Green Market Update for Electrical and Electronics: How to Build a Green Strategy for Your Company and Supply Chain

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Gladys Morris
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1 Green Market Update for Electrical and Electronics: How to Build a Green Strategy for Your Company and Supply Chain Joel Pekay Global Marketing and Business Development Director Health and Environment September 2010

2 Our Industries Our organisation Industries we operate in What we do Supporting our customers in their global trade Our organisation The industries we operate in What we we do do Aerospace & Automotive Consumer Goods Building Products Chemical Commercial & Electrical Consumer Goods & Retailers Electrical & Electronic Oil, Chemical & Agri Energy Food & Agriculture Analytical Services Government & Institutions IT & Telecom Industrial Services Industrial Medical & Pharmaceutical Minerals Petroleum Toys, Games & Hardlines Textile, Apparel & Footwear Testing Inspection Certification Auditing Outsourcing Advisory Quality Assurance

Health and Environment Intertek offers complete solutions for health and environmental compliance for global, regional or local compliance, providing sound traceability systems and strict enforcement

3 Health and Environment Intertek offers complete solutions for health and environmental compliance for global, regional or local compliance, providing sound traceability systems and strict enforcement of due diligence policies. Our solutions offer comprehensive services including on-call consulting, product testing and analysis, legal representation, certification and corporate education appropriate for all types and levels of business. Product Safety, Risk Assessment Global Chemicals Notification and Use Registrations Restricted Substances and Substances of concern Life cycle assessment / GHG emission reduction Design for the environment / End of life / Waste

4 Challenge, Opportunity, and Advantage Restricted substances Substances Competitive of concern Advantage Business/Association Protect the Brand defined limits Environmental Compliance Green Minimize house business gas emissions impact Carbon due to foot non-compliance printing Design for the Environment End of life Waste Green = Customer Choice

5 Effects of Global Regulatory Requirements Global CPSIA Green Convergence

6 Effect of Global Legislation CPSIA EU EU RoHS Proposition China RoHS REACH CO2 CO2 Emissions Korean RoHS

7 Eco Trends REACH Restricted Substances Carbon Reduction Green Packaging Green Building Sustainability Reporting Waste Management Greenhouse Gas Reductions Alt./Renew Energy Recycling Eco Convergence Energy Efficiency Water Footprint

8 Addressing Green Convergence Testing Strategy Supply Chain Management Inspection/Auditing Certification Eco Management Systems Compliance Assurance Systems Management Eco Labels/Marks Eco Management Certification

9 Global

10 Green Claim versus Green Washing Green Claims are any self-declared statements, symbols or graphics that: 1. Refer to an environmental aspect of a product, a component or product packaging; 2. Are made on products, on product packaging, in product literature or advertisements. In terms of regulation, Green Claims are generally governed by marketing and consumer protection legislation as opposed to environmental or product compliance legislation.

Principle Requirements of a Green Claim Green Claim was not observed to conflict with any legislation in the countries identified Green Performance Criteria is applicable to market space of product

11 Principle Requirements of a Green Claim Green Claim was not observed to conflict with any legislation in the countries identified Green Performance Criteria is applicable to market space of product The product or claim is exceptional to the marketplace The Green Performance Criteria is a valid environmental or green performance attribute Any values used in the Green Claim are clear and unambiguous Green Claim used plain language An ordinary member of the public would reasonably be expected to understand the Green Claim Symbol for Green Claim is clear and unambiguous (if symbol is being used for the Green Claim) Can be substantiated

12 Europe

REACH SVHCs 38 current substances on the SVHC list managed by the REACH Regulation Ensure that Supplier(s) have provided a disclosure statement to Retailer for articles that contain 0.

13 REACH SVHCs 38 current substances on the SVHC list managed by the REACH Regulation Ensure that Supplier(s) have provided a disclosure statement to Retailer for articles that contain 0.1% or more of an ECHA listed SVHC Provide disclosure to consumer within 45 days of request for information on presence of an ECHA listed SVHC in concentration of 0.1% or more in products Confirm REACH registration compliance on all products that contain chemical substances in volumes of 1 tonne or more per year prior to trading the product within the EU.

14 EU RoHS Restricted Substances Lead Hex. Chromium Mercury Cadmium PBB PBDE RoHS Limits 1000 ppm 1000 ppm 1000 ppm 100 ppm 1000 ppm 1000 ppm

RoHS Update Addition of medical devices and monitoring equipment to compliance categories in 2014 In-vitro diagnostic medical devices in 2016 Industrial monitoring and control equipment in 2017 CE

15 RoHS Update Addition of medical devices and monitoring equipment to compliance categories in 2014 In-vitro diagnostic medical devices in 2016 Industrial monitoring and control equipment in 2017 CE Marking The CE marking certifies that a product has met EU consumer safety, health or environmental requirements If you apply a CE Mark, you must also be RoHS compliant The CE marking process requires completing a declaration of conformity. RoHS has just been added as one of the conditions that triggers the CE marking process. Review and consideration of additional substances for compliance Brominated and Chlorinated Flame Retardants Phthalates PVC Nanomaterials

WEEE/Batteries/Packaging Directives Three Directives requiring registration for electronics, batteries and packaging All three products must be manufactured to permit reuse or recovery when they

16 WEEE/Batteries/Packaging Directives Three Directives requiring registration for electronics, batteries and packaging All three products must be manufactured to permit reuse or recovery when they become waste Recovery includes the recycling of packaging materials, separate composting of biodegradable packaging, and energy recovery through incineration Restrictions for electronics through RoHS Directive Restrictions in Batteries for Pb, Cd, HG Restrictions in packaging for Pb, Cd, Hg, and Cr6+ Registration in each country Reporting in each country Marking and Labeling Treatment/Disassembly Instructions

17 Asia

18 China RoHS Administrative Measure on the Control of Pollution Caused by Electronic Information Products (EIP) EIP selling in the China market, excluding export and military products Regulates same Restricted Substances as EU Directive: Pb, Cd, Hg, Cr VI, PBB and PBDE Standards Establishment Catalogue Management Cell-phone, telephone sets, and printers

19 North America

third party testing requirements Strengthens the authority to recall and provide notices, and increases potential

20 Consumer Product Safety Improvement Act Federal law Revised limitations on lead in surface coatings and paint, lead in substrates, and prohibition on sale of certain products containing specific phthalates Mandatory toy standards and third party testing requirements Strengthens the authority to recall and provide notices, and increases potential penalties and fines Gives the state attorney s general authority enforce the legislation. May be extended to other consumer products

21 CPSIA Requirements

The Safe Drinking Water and Toxic Enforcement Act: Proposition 65 No person in the course of doing business shall knowingly and intentionally expose any

22 The Safe Drinking Water and Toxic Enforcement Act: Proposition 65 No person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning to such individual.

California Proposition 65 Today 850+ chemicals on current list 250 have Safe Harbor Limits Warning Labels Causing chemicals are present in the product, presumably exceeding the defined safe level.

23 California Proposition 65 Today 850+ chemicals on current list 250 have Safe Harbor Limits Warning Labels Causing chemicals are present in the product, presumably exceeding the defined safe level. A proposition 65 warning means one of two things: The business has evaluated the exposure and has concluded that it exceeds the no significant risk level The business has chosen to provide a warning simply based on its knowledge about the presence of a listed chemical without attempting to evaluate the exposure.

24 CA RoHS Restriction of Hazardous Substances (RoHS) Limit the amounts of certain hazardous heavy metals in specific waste electronic devices so that those metals never find their way into landfills where they can be released into the environment Modeled after the EU s RoHS Directive which bans certain hazardous substances from electrical and electronic equipment Effective January 1, 2007

25 CA RoHS Limits Restricted Substances Lead Hex. Chromium Mercury Cadmium RoHS Limits 1000 ppm 1000 ppm 1000 ppm 100 ppm

26 CA RoHS Applicability Anyone who sells or offers for sale a covered electronic device in California including Manufacturers Distributors Wholesalers Retailers Covered Electronic Device A video display device with a screen greater than four inches, measured diagonally.

CA RoHS Examples Cathode ray tube containing devices (CRT devices) Cathode ray tubes (CRTs) Computer monitors containing CRTs Laptop computers with liquid crystal

27 CA RoHS Examples Cathode ray tube containing devices (CRT devices) Cathode ray tubes (CRTs) Computer monitors containing CRTs Laptop computers with liquid crystal display (LCD) LCD containing desktop monitors Televisions containing CRTs Televisions containing LCD screens Plasma televisions Portable DVD players with LCD screens

CA RoHS Exclusions A video display device that is a part of a motor vehicle including replacement parts for use in a motor vehicle A video display device that is contained within or a part of a piece

28 CA RoHS Exclusions A video display device that is a part of a motor vehicle including replacement parts for use in a motor vehicle A video display device that is contained within or a part of a piece of industrial, commercial, or medical equipment, including monitoring or control equipment A video display device that is contained within a clothes washer, clothes dryer, refrigerator, refrigerator and freezer, microwave oven, conventional oven or range, dishwasher, room air-conditioner, dehumidifier, or air purifier

29 CA RoHS Requirements Compliance with Maximum Concentration Values Manufacturers are required to submit an annual report to the California Board of Equalization General Information (e.g., name, address, phone no, contact person) Estimated amount of covered electronic devices sold during previous year Content for Cadmium, Lead, Mercury and Hexavalent Chromium including their alloys and compounds and PBBs used. Manufacturers are required to submit an annual report to The California Integrated Waste Management Board on or by July 1st every year.

30 E-Waste Legislation California Electronic Waste Recycling Act Cell Phone Takeback and Recycling Rechargeable Battery Takeback and Recycling Connecticut Hawaii Illinois Indiana Maine Maryland Michigan Minnesota Missouri New Jersey New York City North Carolina Oklahoma Oregon Rhode Island Texas Virginia Washington West Virginia Wisconsin

31 Other Disposal Bans or Studies Arkansas Massachusetts Montana New Hampshire New Mexico Rhode Island Canada E-Waste Legislation Alberta British Columbia Nova Scotia Saskatchewan Manitoba New Brunswick Quebec Canada DEHP and BPA Reporting Mandate

32 Compliance

33 Steps to an Eco-Advantage 1. Identification of applicable requirements Market and customer drivers Regulatory requirements Creation of an RSL (if necessary) 2. Compliance Assurance Process implementation and certification 3. Employee and vendor communication and training 4. Supplier data collection Collect existing data If discrepancy with the requirement, identification of applicable alternative (if available) 5. GAP Analysis and Risk Assessment 6. Product re-engineering (if required) 7. Product screening and testing based upon GAP/Risk Assessment 8. Green claims verification/certification, product labeling, and marketing launch Ongoing compliance assurance

34 Sample Approach: Proposition 65 Step 1: Product Assessment and Risk Analysis Identify all responsibilities associated with the product and include a strategy that will assist in meeting the requirements specific to the determined responsibilities. Review California Proposition 65 list of restricted substances Review Product Information provided by Client Assess areas of risk for California Proposition 65 substances Prepare Client California Proposition 65 Positional Statement Strategy Guide and plan for California Proposition 65 Toxicologist Risk Assessment & Test Recommendations Step 2: Product screening and testing Based on the risk assessment, conduct product screening (XRF) or chemical testing Step 3: Exposure Assessment and Safe Harbor Level Development (as necessary)- Assess the potential exposure to chemical hazards presented in a product.

35 Product Certification Program for Suppliers 1. Documentation Review BOM s Drawings Material Declarations Test Reports Certificates of Conformance 2. Process Audit Verify manufacturing processes related to RoHS compliance Indentify High Risk Materials 3. Lab Testing High Risk Materials that can not be verified using XRF, sent to lab for testing 4. Product Certification

36 In Summary We can help customers: address complex scientific issues design and execute safety and efficacy assessment programs develop and execute global regulatory approval strategies resolve regulatory compliance dilemmas Targets Actions Processes Controls

Consumer Product Safety Improvement Act. Model Toxics in Packaging Legislation. Proposition 65 Safe Drinking Water and Toxic Enforcement Act of 1986

Consumer Product Safety Improvement Act Model Toxics in Packaging Legislation Proposition 65 Safe Drinking Water and Toxic Enforcement Act of 1986 Who needs to comply with CPSIA of 2008 regulation? All