EU REACH

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

Nine Entries Added to EU REACH SVHC List

 

eu-reach-svhcEU REACH SVHC List now contains 233 Entries

On January 17, the European Chemicals Agency (ECHA) announced the addition of 9 entries to the EU REACH Substances of Very High Concern (SVHC) Candidate List.

The 9 entries, as well as their reasons for inclusion and common uses, are listed in the table below.

The EU REACH SVHC Candidate List now has 233 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 9 new entries are:

Substance name EC number CAS number Reason for inclusion Examples of use(s)
1,1'-[ethane-1,2-diylbisoxy]bis[2,4,6-tribromobenzene] 253-692-3 37853-59-1 Very persistent and very bioaccumulative (REACH Article 57 e) While the substance itself is not registered under REACH, identification as an SVHC can be seen as a measure to avoid future regrettable substitution.
2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol 201-236-9 79-94-7 Carcinogenic (Article 57 a) As a reactive flame retardant and as an additive flame retardant in the manufacture of polymer resins, in products such as epoxy coated circuit boards, printed circuit boards, paper and textiles.
4,4'-sulphonyldiphenol 201-250-5 80-09-1 Toxic for reproduction (Article 57 c); Endocrine disrupting properties (Article 57 f – environment); Endocrine disrupting properties (Article 57 f – human health) In the manufacture of: pulp, paper and paper products, textile, leather or fur and chemicals.
Barium diboron tetraoxide 237-222-4 13701-59-2 Toxic for reproduction (Article 57 c) In paints and coatings.
Bis(2-ethylhexyl) tetrabromophthalate covering any of the individual isomers and/or combinations thereof - - Very persistent and very bioaccumulative (Article 57 e) As a flame retardant and as a plasticiser for flexible polyvinylchloride and for use in wire and cable insulation, film and sheeting, carpet backing, coated fabrics, wall coverings and adhesives.
Isobutyl 4-hydroxybenzoate 224-208-8 4247-02-3 Endocrine disrupting properties (Article 57 f – human health) In the manufacture of substances and in the following products: coating products, fillers, putties, plasters, modelling clay and inks and toners.
Melamine 203-615-4 108-78-1 Equivalent level of concern having probable serious effects to human health (Article 57 f – human health); Equivalent level of concern having probable serious effects to the environment (Article 57 f – environment) In polymers and resins, coating products, adhesives and sealants, leather treatment products, laboratory chemicals.
Perfluoroheptanoic acid and its salts - - Toxic for reproduction (Article 57 c); Persistent, bioaccumulative and toxic (Article 57 d); Very persistent and very bioaccumulative (Article 57 e); Equivalent level of concern having probable serious effects to human health (Article 57 f – human health); Equivalent level of concern having probable serious effects to the environment (Article 57 f – environment) While the substance itself is not registered under REACH, identification as an SVHC can be seen as a measure to avoid future regrettable substitution.
reaction mass of 2,2,3,3,5,5,6,6-octafluoro-4-(1,1,1,2,3,3,3-heptafluoropropan-2-yl)morpholine and 2,2,3,3,5,5,6,6-octafluoro-4-(heptafluoropropyl)morpholine 473-390-7 - Very persistent and very bioaccumulative (Article 57 e) Used in articles, by professional workers (widespread uses), in formulation or re-packing, at industrial sites and in manufacturing.

ECHA’s announcement of the additions can be found here. The full SVHC-233 list can be found here. The last prior addition to the SVHC list was SVHC-224 in June 2022.

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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Five Entries Added to EU REACH SVHC List

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

 
 
 
 
 
 
 

EU RoHS

January 13, 2023 | Written by GreenSoft Technology, Inc.

EU RoHS Pack-23 Exemption Recommendations Published

 

eu-rohsNew report published with recommendations on commonly used EU RoHS exemptions

On December 19, 2022, a report summarizing the assessment of EU RoHS exemptions and recommending a course of action for the European Commission to take on those exemptions was published.

Twelve exemptions to Annex III of the EU RoHS Directive, known as Pack-23, were studied under a joint effort by the Fraunhofer-Institute for Reliability and Microintegration (IZM), the United Nations Institute for Training and Research (UNITAR), and BIO Innovation Services (Bio IS).

The final evaluation report recommends a course of action for the European Commission to take on each of the Pack-23 exemptions, which include commonly used exemptions such 13(a), 13(b), 15, and 15(a).

The European Commission will consider the evaluation report as they make their determination on the EU RoHS exemptions. The eventual European Commission decision may or may not align with the recommendations provided by the Pack-23 evaluation report.

There is currently no expected date for a final decision from the European Commission. For reference, in January 2021, the evaluation report for Pack-22 was published by the Oeko-Institut, and the European Commission has yet to make a decision on those exemptions.

Access the Pack-23 evaluation report here. The twelve exemptions included in the Pack-23 evaluation report are: e 4(f), 8(b), 8(b)(I), 9, 9(a)(II), 13(a), 13(b), 13(b)(I), 13(b)(II), 13(b)(III), 15. 15(a).

EU RoHS Exemptions List available to download

Until a decision is made by the European Commission, any expired exemption that is under review remains in force and is valid to use. But companies should prepare and plan for a time when they can no longer apply such exemptions, as the exemptions could expire as soon as 12 months after the European Commission's exemption review decision if the exemption is not renewed.

GreenSoft Technology 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. You can download the updated EU RoHS Exemptions List here.

Plus, discover how our EU RoHS Data Services and GreenData Manager software can help your company comply with the EU RoHS Directive. Receive a free Risk Analysis when you contact us.

 

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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

Market Access

December 9, 2022 | Written by GreenSoft Technology, Inc.

Product Recalls Due to EU RoHS, EU REACH, and EU POP Violations

Enforcement-Actions4 products removed from European market due to EU RoHS, EU REACH, and EU POP violations

In the fourth quarter of 2022, importers of four products were ordered to recall their products from the European market for failure to comply with the EU RoHS Directive, the EU REACH Regulation, and the EU POP Regulation.

The recalled products include an antenna power supply, a handheld toy vacuum, a PCI card, and an air humidifier.

The EU Safety Gate published the following alerts due to the violations, which are resulting in environmental risk:

 

Antenna Power Supply

Antenna-Power-SupplyDescription:

The solder has an excessive concentration of lead (Pb) (measured value up to 61.4%). Lead poses a risk to the environment.

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:

A12/01366/22


Handheld Toy Vacuum (Electric Insect Trap)

Handheld-vacuum-toyDescription:

The solder has an excessive concentration of lead (Pb) (measured value up to 38.08%). Lead poses a risk to the environment. The plastic wire cape of the toy contains an excessive amount of bis(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), Diisononyl phthalate (DINP) (measured values up to 2.30%, 2.18% and 2.44% by weight respectively). These phthalates may harm the health of children, possibly causing damage to their reproductive system. The product also contains short chain chlorinated paraffins (SCCPs) (measured value 4%). SCCPs persist in the environment, are toxic to aquatic organisms at low concentrations and bioaccumulate in wildlife and humans, posing a risk to human health and the environment.

The product does not comply with the REACH Regulation nor with the Regulation on persistent organic pollutants (POP Regulation).

Regulation Violation(s):

EU REACH Regulation

EU Persistent Organic Pollutants (POP) Regulation

Alert Number/Link:

A12/01479/22


Air Humidifier

Air-humidifierDescription:

The solder has an excessive concentration of lead (measured value up to 32.11%). Lead poses a risk to the environment. The plastic wire cape contains an excessive amount of bis(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), diisobutyl phthalate (DIBP) (measured values up to 3.76%, 1.69% and 0.11% by weight respectively). These phthalates may harm the health of children, possibly causing damage to their reproductive system. The product also contains short chain chlorinated paraffins (SCCPs) (measured value by weight 0.88 %). SCCPs persist in the environment, are toxic to aquatic organisms at low concentrations and bioaccumulate in wildlife and humans, posing a risk to human health and the environment.

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), the Persistent Organic Pollutants (POPs) Regulation nor with the REACH Regulation.

Regulation Violation(s):

EU RoHS 2 Directive

EU REACH Regulation

EU Persistent Organic Pollutants (POP) Regulation

Alert Number/Link:

A12/01480/22


Peripheral component interconnect (PCI) Card

PCI-CardDescription:

The solder joint on the PCI card contains an excessive concentration of lead (measured value 36.0% by weight). Lead poses a risk to the environment.

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 (ROHS2).

Regulation Violation(s):

EU RoHS 2 Directive

Alert Number/Link:

A12/01634/22


As a result of the violations, the importers of all four products were required to withdraw the products from the European market. Additionally, the manufacturer of the antenna power supply was required to warn consumers of the environmental risks.

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

Compliance with EU RoHS, EU REACH, 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 these regulations 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, EU REACH, 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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UKCA Marking

December 7, 2022 | Written by GreenSoft Technology, Inc.

UKCA Mark Deadline Extended 2 Additional Years

UKCA-Mark-Blog-GraphicCompanies now have until December 2024 to meet UKCA compliance requirements

On November 14, the United Kingdom announced that businesses will be given an additional two years to apply the new UK Conformity Assessed (UKCA) product marking requirements.

The new deadline for UKCA marking is December 31, 2024. The deadline had been previously postponed in August 2022.

The UK’s Business Secretary Grant Shapps said the move “will give businesses the breathing space and flexibility they need at this crucial time and ensure that our future system for product safety marking is fit for purpose, providing the highest standard for consumers without harming businesses.”

The announcement cited difficult economic conditions post-pandemic, high energy prices, and international conflict as reasons for the deadline postponement, as the UK government did not want to burden businesses with the requirement to meet the prior deadline of December 31, 2022.

Read the UK government announcement online.

Incremental UKCA mark implementation across the United Kingdom

The UK government will continue to recognize CE marking until the new December 31, 2024 UKCA marking deadline, although businesses may use the UKCA marking before the deadline if they choose.

Businesses may also affix the UKCA marking and include importer information for products from EEA countries on an accompanying document or label until December 31, 2027.

Additionally, conformity assessment activities for CE marking undertaken by December 31, 2024 may be used by manufacturers as the basis for the UKCA marking until December 31, 2027.

Businesses have been able to use the UKCA mark since January 2021 to demonstrate their conformity with product standards in England, Scotland, and Wales. Under the Northern Ireland Protocol, businesses placing goods on the market in Northern Ireland will continue to use CE marking, and will need to use the UKNI marking if they use a UK Conformity Assessment Body to test their products.

To understand more about the UKCA marking requirements, the UKNI marking requirements, and the UK RoHS regulation, visit our Webinar Archive and view our UK RoHS Webinar. Or contact us to learn how GreenSoft Technology helps manufacturers comply with UK RoHS and other environmental regulations.

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SCIP Database

December 6, 2022 | Written by GreenSoft Technology, Inc.

SCIP Database Submissions Now Required in European Economic Area

SCIP-Extends-to-EEA-Blog-GraphicAffected companies in the EEA must now submit reportable SVHCs to the SCIP Database

The obligation to submit notifications to the SCIP Database has been extended to cover companies that supply articles in the European Economic Area (EEA).

Starting November 7, 2022, affected companies placing articles containing reportable Substances of Very High Concern (SVHCs) on the market in Iceland, Liechtenstein and Norway must submit notifications to the European Chemicals Agency (ECHA) online SCIP Database.

The requirement comes as the amendment to the Waste Framework Directive has been incorporated into the EEA Agreement. European Union countries have been required to make SCIP Database submissions since January 2021.

The goal of the public-facing SCIP Database is to enable consumers to make more informed purchasing choices and help waste operators to further develop the re-use of articles and the recycling of materials.

Read ECHA’s announcement of the requirement online.

GreenSoft Technology provides SCIP Database services, software, and education

GreenSoft Technology provides Data Services and Software to help companies comply with the SCIP Database submission requirements.

The SVHC data required for SCIP dossier submissions is significantly higher and more complex than the previous EU REACH requirements. And it can be challenging for affected companies to collect this information due to lack of familiarity with SCIP on the part of suppliers.

Additionally, submitting dossiers to the SCIP online portal contains its own set of challenges, as companies must be familiar with TARIC Codes, SCIP Reference IDs, SCIP Legal Entities, and other portal-related tasks.

GreenSoft Technology’s SCIP solution helps companies with data collection, data processing, and SCIP dossier submissions. Learn more online or contact us to receive a demo.

Plus, access our SCIP FAQ to read helpful lessons that we’ve compiled from our experience submitting SCIP dossiers. And visit the GreenSoft Technology channel on YouTube to see our SCIP Database playlist with educational videos on SCIP submissions and data preparation.

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Webinar

December 1, 2022 | Written by GreenSoft Technology, Inc.

Regulatory Update for Electronics Producers 2023 Webinar

regulatory-update-webinar

Register now to learn everything you need to know for environmental compliance in 2023

Learn what's new and what's changing in 2023 for environmental regulations affecting electronics manufacturers. Get the latest developments and updates to ensure your company is complying with the most recent versions of regulations.

Join regulatory expert Randy Flinders as he provides an overview of the critical updates to environmental regulations including:

  • UKCA Mark (UK RoHS)
  • EU RoHS
  • PFAS
  • And other regulations

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

Space is limited, so register now to save your spot!

Thursday, January 19

2 session times to choose from:

  • 10am Eastern Time/7am Pacific Time/4pm Central European Time - Register Online
  • 2pm Eastern Time/11am Pacific Time/8pm Central European Time - Register Online

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EU REACH

November 29, 2022 | Written by GreenSoft Technology, Inc.

ECHA Launches New Enforcement Project for EU REACH Imports

EU-REACH-Enforcement-ProjectCustoms inspectors will check imports into the European Union for EU REACH compliance in 2023-2025

On November 16, the European Chemicals Agency (ECHA) announced the launch of a new enforcement project for EU REACH.

Ref-12 will investigate how companies fulfil the registration, authorization and restriction obligations for products and chemicals they import from outside the European Union.

The project will be performed in 2023-2025. During that time, national customs authorities will check imported substances, mixtures, and articles* for compliance with EU REACH.

ECHA states that control of imports at the point of entry is the most effective means of checking that non-compliant products do not enter the European market.

In its November meeting, the ECHA Enforcement Forum stated the focus of Ref-12 was triggered by high levels of non-compliance in imported goods detected in previous Enforcement Forum projects, including a recent pilot project. The pilot project found that 23% of imported products are non-compliant with the EU REACH and Classification, Labelling and Packaging (CLP) regulations, and that further controls are necessary.

The Enforcement Forum additionally stated that the Ref-12 project will also work on further developing and strengthening existing cooperation between REACH inspectors and customs.

Read ECHA’s announcement of Ref-12 here.

*Learn the definition of an "article" under EU REACH based on the European Court of Justice “Once an Article, Always an Article“ ruling here.

GreenSoft can help with EU REACH compliance

Compliance with EU REACH is a requirement for affected companies that manufacture or distribute products in the European market. Failure to comply with EU REACH 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 REACH, 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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California Proposition 65

November 8, 2022 | Written by GreenSoft Technology, Inc.

Nearly 100% Increase in California Proposition 65 PFAS Enforcement Notices in October

prop-65Private CA Prop 65 enforcers increasingly targeting PFAS for enforcement actions

On October 26, the National Law Review reported a  nearly 100% increase in the number of enforcement notices targeting PFAS substances regulated under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) during the month of October.

The Office of Environmental Health Hazard Assessment (OEHHA) lists or has proposed to list six types of PFAS as chemicals known to cause cancer or reproductive harm under California Proposition 65: PFOA, PFOS, PFDA, PFHxS, PFNA, and PFUnDA.

The increase in notices filed against companies tend to target PFOA and PFOS substances in products. While PFOA and PFOS have largely been phased out of use in the United States, they continue to be manufactured overseas and are used in products or components used in finished goods that are ultimately sold in the United States.

The most recent notices filed against companies have targeted various home goods and textile products, including umbrellas, shower liners, bath pillows, jackets, bibs, crib mattress pads, and tablecloths.

These notices demonstrate that private enforcers of California Proposition 65 are increasingly targeting PFAS “forever-chemicals” for enforcement actions. Learn more about private enforcement under CA Prop 65 from our short video here.

Read the National Law Review’s full article here.

GreenSoft Technology’s Proposition 65 services can help protect companies from potential enforcement and penalties

Companies subject to the California Proposition 65 regulation are required to inform Californians about exposure to substances on the CA Prop 65 chemicals list before the potential exposure takes place. Penalties for being found in violation of CA Prop 65 can be as high as $2,500 per violation, per day.

With the increase in California Proposition 65 enforcement actions and the exponential penalty amounts, it is essential for business to protect themselves from violation notices and lawsuits.

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

October 6, 2022 | Written by GreenSoft Technology, Inc.

RMI Annual Conference 2022 for Conflict Minerals and Responsible Sourcing

RMIJoin RMI’s biggest event of the year, focused on corporate social responsibility and global supply chains

Join GreenSoft Technology on October 20, 2022 at the Responsible Minerals Initiative (RMI) Annual Conference.

This year's conference theme is "The Next Generation of Due Diligence": focusing on tools and practices to support the expanding scope of due diligence and the evolving definition of responsible minerals.

The event will be held both in-person in Santa Clara, CA and virtually. GreenSoft Technology will be on-site in Santa Clara to talk about our Conflict Minerals solutions with attendees, including our CMRT and EMRT data collection services and Conflict Minerals Module for GreenData Manager (GDM) software.

Conference participants will gain valuable insight on the progress to date from collective efforts and multi-sector stakeholder initiatives as well as updates on legal and regulatory activities, emerging issues and relevant technologies and tools.

Participants will walk away with a deeper understanding of the challenges and opportunities for facilitating responsible minerals trade and what it takes to meet stakeholder expectations and comply with regulations.

Learn more about the event and register to attend here.

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EU RoHS

October 5, 2022 | Written by GreenSoft Technology, Inc.

EU RoHS Enforcement Actions for Q3-2022

eu-rohs8 products removed from European market due to EU RoHS violations

In the third quarter of 2022, importers of eight products were ordered to recall their products from the European market for failure to comply with the EU RoHS Directive.

The recalled products include an electric toothbrush, three digital food thermometers, an antenna power supply, a juice blender, a digital kitchen scale, and a bicycle light set.

The EU Safety Gate published the following alerts due to the violations, which are resulting in environmental risk:


Electric Toothbrush

electric-toothbrush

Description:

The solder in the product has an excessive concentration of lead (measured value up to 55 % by weight). Lead poses a risk to the environment.

The article 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):

RoHS 2 Directive

Alert Number/Link:

A12/00908/22


Digital Food Thermometer (1)

digital-thermometerDescription:

The metal (solder) in the thermometer contains an excessive concentration of lead (measured value up to: 245 g/kg). Lead poses a risk to the environment.

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

Regulation Violation(s):

RoHS 2 Directive

Alert Number/Link:

INFO/00120/22


Digital Food Thermometer (2)

digital-thermometerDescription:

The metal (solder) in the thermometer contains an excessive concentration of lead (measured value up to: 298 g/kg). Lead poses a risk to the environment.

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):

RoHS 2 Directive

Alert Number/Link:

A12/01251/22


Digital Food Thermometer (3)

digital-thermometerDescription:

The metal (solder) in the thermometer contains an excessive concentration of lead (measured value up to 55,2 %). Lead poses a risk to the environment.

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):

RoHS 2 Directive

Alert Number/Link:

A12/01265/22


Antenna Power Supply

Antenna-power-supply

Description:

The solder contains an excessive amount of lead (measured value up to 41,5% by weight). Lead poses a risk to the environment.

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):

RoHS 2 Directive

Alert Number/Link:

A12/01277/22


Juice Blender

juice-blenderDescription:

The solders of the product contain an excessive concentration of lead (Pb) (measured value up to 18%). Lead poses a risk to the environment.

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):

RoHS 2 Directive

Alert Number/Link:

A12/01288/22


Digital Kitchen Scale

digital-kitchen-scaleDescription:

The metal (solder) in the product contains an excessive concentration of lead (measured value up to 6,4%). Lead poses a risk to the environment.

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):

RoHS 2 Directive

Alert Number/Link:

A12/01287/22


Bicycle Light Set

bicycle-light-setDescription:

The product has an excessive concentration of bis(2-ethylhexyl) phthalate (DEHP) and di-n-butyl phthalate (DBP) (measured values up to 9.48% and 0.13% by weight respectively). These phthalates may harm the health of children, causing possible damage to their reproductive system.

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):

RoHS 2 Directive

Alert Number/Link:

A12/01317/22


As a result of the violations, the importers of all eight 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 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 EU RoHS 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, 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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EU RoHS

September 20, 2022 | Written by GreenSoft Technology, Inc.

Two New Substances Proposed to be Added to EU RoHS Directive

eu-rohsEuropean Commission expected to announce inclusion of 2 new substances to EU RoHS Directive by end of 2022

The European Commission is currently reviewing a consultant report by the Oeko-Institut which recommends adding two new substances for restriction under the EU RoHS Directive.

It is expected that the European Commission will agree with the consultant recommendation to include the substances in the EU RoHS Directive. The European Commission is expected to announce their decision by the end of this year.

The two substances are:

  • Medium chain chlorinated paraffins (MCCPs)
  • Tetrabromobisphenol A (TBBP-A)

MCCPs are used in electrical and electronic equipment (EEE) mostly as constituents of PVC insulations for electric cables and wires and other soft plastic or rubber components, including polyurethane, polysulphide, acrylic and butyl sealants.

The primary use of TBBP-A is as a precursor in the production of brominated epoxy resins that function as reactively flame-retarded substrate in printed wiring boards (PWB). It is also used as an additive flame retardant in thermoplastic EEE components, for example housings that consist of ABS plastic.

The path to implementation

The consultant report which recommends to add MCCPs and TBBP-A to the EU RoHS Directive was part of the Pack 15 review, which studied seven substances total. In November 2020, the Oeko-Institut completed the Pack 15 review and issued their final report, which recommended to add these two substances out of the seven total substances under review.

In May 2022, the European Commission launched an official initiative to propose adding the two substances to EU RoHS based on the Oeko-Institut recommendation. It is anticipated that the European Commission will adopt the proposal.

The initiative is expected to be completed in by the end of 2022. At that time, an amendment to the EU RoHS Directive would be published to the Official Journal and the substance additions become official.

The deadlines for implementation for affected companies currently using MCCPs and TBBP-A is still unknown. When four phthalates were added to EU RoHS in June 2015, a period of four years was provided before the restrictions began to take effect. While it is unclear how long affected companies will be given for implementation of these new substance additions, it is expected that some form of implementation period will be provided.

GreenSoft Technology will continue to track the status of the substance additions to the EU RoHS Directive, and will publish updates on our blog.

The new substances are part of RoHS-2

The restriction of MCCPs and TBBP-A under EU RoHS will be adopted as an amendment to the EU RoHS Directive, just as the addition of the four phthalates in June 2015 was adopted as an amendment.

Although the RoHS-2 regulation with the four phthalates is sometimes referred to within the industry as RoHS-3, it is still officially considered the RoHS-2 regulation by the European Commission.

The EU RoHS Directive will remain as RoHS-2 until such time as it is recast by the European Commission, regardless of additional amendments to include new substances.

Such a recast may be coming in the near future, as the European Commission did launch a public consultation period to review the EU RoHS Directive rules in March 2022. Learn more on that review period here.

GreenSoft can help with EU RoHS

GreenSoft Technology provides Data Services and GreenData Manager software to help your company comply with the EU RoHS Directive.

We will collect compliance data on parts and assemblies from your supply chain for you, so that you can show due diligence while still focusing on your core competencies. Compliance and completion reports can be generated for you by GreenSoft Technology, or by using GreenData Manager software.

Learn more and receive a free Risk Analysis when you contact us.

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Webinar

September 19, 2022 | Written by GreenSoft Technology, Inc.

Watch On-Demand: Ask the Experts Webinar

ask-the-expertsEnvironmental Compliance: Ask the Experts webinar now available to view on-demand in the Webinar Archive

On September 15, GreenSoft Technology teamed up with professionals representing perspectives from leading experts in data collection, testing, consulting, and producers to share their knowledge and expertise in our Environmental Compliance: Ask the Experts webinar.

The webinar is now available to watch on-demand in our Webinar Archive and on our YouTube channel.  

Attendees from global electronics manufacturers and other companies had the opportunity to ask questions on EU RoHS, EU REACH, SCIP Database, U.S. Toxic Substances Control Act (TSCA), California Proposition 65, Conflict Minerals and more.

The webinar’s expert panel included:

Watch the recording now in our Webinar Archive to gain valuable insight on regulations affecting electronics manufacturers.

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