French Environmental Labeling Requirements

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

France Implements New Environmental Labeling Decree for Electronics and Other Products

Republique-FrancaiseFrench environmental labeling requirements for consumer products, including electrical and electronic equipment, take effect on January 1, 2023

On April 29, 2022, France published new environmental labeling requirements for waste-generating products intended for consumers.

The requirements, Decree 2022-748, concern producers, importers distributors or other marketers of waste-generating products intended for consumers, including those using a website, a platform or any other online distribution channel as part of their commercial activity in France.  

The types of products targeted by the regulation include electrical and electronic equipment, batteries and accumulators, packaging and packaging products, construction products and materials, passenger cars and vans, motor vehicles with 2 or 3 wheels and motor quadricycles, textile products, and other products such as furnishings, toys, sports and leisure items, and DIY and garden items.

Affected companies are required to provide information on the environmental qualities and characteristics of products and packaging. This includes, but is not limited to, information on the products’ reparability, sustainability, recyclability, and the presence of hazardous substances, precious metals, or rare earth metals.

The deadlines for compliance vary based on company revenue and product type, starting on January 1, 2023 for the largest companies, and with all affected companies being required to comply by January 1, 2025.

Implementation Deadlines

Deadline Conditions

January 1, 2023

Annual revenue > EUR 50 million
Placement on the national market of at least 25,000 units 

January 1, 2024

Annual revenue > EUR 20 million
Placement on the national market of at least 10,000 units

January 1, 2024

Product:

- Building products and materials
- Toys
- Passenger cars, vans, motor vehicles (with 2 or 3 wheels) and motor quadricycles

January 1, 2025

Annual revenue > EUR 10 million
Placement on the national market of at least 10,000 units

Affected companies will be required to make the environmental information available by electronic means and/or by display and labeling. While the decree directs varying labeling requirements at different types of products, producers of electrical and electronic equipment (EEE) must be prepared to address the following specific labeling/information requirements directed at their products, including:

Electrical and Electronic Products
- Product must display a reparability index rating
- Product must display a sustainability index rating (from Jan 1, 2024)
- Product must display details on presence of precious metals
- Product must display details in the presence of rare earth metals
- Product must display % of recycled materials present
- Product must display a warning if dangerous substances are present
- Product must display details on the presence of EU REACH SVHCs
- Product must display details on recyclability status

Packaging used for the import/sale of Electrical and Electronic Products
- Packaging must display “compostable packaging” if packaging is compostable
- Packaging must display % of recycled materials present
- Packaging must display information if it is “Reusable” or “Refillable”
- Packaging must display a warning if dangerous substances are present
- Packaging must display details on the presence of EU REACH SVHCs
- Packaging must display details on recyclability status

Read the full text of the regulation here.

GreenSoft Technology provides data collection services to help companies with the French environmental labeling regulation

Since the implementation of the new French environmental labeling regulation, GreenSoft Technology has already begun to help some of our affected customers with compliance to the regulation.

As part of our Data Services, we will contact your supply chain on your behalf to collect the information required under the regulation, and we will analyze that data for accuracy and completeness.

Our Data Services enable you to generate the appropriate labeling as required under the regulation, so that you can maintain market access to the French market.  

Contact us to learn more about how GreenSoft Technology can help with the French environmental labeling regulation.

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Material Declaration

August 15, 2022 | Written by GreenSoft Technology, Inc.

Updates to the IEC 62474 Declarable Substance List for the Electronics Industry

IEC

IEC 62474 DSL updated to include PFCA substances

On July 18, 2022, the IEC 62474 Declarable Substances List (DSL) was updated to version D25.00.

The IEC 62474 database is an International Standard for the electrical and electronics industry on material declaration that includes the internationally recognized DSL, a material declaration procedure, and an XML-schema for data exchange.  This database is maintained by the IEC TC-111: Environmental standardization for electrical and electronic products and systems.

The IEC 62474 DSL is a list of regulated substances and substance groups which a manufacturer should declare to downstream manufacturers if present in electrical or electronic equipment (EEE). The list is based on global requirements applicable to the EEE industry, and is screened to exclude substances which are not relevant to the electrical and electronic products. 

The IEC 62474 Database version D25.00 update includes:

1.      Addition of two new substance group entries based on the new EU REACH Annex XVII entry 68 to the IEC 62474 database’s Declarable Substances List (DSL):

  • C9-C14 PFCAs and their salts
  • C9-C14 PFCA-related substances

Typical uses of both substance groups include greases, textiles and other coated products, and emulsifiers used for manufacturing Fluoropolymers.

2.      Addition of a non-exhaustive list of discreet reference substances related to the newly added substance groups to the IEC 62474 database Reference Substances List (RSL).

3.      Update of the EU RoHS Annex III exemption list to version 5.0, which includes the addition of recent updates to EU RoHS Annex III exemptions.

4.      Review of N-(hydroxymethyl)acrylamide, which was added to the REACH Substances of Very High Concern (SVHC) Candidate List in June 2022. The substance was deemed not relevant to the EEE industry for the purpose of material declaration and was screened out by the IEC 62474 Validation Team. As a result, the substance was added to the IEC 62474 database complementary list (not to the DSL).

Companies using the IEC 62474 DSL to communicate substance data across the supply chain should ensure they are referencing the latest addition of the DSL, which can be accessed here.

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Webinar

August 4, 2022 | Written by GreenSoft Technology, Inc.

Environmental Compliance: Ask the Experts Webinar

 

Bring your questions on EU RoHS, EU REACH, SCIP, TSCA, Prop 65 and more to this live webinar

Ask-the-Experts_webinar

Get ready for an exciting new opportunity to ask industry experts your questions on environmental regulations!

GreenSoft Technology has teamed up with professionals from across the electronics and regulation industries, including manufacturers, test laboratories, consultants, and solution providers, to share their knowledge and expertise with you.

Bring your questions to the Environmental Compliance: Ask the Experts webinar on Thursday, September 15 to gain valuable insight on regulations affecting electronics manufacturers, including 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 includes:

Register now to save your spot!

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

Thursday, September 15

11:00am Pacific Time (US and Canada)/2:00pm Eastern Time (US and Canada)/20:00 Central European Summer Time

Register online

 

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Full Material Declaration (FMD)

August 2, 2022 | Written by GreenSoft Technology, Inc.

Your Guide to Full Material Declaration (FMD)

 

FMD-webinar-thumbnailWatch on-demand: The Essential Guide to Full Material Declaration (FMD) webinar

Learn the best practices for maintaining Full Material Declaration (FMD) data on your products from our educational videos.

GreenSoft Technology recently hosted an FMD webinar which is now available to view in our Webinar Archive.

Discover the benefits of FMD data, best practices for incorporating FMD data into your product environmental compliance strategy, and how to leverage FMDs as evidence of compliance on California Proposition 65, EU POP, EU Medical Devices Regulation (MDR), U.S. Toxic Substances Control Act (TSCA), and any other required regulations in addition to standard EU RoHS and EU REACH regulations.

View the full-length webinar on-demand in our Webinar Archive.

Plus, highlights from the webinar are now available to view on YouTube.  Our FMD playlist on YouTube covers topics including:

View the full playlist on YouTube.

Coverage for complex regulations and proprietary substances

GreenSoft Technology provides FMD processing as part of our Data Services. With FMD data, you can not only validate your products for common regulations such as EU REACH and EU RoHS, but you can also validate for other regional regulations such as California Proposition 65, the US Toxic Substances Control Act (TSCA), the EU Medical Devices Regulation (EU MDR), automotive industry IMDS requirements, and unique customer requirements.

FMD data can even be used when parts contain proprietary substances. Whether your suppliers provide partial or complete disclosure, GreenSoft Technology's FMD processing services can validate the non-compliance on your products based on the partial disclosure or FMD with proprietary substances.

Learn more about our FMD data solution online.

 

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EU POP

June 28, 2022 | Written by GreenSoft Technology, Inc.

New Substance Additions Proposed for EU POP Regulation

ECHA

Provisional deal to add 6 substance groups to list of restricted substances under EU POP agreed upon

On June 21, the European Council and the European Parliament reached a provisional deal to add new chemical restrictions to the EU Persistent Organic Pollutant (POP) regulation.

The proposed regulation aims to bring the EU’s legislation into line with its international commitments, particularly under the Stockholm Convention on Persistent Organic Pollutants.

To achieve this, it will add some substances to annex IV of the POP Regulation (Regulation (EU) 2019/1021 on persistent organic pollutants) and update the concentration limit values for some substances in annexes IV and V of that regulation.

The proposal concerns mainly the following substances:

  • Perfluorooctanoic acid (PFOA) and its salts and related compounds – found in waterproof textiles and fire-fighting foams
  • Polybrominated diphenyl ethers (PBDEs) – flame retardants found in plastics and textiles used in electrical and electronic equipment, vehicles and furniture;
  • Hexabromocyclododecane (HBCDD) – flame retardant found in some plastic and textile waste, particularly in polystyrene insulation from demolition of buildings;
  • Short-chain chlorinated paraffins (SCCPs) – flame retardants found in some rubber and plastic waste, such as rubber conveyor belts, hoses, cables and seals;
  • Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/Fs) – these substances are not produced or added to materials intentionally but are present as impurities in certain ashes and in other industrial waste;
  • Dioxin-like PCBs – similar to dioxins, these PCBs can be present as impurities in some ashes and industrial oils. Limits for these specific PCBs are proposed, together with those for dioxins.

The agreed upon deal will now be submitted for endorsement by the Committee of permanent representatives, and a formal adoption procedure will then be launched.

A press release of the announcement can be found here.

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EU REACH

June 13, 2022 | Written by GreenSoft Technology, Inc.

One Substance Added to EU REACH SVHC List

EU-REACHEU REACH SVHC List now contains 224 Substances

On June 10, the European Chemicals Agency (ECHA) announced the addition of 1 chemical to the EU REACH Substances of Very High Concern (SVHC) Candidate List.

N-(hydroxymethyl)acrylamide (EC No. 213-103-2; CAS No. 924-42-5) has been added to the EU REACH SVHC Candidate List as it may cause cancer or genetic defects. It is mostly used in polymers and when manufacturing other chemicals, textiles, leather or fur. It is not likely to be present in electrical or electronic products.

The EU REACH SVHC Candidate List now has 224 entries, though some entries are groups of chemicals so the overall number of impacted chemicals is higher. The last prior addition to the SVHC list was SVHC-223 in January 2022.

ECHA’s announcement of the additions can be found here. The full SVHC list can be found here.

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 notifications and notifying ECHA through submissions to the SCIP Database.

GreenSoft can help with EU REACH compliance

The EU REACH SVHC List is typically updated twice per year, resulting in affected companies needing to re-evaluate their product compliance and possibly re-collect substance data from their suppliers.

GreenSoft helps manage this process for companies, including coverage for the SCIP Database, by performing data collection, data validation, substance calculations and report generation as part of our EU REACH data services.

Learn more about how our EU REACH data services can help your company with EU REACH compliance by contacting us.

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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.

Market Access

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

EU RoHS & EU POPs Enforcement Actions for Q2-2022

6 products removed from market due to EU RoHS and EU POPs violations

eu-rohsIn the second quarter of 2022, importers of six products were ordered to recall their products from the European market for failure to comply with the EU RoHS Directive and/or the EU Persistent Organic Pollutants (POPs) Regulation.

The recalled products include two power supply modules, two battery operated children’s toys, an LED light, and an antenna amplifier.

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


LED Light

led-lightDescription:

The solder contains an excessive concentration of lead (measured value: up to 10.66 % by weight). Lead poses a risk to the environment. The plastic cord contains SCCPs (measured value: at least 0.43 % by weight). 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 plastic cord also contains an excessive concentration of bis(2-ethylhexyl) phthalate (measured value: 1.8 % by weight). DEHP may harm the health of children, causing possible damage to their reproductive system.

Regulation Violation(s):

RoHS 2 Directive

POPs Regulation

Alert Number/Link:

A12/00788/22


Battery Operated Car Track

car-toyDescription:

The solder contains an excessive amount of lead (measured value up to 73.5% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

RoHS 2 Directive

Alert Number/Link:

A12/00802/22


Battery Operated Toy Train

toy-trainDescription:

The solder contains an excessive amount of lead (measured value up to 85.9% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

RoHS 2 Directive

Alert Number/Link:

A12/00805/22


Antenna Power Supply Amplifier

Antenna-Power-Supply-AmplifierDescription:

The solders contain an excessive amount of lead (measured value up to 40.89% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

RoHS 2 Directive

Alert Number/Link:

A12/00806/22


Antenna Amplifier

Antenna-AmplifierDescription:

The solders contain an excessive amount of lead (measured value up to 54.9%). Lead poses a risk to the environment.

Regulation Violation(s):

RoHS 2 Directive

Alert Number/Link:

A12/00807/22


Power Supply with Power Supply Separator

Power-Supply-SeparatorDescription:

The solders contain an excessive amount of lead (measured value up to 33.9% by weight). Lead poses a risk to the environment.

Regulation Violation(s):

RoHS 2 Directive

Alert Number/Link:

A12/00808/22


As a result of the violations, the importers of all six 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 POPs are requirements 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 provides Data Services to help your company comply with EU RoHS and EU POPs, 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 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

California Proposition 65

May 31, 2022 | Written by GreenSoft Technology, Inc.

California Proposition 65: Warning Label Changes to Undergo New Proposal

prop-65

Rulemaking timeframe lapses for CA Prop 65 proposed changes to warning labels; new proposal process to begin soon

California’s Office of Environmental Health Hazard Assessment (OEHHA) will restart a rulemaking process to evaluate proposed amendments to warning label requirements under the state’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).

The proposed rulemaking to amend the regulation related to short-form Proposition 65 warnings was initially due to be completed in January 2022. That timeframe was extended by 120 days due to the COVID-19 pandemic. However, even with the additional time provided, OEHHA was unable to complete the regulatory process within the allotted time.

Now that the rulemaking time period has lapsed, OEHHA intends to restart the rulemaking process on the short-form warning labels with a new regulatory proposal in the next several weeks. The new proposal will be informed by comments on the previous proposal, and a public notice and opportunity to comment on the new proposal will be provided.

Read the full notice from OEHHA here.

GreenSoft Technology provides help with California Prop 65

GreenSoft Technology will continue to track updates from OEHHA, and will alert our readers via our blog when the new rulemaking proposal is published and when the final decision is made.

Visit our website to learn about our California Proposition 65 Data Services, including supply chain data collection, validation and reporting. Contact us to learn more.

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PFAS

May 23, 2022 | Written by GreenSoft Technology, Inc.

PFAS Restrictions Facing Electronics Producers

PFASManufacturers face various proposals restricting PFAS “Forever Chemicals” in the US and EU

Concern over the dangers of Per- and polyfluoroalkyl substances, or “PFAS,” have increased exponentially in recent years.

These substances, often called “forever chemicals,” have become a popular topic in the media. And government bodies around the globe are racing to implement PFAS restrictions.

However, the nature of PFAS substances makes regulating the chemicals a complicated task, and will make the effort to comply with such regulations difficult for manufacturers.

GreenSoft Technology has published a series of educational videos on YouTube addressing the concerns and current status of PFAS restrictions around the globe. View the full paylist online.

What are PFAS "Forever Chemicals"? Where can you find a list of PFAS substances?

The term “PFAS” refers to a class of chemicals rather than a specific chemical or mixture. This makes PFAS difficult to define specifically, but the Organisation for Economic Co-operation and Development (OECD) has identified the primary distinguisher for PFAS as “a fluorinated substance that contains at least one fully fluorinated methyl or methylene carbon atom."

The nature of PFAS also makes it difficult to compile a list of PFAS substances. The OECD has identified and listed over 4,700 PFAS chemicals, while the US Environmental Protection Agency (EPA) has identified and listed over 12,000 PFAS chemicals.

PFAS substances are referred to as “forever chemicals” because they break down very slowly and accumulate in the environment and in human tissue, specifically the liver. PFAS has been detected in drinking water, food supplies, and even in newborn babies.

View or share the “What are PFAS ‘Forever Chemicals?’” video here.

PFAS restrictions facing electronics manufacturers

While currently there are no active PFAS restrictions directed at electronics producers, there are various regulatory approaches in development around the globe that could affect electronics producers in the future.

Until now, most legislative activity related to PFAS has been focused on drinking water PFAS limits and the removal of PFAS from firefighting foams. Newer restrictions have also been directed at food contact products and cosmetics.

But research and analysis of potential PFAS restrictions are ongoing globally, including in the EU, in US at the federal level, and in the US at the state level. Notably, there is a new proposal in the EU to place restrictions on all PFAS substances entirely (excluding essential uses).

The proposals have taken various approaches. Some aim to restrict a single substance (i.e.  PFOS), others aim to restrict a group of PFAS substances (i.e. non-polymeric PFAS), and others aim to restrict all PFAS as a substance group (with exceptions for essential use).

View or share the PFAS Restrictions Facing Electronics Manufacturers video here.

PFAS restrictions in the European Union

There are multiple existing restrictions on PFAS in the EU stemming from various regulations. The PFAS substances restricted or pending restriction under EU REACH, EU POPs, or the Stockholm Convention include: PFOS, PFHxS, PFOA, C9-C14 PFCAs, PFHxA, HFOP-DA (Gen X), and PFBS.

Additionally, more restrictions are being proposed or reviewed:

  • Some PFAS are currently undergoing REACH substance evaluation or have a harmonized classification under the CLP regulation.
  • A dossier was submitted to the European Chemicals Agency (ECHA) in January 2022 to ban the use of PFAS in firefighting foams.
  • 5 EU member states (Netherlands, Denmark, Germany, Norway, and Sweden) have proposed a broad ban on all PFAS usage excluding “essential uses” (which have yet to be defined). A final dossier is expected to be submitted in July 2023.
  • A proposed restriction on PFHxA by Germany is now moving forward.

View or share the PFAS Restrictions in the European Union video here.

PFAS restrictions in the United States

Currently, there are no specific PFAS restrictions or regulations at the federal level in the US. However, the EPA has issued a “PFAS Strategic Roadmap” to outline the actions that it will take to address the risks of PFAS usage, including:

  • Publish a national PFAS testing strategy. (Released October 2021)
  • Ensure a robust review process for new PFAS. (Efforts ongoing)
  • Review existing PFAS under the Toxic Substances Control Act (TSCA). (Expected Summer 2022 and ongoing)
  • Enhance PFAS reporting under the Toxics Release Inventory. (Expected Spring 2022)
  • Finalize new PFAS reporting under TSCA Section 8. (Expected Winter 2022)

At the state level, 20 US states have enacted PFAS drinking water standards as of March 1, 2022, and 6 states have pending PFAS drinking water standards. The water standards are not universal, so each state’s restrictions have different chemical and threshold limits.

As of this time, there are no specific regulations directed at consumer or electronic products. However, California and Washington have introduced legislation to ban PFAS in cosmetics, with six other states looking to follow. And California has added or is considering adding the following PFAS chemicals to the California Proposition 65 substances list: PFOS, PFOA, PFDA, PFHxS, PFNA, and PFUnDA.

View or share the PFAS Restrictions in the United Sates video here.

Summary

While electronics producers are not yet directly targeted by regulations on PFAS substances, future restrictions seem likely if the current trend continues.

Compliance with such regulations will be complicated due to the difficult to define nature of PFAS chemicals, and the varying and inconsistent approaches from government bodies.

GreenSoft Technology has already begun to help our customers compile their own lists of PFAS chemicals to track in their products as part of our Data Services.

We will keep a close eye on PFAS regulatory developments around the globe, and will post updates to our blog. Be sure to subscribe to our blog to receive updates in your email inbox.

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Conflict Minerals

May 17, 2022 | Written by GreenSoft Technology, Inc.

New Conflict Minerals Reporting Template Version Released

RMI-vendor-memberCMRT 6.22 now available for download

The Responsible Minerals Initiative (RMI) organization has released an updated Conflict Minerals Reporting Template (CMRT) version: CMRT 6.22.

CMRT forms are used to exchange conflict minerals data across the supply chain in order to comply with the US Conflict Minerals regulation.

CMRT forms are typically updated once per year by the RMI organization. The last major CMRT update was version 6.1 in April 2021, and RMI anticipates the next version will be released in Spring 2023.

RMI recommends using version CMRT 6.1 or higher for current reporting year declarations.

The major changes in CMRT 6.22 from CMRT 6.1 include:

  • Correction to the version number on the template
  • Corrections to bugs and errors
  • Updated Smelter Reference List and Standard Smelter List
  • Translation Improvements

The new CMRT 6.22 can be downloaded here.

Note: CMRT 6.22 was released on May 11, 2022. A previous version, CMRT 6.21 was released on May 6, 2022, but contained an incorrect version number on the template, and an additional previous version, CMRT 6.2, was released on April 27, 2022, but contained smelter list tab errors. The RMI organization has corrected the errors in the updated CMRT 6.22 version.

Get Help with CMRT Collection and Conflict Minerals Compliance

GreenSoft can manage conflict minerals compliance for you as part of our Conflict Minerals data services or Turnkey Service. We provide CMRT gathering, validation, and review for your Reasonable Country of Origin Inquiries (RCOIs). We also offer Smelter or Refiner (SOR) Validation.

Our Conflict Minerals Module for GreenData Manager software generates Conflict Minerals reports quickly and easily.

For customers already using GreenSoft’s Conflict Minerals data services or Turnkey Service, our data services team will prepare to start using CMRT 6.22 for data collection going forward.

For customers using our GreenData Manager software Conflict Minerals Module, our software development team will begin preparations to update the software for CMRT 6.22.

If you are not yet a GreenSoft customer, contact us today to learn about our Conflict Minerals data services and software and we’ll provide you with a free Risk Analysis!

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Webinar

May 16, 2022 | Written by GreenSoft Technology, Inc.

Watch on Demand: Regulatory Update for Electronics Producers Webinar

regulatory-update

Watch now in our Webinar Archive to get the latest updates on critical regulations for manufacturers

The Regulatory Update for Electronics Producers webinar is now available to view on-demand in our Webinar Archive.

Multiple changes are in the works for regulations affecting electronics producers.

During this educational webinar, host Randy Flinders, Compliance Specialist for GreenSoft Technology, provides viewers with all the latest updates including:

  • California Proposition 65: Short-form warning label changes
  • EU RoHS: Exemption statuses for common exemptions such as 6c, 7a, 7c1
  • PFAS: A summary of various PFAS “forever chemicals” regulations around the globe
  • TSCA: Deadline changes for the US Toxic Substances Control Act (TSCA)
  • And other regulatory updates.

Plus, attendees were able to ask Randy their questions during a live Q&A session, which are answered in the recording.

Watch the webinar today in our Webinar Archive.

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EU Green Deal

April 28, 2022 | Written by GreenSoft Technology, Inc.

EU Announces Largest Ever Restriction of Toxic Chemicals

european-commission

Roughly 5,000 to 7,000 chemicals will be regulated in the EU by 2030

On April 25, the European Commission released its plan to enact the largest ever restriction on toxic chemicals as part of the zero-pollution goal of the EU Green Deal.

The plan, called the Restrictions Roadmap, is a staff working document prepared by the European Commission services and does not necessarily represent the views of the European Commission. It is in no way legally binding, but rather provides a view into future EU environmental compliance policy. Implementing the Roadmap will require the joint commitment and collaborative efforts of Member States, the European Commission, and the European Chemicals Agency (ECHA).

The roadmap outlines plans to use existing laws to review and implement restrictions for large substance categories, such as all flame retardants and bisphenols, as well as all forms of PVC. It will also direct resources to apply restrictions on PFAS ‘forever chemicals’, along with around 2,000 other harmful chemicals.

In total, the European Environmental Bureau (EEB) has estimated the Restrictions Roadmap will lead to the restriction of roughly 5,000 to 7,000 chemicals by 2030.  Some chemicals on the Restrictions Roadmap list were already facing EU restrictions, but most are new.

‘The Sick Six’ chemical groups to be restricted

The Restrictions Roadmap will use a group approach to regulating chemicals, in which the most harmful member of a chemical family defines legal restrictions for the whole family. That should end an industry practice of tweaking chemical formulations slightly to evade restrictions, according to the EEB.

The EEB singles out 6 groups of chemicals that it dubs the ‘Sick Six’. These have two things in common: they are highly hazardous but still widely used in European consumer goods.

The ‘Sick Six’ chemicals to be restricted are:

  • Polyvinyl Chloride (PVC) and its additives

PVC is commonly used in used in a very wide range of products, from toys and inflatable products (pools, water sports accessories, trampolines) to packaging and food contact materials, such as food wraps, to artificial Christmas trees, textiles like ‘vegan leather’, furniture, shoes, building materials, etc.).

  • PFAS (non-essential uses)

PFAS are commonly used in a wide variety of consumer items, from takeaway and other food packaging to non-stick coatings, stain-free and waterproof clothes to sun-cream and cosmetics, even dental floss.

  • Bisphenols, including BPA

BPA is found in a wide range of consumer goods, such as sports equipment, CDs, DVDs, automobile parts and food containers, such as reusable beverage bottles and reusable plastic tableware.

  • Flame retardants

These chemicals are required by law to be used in a broad range of household goods, including childcare products (such as crib mattresses), furniture (e.g. children’s high chairs) and textiles (e.g. car seats), building materials and electronics “to delay fires”. However, they have a dubious record of actually slowing fire.

  • Chemicals in childcare products that cause cancer, genetic mutation or harm the reproductive system (CMRs)

CMRs are commonly used in baby/children’s pacifiers, teething toys, bathing products, general body care products (such as baby soaps, shampoos or creams), feeding products (such as children kitchenware or cutlery), etc.

  • Toxic chemicals in single use nappies / diapers

Most of the paper pulp used for manufacturing baby nappies comes from the US and is highly contaminated, a problem known by industry. It is the same pulp used in menstrual products and incontinence nappies.

Next steps for the regulations

The Restrictions Roadmap is a political commitment; its implementation will require the joint commitment and collaborative efforts of Member States, the European Commission, and ECHA.

The Restrictions Roadmap seeks to leverage the pre-existing authority of the REACH Regulation to accomplish its stated goals. The proposed group approach to regulating chemicals requires changes to the REACH Regulation and product laws, which the European Commission has proposed to be in place by between 2025 – 2027. Details on the timeline for proposed REACH regulation changes can be found here.

Member states and the European Commission will examine each proposed chemical ban in detail. If either decides to take a restriction forward, it will then be submitted to the ECHA for the agency’s scientific opinion.

This opinion then goes to the European Commission for a decision on whether to approve or reject it. This decision still needs to then be approved through an anonymous, qualified majority vote by member state officials who are part of an opaque body called the REACH Committee, which is formally part of the European Commission.

The committee’s decisions can be vetoed by the European Parliament or the European Council, but this power is rarely used. Once approved, the ban will likely have a “transition period” of months or years before coming into force.

More details on the Restrictions Roadmap announcement and the ‘Sick Six’ chemicals to be restricted can be found here.

 

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