAS chemicals.

GreenSoft Technology has conducted a comprehensive search in our Full Material Declaration (FMD) database, which contains information on over 11 million components, to identify parts that contain PFAS chemicals. We based our analysis on the U.S. Environmental Protection Agency (EPA) Master List of PFAS Chemicals, which identifies over 12,000 PFAS chemicals, and the Organization for Economic Co-operation and Development (OECD) list, which identifies over 4,700 PFAS chemicals.

Our study found that 56 types of PFAS chemicals were commonly found to be present in 27 different categories of products, and over 7,000 parts in our FMD database were found to contain one or more PFAS chemicals. This data provides valuable insights for electronics manufacturers, enabling you to proactively prepare for upcoming PFAS bans and regulatory deadlines.

Identifying the most common parts containing PFAS

The analysis of our FMD database revealed three types of parts most likely to contain PFAS chemicals: capacitors, connectors, and cables/cable assemblies.

Capacitors: Out of the 11 million parts in our FMD database, 1,752 were found to contain PFAS chemicals. Capacitors, widely used in electronic circuits for energy storage and filtering, were the most common parts associated with PFAS.

Connectors: The search identified 1,549 connector parts containing PFAS chemicals. Connectors play a crucial role in establishing electrical connections between different components and devices.

Cables/Cable Assemblies: Our analysis found that 1,288 cable/cable assembly parts contained PFAS chemicals. Cables are essential for transmitting signals and power within electronic systems, making their identification vital for compliance efforts.

Other parts found to contain PFAS chemicals include Resistors (642 parts were found to contain PFAS chemicals), Mechanical Parts (612 parts were found to contain PFAS chemicals), and Transformers (429 parts were found to contain PFAS chemicals).

While the most common parts found to contain PFAS are listed above, the presence of PFAS chemicals overall was detected in 27 different part categories, including Modules, Memory Systems, ICs, Switches/Relays, Inductors, Fasteners, Filters, Other Passive Parts, Adhesives, Resins, Crystals/Oscillators, Other Active Parts, PCBs, Opto Electronics, Labels, Paints, Enclosures/Structure Support, Batteries, Discrete Semiconductors, Packaging, and Chemicals Reagents.

The prevalence of specific PFAS chemicals

Among the PFAS chemicals identified in the aforementioned parts, the most common substance present was Ethene, 1,1,2,2-tetrafluoro-, homopolymer (PTFE with CAS Number 9002-84-0, aka Teflon), which was found in over 5,800 parts in our database.

Other PFAS substances frequently identified in the parts database include:

  • 1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1,2,2-tetrafluoroethene (CAS Number 25067-11-2) - present in 362 parts;
  • Pentadecafluorooctanoic acid (CAS Number 335-67-1) - found in 333 parts; and,
  • Propane, 1,1,1,2,2,3,3-heptafluoro-3-[(1,2,2-trifluoroethenyl)oxy]-, polymer with 1,1,2,2-tetrafluoroethene (CAS Number 26655-00-5) - detected in 243 parts.

Overall, a total of 56 PFAS chemicals were detected in various parts in the database. The full list of PFAS chemicals detected is included in Appendix A at the bottom of this post.

Implications for electronics manufacturers

By understanding which components are likely to contain PFAS chemicals, manufacturers can take proactive steps to prepare for upcoming regulatory requirements, such as the recent PFAS regulations passed in Maine and Minnesota, or the PFAS regulation currently under review in the European Union.

GreenSoft Technology’s Data Services solution can also help companies identify PFAS in their products by collecting chemical data from your supply chain. Our data collection team will contact your suppliers to obtain data on the substances contained in your products and components. We’ll validate that data for accuracy and completeness, and check it against the EPA and OECD PFAS lists, and any other global environmental regulations that you must comply with.

With our Turnkey Service, we can generate the necessary compliance reports for you. Or you can use our GreenData Manager software to manage your company’s substance database and easily generate reports for this and other environmental regulations.

Contact us to learn more.

 

Appendix A: Full list of PFAS chemicals detected

PFAS Chemical Detected Number of Parts PFAS Chemical Detected In
Ethene, 1,1,2,2-tetrafluoro-, homopolymer 5843
1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1,2,2-tetrafluoroethene 362
Pentadecafluorooctanoic acid 333
Propane, 1,1,1,2,2,3,3-heptafluoro-3-[(1,2,2-trifluoroethenyl)oxy]-, polymer with 1,1,2,2-tetrafluoroethene 243
1-Hexene, 3,3,4,4,5,5,6,6,6-nonafluoro-, polymer with ethene and 1,1,2,2-tetrafluoroethene 146
Perfluoro compounds, C5-18 93
Potassium 1,1,2,2,3,3,4,4,4-nonafluorobutane-1-sulphonate 53
Norflurane 46
1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene 43
2-Propenoic Acid, 2-[Methyl[(Nonafluorobutyl)Sulfonyl]Amino]Ethyl Ester, Telomer With Methyloxirane Polymer With Oxirane Di-2-Propenoate and Methyloxirane Polymer With Oxirane Mono-Propenoate 39
1-Hexanesulfonic acid, 1,1,2,2,3,3,4,4,5,5,6,6,6-tridecafluoro- 34
Ammonium pentadecafluorooctanoate 32
Tetrafluoroethylene 28
Heptacosafluorotetradecanoic acid 24
1-Hexanesulfonic acid, 1,1,2,2,3,3,4,4,5,5,6,6,6-tridecafluoro-, lithium salt (1:1) 18
4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol 15
Pentacosafluorotridecanoic acid 15
1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene and 1,1,2,2-tetrafluoroethene 13
Henicosafluoroundecanoic acid 13
Oxetane, 2,2,3,3-tetrafluoro-, homopolymer, fluorinated 13
Tricosafluorododecanoic acid 13
Propane, 2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-heptafluoro- 11
1-Octanesulfonic acid, 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-heptadecafluoro-, ammonium salt (1:1) 10
Butane, 1-ethoxy-1,1,2,2,3,3,4,4,4-nonafluoro- 10
Butane, 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy- 9
Ethene, 1,1,2,2-tetrafluoro-, polymer with ethene 9
1-Propene, 1,1,2,3,3,3-hexafluoro-, oxidized, polymd. 7
Propane, 2-(difluoromethoxymethyl)-1,1,1,2,3,3,3-heptafluoro- 7
Triethoxy(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)-silane 7
1-Propene, polymer with 1,1,2,2-tetrafluoroethene 6
Ethene, 1-chloro-1,2,2-trifluoro-, homopolymer 6
Ethyl perfluorononan-1-oate 6
Mixture of S,S,S',S'-Tetraphenylthiobis(4,1-phenylene)disulfonium dihexafluoroantimonate and diphenyl(4-phenylthiophenyl) sulfonium hexafluoroantimonate 6
Ethene, 1,1,2,2-tetrafluoro-, oxidized, polymd. 5
Pentanoic acid, 4,4-bis((gamma-omega-perfluoro-C8-20-alkyl)thio) derivs., compds. with diethanolamine 4
Poly[oxy[trifluoro(trifluoromethyl)-1,2-ethanediyl]], .alpha.-(1,1,2,2,2-pentafluoroethyl)-.omega.-[tetrafluoro(trifluoromethyl)ethoxy]- 4
1-Butanesulfonamide, 1,1,2,2,3,3,4,4,4-nonafluoro-N-(2-hydroxyethyl)-N-methyl- 3
1-Octanesulfonamide, N-[3-(dimethyloxidoamino)propyl]-1,1,2,2,3,3,4,4,5,5, 6,6,7,7,8,8,8-heptadecafluoro- 3
ETFE 3
Ethene, fluoro-, homopolymer 3
Heptadecafluorooctanesulphonyl fluoride 3
Poly(difluoromethylene), .alpha.-(cyclohexylmethyl)-.omega.-hydro- 3
pentadecafluorooctyl chloride 2
Phosphonium, triphenyl(phenylmethyl)-, salt with 4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]bis[phenol] (1:1) 2
Poly(oxy-1,2-ethanediyl), .alpha.-hydro-.omega.-hydroxy-, ether with .alpha.-fluoro-.omega.-(2-hydroxyethyl)poly(difluoromethylene) (1:1) 2
(2-carboxylatoethyl)(dimethyl)[[[4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,15,15,15-tetracosafluoro-2-hydroxy-14-(trifluoromethyl)pentadecyl]amino]propyl]mmonium 1
1,1,1,2,2,4,5,5,5-nonafluoro-4-(trifluoromethyl )-3-pentanone 1
1-Propene, 1,1,2,3,3,3-Hexafluoro-, oxidzed, polymd., reduced, hydrolized reaction products with ammonia, mittlere Molmasse 3000 g/m 1
3-ethoxy-1,1,1,2,3,4,4,5,5,6,6,6-dodecafluoro-2-(trifluoromethyl)-hexane 1
Diammonium 4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,11-heptadecafluoro-2-hydroxyundecyl phosphate 1
Ethene, 1,1,2,2-tetrafluoro-, polymer with 1,2,2-trifluoro-2-(trifluoromethoxy)ethene 1
Ethene, 1-chloro-1,2,2-trifluoro-, polymer with ethene 1
Pentafluoroethane 1
Pentane, 1,1,1,2,2,3,4,5,5,5-decafluoro- 1
Perfluoroethane 1
Propane, 1,1,1,3,3,3-hexafluoro- 1
Total Number of Instances PFAS Chemicals Detected in Parts 7561
 

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PFAS

June 9, 2023 | Written by GreenSoft Technology, Inc.

New PFAS Regulation in Minnesota Coming in 2026

 

Minnesota-PFAS-RegulationGovernor signs law regulating products containing PFAS sold in Minnesota, effective January 1, 2026

On May 24, Minnesota Governor Tim Walz signed a new bill into law which regulates the selling of PFAS, or “forever chemicals,” in the state of Minnesota.

Effective January 1, 2026, the new regulation requires notification prior to selling, offering for sale, or distributing in the state any product that contains intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS).

Per the regulation, on or before January 1, 2026, affected manufacturers must submit to the commissioner of the Minnesota Pollution Control Agency information that includes:

  1. A brief description of the product, including a universal product code (UPC), stock keeping unit (SKU), or other numeric code assigned to the product;
  2. the purpose for which PFAS are used in the product, including in any product components;
  3. the amount of each PFAS, identified by its chemical abstracts service registry number (CAS Number), in the product, reported as an exact quantity determined using commercially available analytical methods or as falling within a range approved for reporting purposes by the commissioner;
  4. the name and address of the manufacturer and the name, address, and phone number of a contact person for the manufacturer; and
  5. any additional information requested by the commissioner as necessary to implement the requirements of this section.

Further, effective January 1, 2032, all products sold in Minnesota are banned from containing intentionally added PFAS entirely, unless deemed as an essential use by the state commissioner.

Intentionally added PFAS is also banned from certain categories of products even sooner, though this provision is expected to have minimal effect on the electronics industry. Effective January 1, 2025, intentionally added PFAS is completely banned from the following products: (1) carpets or rugs; (2) cleaning products; (3) cookware; (4) cosmetics; (5) dental floss; (6) fabric treatments; (7) juvenile products; (8) menstruation products; (9) textile furnishings; (10) ski wax; or (11) upholstered furniture.

The regulation is authorized as part of a larger spending bill for the state, HF2310A. The spending bill creates a new section, 116.943 - PFAS Containing Products, to Chapter 116 of the Minnesota State Statutes containing the PFAS provisions.

Minnesota’s new PFAS regulation closely resembles the PFAS regulation recently enacted in the state of Maine. (Note: On June 1, the Maine PFAS regulation implementation deadline was delayed by 2 years until 2025.)

Read the full text of the new Minnesota PFAS regulation here. Details on the progression of the bill through the Minnesota legislature and governor’s office can be found here.

GreenSoft Technology offers a PFAS solution for manufacturers

GreenSoft Technology’s Data Services solution provides affected companies with the chemical data from their supply chain that is needed to comply with the new Minnesota PFAS regulation.

Our data collection team will contact your suppliers to obtain data on the substances contained in your products and components. We’ll validate that data for accuracy and completeness, and then check it against the U.S. Environmental Protection Agency (EPA) Master List of PFAS Chemicals, the Organisation for Economic Co-operation and Development (OECD) list of PFAS chemicals, and any other global environmental regulations that you must comply with.

With our Turnkey Service, we can generate the necessary compliance reports for you. Or you can use our GreenData Manager software to manage your company’s substance database and easily generate reports for this and other environmental regulations.

Contact us to learn more.

 

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PFAS

June 7, 2023 | Written by GreenSoft Technology, Inc.

Maine PFAS Regulation Deadline Extended to 2025

 

Maine-PFAS-Deadline-Extended

Deadline for reporting PFAS under Maine’s new regulation pushed to January 1, 2025 

On June 1, the U.S. state of Maine approved an amendment to the state’s PFAS regulation extending the reporting deadline to January 1, 2025. 

The regulation mandates reporting requirements for any products sold in the state of Maine which contain intentionally added perfluoroalkyl and polyfluoroalkyl substances (PFAS). The original reporting deadline in the initial publication of the regulation was January 1, 2023.  

With this new deadline extension, affected companies will have an additional two years to comply with the regulation. The changes made in the amendment are made retroactive to January 1, 2023. 

In addition to extending the reporting deadline to January 1, 2025, the amendment also: 

  • Authorizes reporting the amount of total organic fluorine if the amount of each PFAS compound is not known, 
  • Allows the amount of PFAS to be reported based on information provided by a supplier rather than testing, 
  • Clarifies the packaging exemption under the law regulating PFAS in products, 
  • Exempts from PFAS reporting requirements manufacturers that employ 25 or fewer people, 
  • Clarifies that the requirements and prohibitions of PFAS in products do not apply to used products or used product components, and 
  • Makes other technical clarifications to PFAS reporting requirements.   

The full text of the regulation and the amendment can be found online. GreenSoft Technology’s summary of the regulation requirements can be found on our blog. 

GreenSoft Technology offers a PFAS solution for manufacturers

With the new reporting deadline of January 1, 2025 over a year away, now is the time to start preparing for the effective date by collecting data from the supply chain and evaluating products for the presence of PFAS. 

GreenSoft Technology’s Data Services solution provides affected companies with the chemical data from their supply chain that is needed to comply with the Maine PFAS regulation. 

Our data collection team will contact your suppliers to obtain data on the substances contained in your product and components. We’ll validate that data for accuracy and completeness, and then check it against the U.S. EPA’s Master List of PFAS Chemicals (the list which the Maine PFAS regulation references to identify PFAS substances), as well as any other global environmental regulations you must comply with.  

With our Turnkey Service, we can generate the necessary compliance reports for you. Or you can use our GreenData Manager software to manage your company’s substance database and generate reports for this and other environmental regulations.  

Contact us to learn more.  

 

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Conflict Minerals

June 6, 2023 | Written by GreenSoft Technology, Inc.

New Conflict Minerals Reporting Template Version 6.31 Released

 

New-Conflict-Mineral-Reporting-TemplateConflict Minerals Reporting Template (CMRT) 6.31 now available to download

On May 26, the Responsible Minerals Initiative (RMI) released an updated Conflict Minerals Reporting Template (CMRT) version: CMRT 6.31.

CMRT forms are used to exchange conflict minerals data across the supply chain in order to comply with the U.S. Conflict Minerals regulation (U.S. Dodd-Frank Act of 2010).

Changes to CMRT 6.31 from the prior version include:

  • Minor revisions to correct reported issues including those related to “Declaration,” “Smelter List,” and “Smelter Look-up” tabs on CMRT 6.3.

The new CMRT 6.31 form can be downloaded online.

Note: CMRT 6.31 was released on May 26, 2023. A previous version, CMRT 6.3, was released on May 5, 2023, but contained reported issues. The RMI organization has corrected the issues in the updated CMRT 6.31 release. The RMI organization recommends using CMRT 6.31 or higher for the Reporting Year.

GreenSoft Technology provides CMRT collection and conflict minerals compliance services

GreenSoft Technology helps companies manage Conflict Minerals compliance as part of our Conflict Minerals data services. We provide CMRT collection, validation, and review for your Reasonable Country of Origin Inquiries (RCOIs). We also offer Smelter or Refiner (SOR) Validation, and Extended Mineral Reporting Template (EMRT) collection.

For existing GreenSoft Technology customers, our data services team will prepare to start using CMRT 6.31 for data collection going forward. And our software development team will begin preparations to update our GreenData Manager (GDM) software Conflict Minerals Module for CMRT 6.31.

Learn more about how our Data Services help your company with Conflict Minerals compliance by contacting us.

 

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White Paper

May 19, 2023 | Written by GreenSoft Technology, Inc.

Staying Ahead of the Game: Using Full Material Declaration (FMD) Data to Ensure Compliance with Current and Future Regulations

 

FMD-White-PaperDownload our new White Paper on green compliance management best practices for component manufacturers today!

GreenSoft Technology has published a new White Paper on the benefits of Full Material Declaration (FMD) data for green compliance management.

Staying Ahead of the Game: Using FMD Data to Ensure Compliance with Current and Future Regulations provides an overview of the environmental regulation challenges and solutions for electronic component manufacturers.

Download the White Paper for free in our White Paper Library!

A practical solution for ever-changing green regulations

As demand for green compliance regulations increases across the globe, component manufacturers face new challenges to comply with these complex regulations. Failure to comply can result in fines, loss of business, and harm to the environment. GreenSoft Technology provides a practical way to manage these challenges.

GreenSoft Technology’s FMD solution creates a materials database for products, which can be used to validate against current and future green regulations from around the world. The database also provides an early warning for whether products will remain compliant when restricted substance listings are still in the proposal stage, so companies can stay ahead of the game.

This new White Paper outlines GreenSoft Technology's 3-step process for implementing an FMD materials database solution. The solution helps component manufacturers create their company's material database with FMD data, validate it against various green compliance regulations from different regions, and generate compliance statements per required regulations in industry-standard exchange formats.

GreenSoft Technology's FMD solution enables component manufacturers to meet their green compliance requirements in a cost-effective and streamlined manner. By investing in an FMD materials database, component manufacturers can manage the increasing demands of green compliance regulations and stay ahead of future regulations.

Download Staying Ahead of the Game: Using Full Material Declaration (FMD) Data to Ensure Compliance with Current and Future Regulations today and learn how GreenSoft Technology's FMD solution can help your company manage green compliance requirements efficiently and effectively.

 

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