Comparative study of multifunctional device (MFD)

Transcription

1 Comparative study of multifunctional device (MFD) Thai Green Label (TH) TGL-37-R2-15_Printers Green Choice Philippines (PH) GCP_ _Multi function printing device (MFPD) Remarks on identifying common core criteria Open questions Status revised in 2015 valid since Scope The criteria for printers covers products that creates pictures on printing materials, which receives information from a single user or networked computer or other input equipment (such as digital camera). The printer is dependent on electrical energy sources. The criteria also include multifunction printer with printing function as the main function. The criteria are applicable to Multi-function Printing Devices. Scope is similar for both countries. Alignment is possible. 2. Quality/ safety (1) 4.1 The product s safety standard must be certified or tested as required by TIS 1561: Information technology equipment safety or IEC : Information technology equipment -Safety- P.1: General requirements or EN : Information technology equipment -Safety- P.1: General requirements or certified by the equivalent test. Sampling methods for products shall comply with the product s relevant Standards Verification: certificate of compliance or test reports according to the mentioned standards Quality Performance The product shall comply with the performance requirements of the relevant Philippine National Standard for its intended application in Table 1 or the product meets any other internationally accepted. Standard PNS IEC :2005 PNS ISO/IEC :2003 PNS ISO/IEC :2003 Title Information Technology Equipment Safety Part 1: General Requirements Information technology Office Equipment Minimu information to be included in specification sheets Printers Part 1: Class 1 and Class 2 printers Information technology Office Equipment Minimu information to be included in specification sheets Printers Part 2: Class 3 and Class 4 printers shall be accompanied by the relevant documentations (notarized documents). Alignment might be possible. Both countries could accept common international standards for safety (IEC ), but not for product information according to PNS/IEC and Discussion is needed regarding verification method: TH requires only certification or test report, while PH accepts notarized documents. If TH manufacturers provide information of product according to IEC or , this requirement can be possibly aligned. Note: ISO/IEC is intended to facilitate users in selecting a printer which meets their requirements. ISO/IEC specifies the minimum information to be included in the specification sheets of printers in order for users to compare the characteristics of different machines. The term "Specification Sheets" applies to documents which describe the performance characteristics of the printers to be included in instruction manuals, product brochures or on websites. Question to PH: Who issues the notarized documents? Is third party (lab test) or self-declaration required? Verification method needs to be clarified. 3. Safety (EMC) 4.2 The product s safety must be certified or tested by as required by TIS 1956: Information technology equipment radio disturbance limits, or Information Technology Equipment Safety Electromagnetic Compatibility (EMC) tests as required in CISPR 22 Standard: Information technology equipment-radio disturbance characteristics-limits and methods of measurement, or EN 55022: Information technology equipment - Radio disturbance characteristics - Limits and methods of measurement, or certified by the equivalent test. Verification: certificate of compliance or test reports according to the mentioned standards N/A Alignment is not possible. 4. Warrantee of product N/A Warranty The manufacturer shall offer a commercial guarantee on the quality of the product provided the product is used for its intended purpose. The period of this guarantee must be at least 1 year. Consideration is required. If this requirement is already fulfilled by Thai companies, this requirement could potentially be a common core criterion. Question to TH: Do companies in TH provide the same commercial warrantee as mentioned in PH requirement? 5. Law compliance 4.3 Production, transportation, and disposal of waste from the production process must follow the law and regulations of the government, or the manufacturing plant has been certified for ISO Verification: relevant evidences showing compliance Compliance to Environmental Regulations The applicant is required to comply with relevant environmental legislations. This includes production process, transport and disposal features of the product. Verification: Submission of applicable licenses and permits to operate indicating the manufacturer s compliance with agreements on environmental regulations applicable to the area which the plant is located. TH and PH have common requirement. However, this is the basic principle of ISO Note: For TH, on-site audit for the first time application is excepted if the manufacturing plant has been certified for ISO TH has several manufacturing plants (SHARP, Ricoh, etc.) which also certified by ISO There is no manufacturing plant located in PH. Question to PH: Is an ISO certificated accepted? Remark: Both countries could accept ISO certification. 6. Energy efficiency 5.1 The power consumption complies with the requirements of International Energy Star Program Requirements for Imaging Equipment. Verification: A certificate of Energy star or evidences to prove the compliance of the product Energy Energy consumption shall comply with the requirements of Energy Star at the time of the application. shall be accompanied by the relevant documentations (notarized documents). Alignment is possible. TH and PH have common requirement for the most updated version of Energy Star. Question to PH: Do you request additional evidences than the writing statement and notarized documents to prove that the product meet this requirement? Question to TH: Would TH accept the PH verification requirements? 1

2 Thai Green Label (TH) TGL-37-R2-15_Printers Green Choice Philippines (PH) GCP_ _Multi function printing device (MFPD) Remarks on identifying common core criteria Open questions 7. 3 R design 5.5 The design of product shall be according to 3 R principle, provided in the check list for 3 R design. Verification: Self declaration according to the check list. Note: TGL refers this requirement and also using the check list from Eco mark criteria No. 155 in M (must) requirements. The check list is provided in Appendix R Design The standard for the design of multi-function devices are established based on its modularity. Each part of the product or module can be separated from the whole, and hence can be treated as a single entity for the purpose of recyclability, disassembly and reparability. The following requirements have to be fulfilled: The parts of the product shall be recyclable. There shall be no inseparable joints between different materials such as glued or welded joints. Modules shall be easily removed. Connections between parts must be easily located. Labels and/or stickers shall be made up of the same material as the part in which they are attached and/or it must not be treated in a manner that would pose difficulty in recycling. The five requirements of the 3R design are common. Alignment is possible. 3R design check list of TH covers 3R design requirements of PH. Question to PH: Can PH consider integrating the check list of the 3R design into their requirements? shall be accompanied by the relevant documentations (notarized documents). 8. Emissions 5.3 The emission of dust, ozone, total volatile organic compound (TVOC), styrene, and benzene during operation shall comply with Table 2. Emission Emission rate (mg/hr) Monochrome Color Dust < 4.0 < 4.0 Ozone < 1.5 < 3.0 Print phase < 10 < 18 TVOC Ready Floor-mounted equip. < 2.0 < 2.0 phase Desktop products < 1.0 < 1.0 Styrene < 1.0 < 1.8 Benzene < 0.05 < 0.05 Verification: Test report according to RAL-UZ-171. Submission of test report is depending on type of the printers as followings; Printer type Parameter to be tested TVOC Dust Ozone Styrene Benzene Electrophotog raphic Ink jet Thermal sensitive Wire dot Emissions For Multi-Function Printing Devices with laser and inkjet printing, emissions shall not exceed the levels indicated in the following tables Emission limits for laser printing Emission Laser Printing (of product body volume) Ozone Less than 0.04 mg/m 3 PM 0.25 mg/m 3 Emission limits for ink jet printing Emission Ink jet printing VOC 5% by weight For Multi-Function Printing Devices with copiers, emissions (Dust, Ozone & Styrene) shall not exceed the levels indicated in the following table: Emission Copiers Dust mg/m 3 Ozone 0.02 mg/m 3 Styrene 0.7 g/m 3 Verification: Signed certification from recognized/accredited laboratories and/or certification bodies.* TH and PH have requirements on emission. However, the numbers and units of measurement are different. PH requirement is quite flexible in term of test method, while TH follows German verification. Alignment is not possible/ very difficult. * Laboratories accepted by national or international accreditation bodies such as the Asia Pacific Laboratory Accreditation Cooperation (APLAC) or International Laboratory Accreditation Cooperation (ILAC) 9. Noise 5.2 The product, during its operation, shall meet the requirement on limitation of noise exposure level but A-weighted sound power level (LWAd) not exceed 75.0 db as noted in Table 1. A-weighted sound power level: L WAd (db) Monochrome Color 0.35*Sbw+59 and 75 parallel equipment : 0.3*Sco+61 and 75 Serial equipment : Submit reference value for the equipment of Sco<0.5 Sbw Remarks: Sbw = Operating speed in pages per minute for monochrome copying Sco: Operating speed in pages per minute during color copying Reference to RAL-UZ-171 (3.5) For wire dot printer, the test shall be conducted and measured at full speed mode without calculation of L Wad Noise Sound emission from printers shall meet either sound pressure level limits or preferably sound power level limits indicated in Table 5: Copies per Minute Sound Power Level (LWad) Operating db db db >70 - Stand by db >30 - Verification: Signed certification from recognized/accredited laboratories and/or certification bodies.* TH and PH have requirements on noise. However, the criteria of TH depend on printing modes and printing speed, while PH specify noise according to range of product speed. PH requirement is flexible in terms of test methods. Alignment is not possible/ very difficult. Verification: Test report according to test method ISO 7779 Acoustics-Measurement of airborne noise emitted by computer and business equipment. A-weighted sound power level (LWAd) shall be according to ISO 9296: Acoustics-Declared noise emission value of computer and business equipment. *Laboratories accepted by national or international accreditation bodies such as the Asia Pacific Laboratory Accreditation Cooperation (APLAC) or International Laboratory Accreditation Cooperation (ILAC) 10. Hazardous substances in product N/A Hazardous Substances The product shall not contain substances listed in DENR AO and/or in ROHS. Alignment is not possible. 2

3 Thai Green Label (TH) TGL-37-R2-15_Printers Green Choice Philippines (PH) GCP_ _Multi function printing device (MFPD) Remarks on identifying common core criteria Open questions 11. Toner and ink 5.10 Toner, ink, and ribbon Shall not contain the following substances. 1) Hg, Pb, Cd, Cr 6+, Ni (except high molecular weight compound) 2) substances listed in Table 3.1 of Appendix VI of Regulation (EC) No. 1272/2008 in the following categories Carcinogenic category 1A, 1B or 2 Mutagenic category 1A, 1B or 2 Toxic to reproduction category 1A, 1B or 2 3) Substances required to be marked with hazardous symbol R- or H- on the product pursuant to table 3.1 or 3.2 in Appendix VI of Regulation (EC) 1272/2008 as followings H370 (R39/23/24/25/26/27/28): Specific target organ toxicity- Single exposure, hazard category 1 H371 (R68/20/21/22): Specific target organ toxicity-single exposure, hazard category 2 H372 (R48/25/24/23): Specific target organ toxicity-repeated exposure, hazard category 1 H373 (R48/20/21/22): Specific target organ toxicity-repeated exposure, hazard category 2 shall be accompanied by the relevant documentations (notarized documents) Toners and Inks The inks and toners shall comply with the requirements of GCP Criteria and GCP shall be accompanied by the relevant documentations (notarized documents). Consideration is required. Alignment is not possible/ very difficult. PH refers to two other product requirements: ink jet cartridge (GCP ) and toner cartridge (GCP ), which have more requirements than TH requirement for toner/ink used in MFD. Questions to PH: 1. Could you please confirm the code of criteria for ink jet cartridge (it is or , as the downloaded version is ). Where can GCP be found? 2. Do you mean that the ink/toner has to fully comply with the referred criteria (including law compliance of cartridge manufacturer, print quality, 3R design, heavy metals, take back system, etc.)? Please kindly explain. Should the ink/toner cartridge be certified also? 3. If the question 2 is correct, why do you need just statement in writing and notarized documents? This is because test reports of some requirements are mentioned in the two cartridges criteria. Verification: The applicant shall submit a declaration letter of compliance, and declaration letter from manufacturer of toner Shall not use azo dyes which generate any of 22 amines listed in the table below according to the official test method corpus based on the German Law on Foods and Sundries Article 35:Amitliche Sammlung Von Untersuchungsverfahren nach 35 LMBG [Note: the list of 22 amines is referred from Appendix 8 of REACH or EC Regulation No. 1907/2006] Verification: The applicant shall submit a declaration letter of compliance, and declaration letter from manufacturer of toner, or submit a test report according to Article 35 of German Law on Food and Sundries. 12. Toner cartridge and toner container Plastic part of cartridges shall be as followings; (1) Plastic part weighing from 25 grams shall not contain heavy metals and flame retardant. However, unintentional contamination shall be limited according to the following table. Substance Content (ppm) Heavy metals Flame retardant Pb Cd Hg Cr 6+ PBB PBDE <1000 <100 <1000 <1000 <1000 < Toners and Inks The inks and toners shall comply with the requirements of GCP Criteria and GCP shall be accompanied by the relevant documentations (notarized documents). See remarks above. Verification: There are two options for verification. Option1: The manufacturer has a system to control the level of mentioned substances. The applicant shall submit 1) Declaration letter of compliance 2) Operating manual or procedure of practice 3) Certification letter and/or test report from plastic part suppliers (as supporting evidences) Option 2: The manufacturer does not have the system for controlling the mentioned substances. The applicant shall submit test reports of plastic parts according to IEC or equivalent test methods. (2) Plastic casing parts of the cartridge shall be recyclable for at least 95% by weight (3) Plastic part of toner cartridge shall be produced from homo polymer, copolymer or polymer blends in order to facilitate separation. In case that the label is used and is hard to remove, it should be the same material as the plastic part it is attached to, and shall not prevent the recycling process. Verification: The applicant shall submit declaration letter of compliance. 13. Plastic 5.4 Plastic materials Plastic Materials and Photosensitive/Photographic Components Plastic Alignment is not possible/ very difficult. 3

4 Thai Green Label (TH) TGL-37-R2-15_Printers Green Choice Philippines (PH) GCP_ _Multi function printing device (MFPD) Remarks on identifying common core criteria Open questions materials Polymer containing halogen shall not be used for plastic casing parts weighing from 25 grams. Except, fluoroorganic additives (for example, anti-dripping agents, etc.) used to improve the physical properties of plastics, provided that they do not exceed 0.5wt% Verification: Declaration letter of compliance Plastic parts which weigh from 25 g shall not contain heavy metals and flame retardants. However, unintentional contaminations are limited according to table below. components, plastic additives and pigments shall not contain any substances restricted under DENR AO shall be accompanied by the relevant document. Note: DENR AO is Priority chemical list (PCL) according to the Toxic Substance and Hazardous Waste and Nuclear Waste Act There are 48 chemical substances under the list, which also include Pb, Hg and Se. There are only common requirements regarding Pb, Hg, and Cr6+. It is difficult to define whether DENR AO and the list of prohibited chemicals in TH in Table 3.2 of EU Regulation No.1272/2008 are common. For flame retardants, PH controls only poly-brominated biphenyls (PBBs, CAS No ), while TH control both PBBs and poly-brominated PBDEs. Substance Content (ppm) Heavy metals Flame retardant Pb Cd Hg Cr 6+ PBB PBDE <1000 <100 <1000 <1000 <1000 <1000 Note: If result of total Chromium is less than 1000, it is implied that Cr 6+ already meets this requirement without further analysis. Verification: There are two options for verification. Option1: The manufacturer has a system to control the level of mentioned substances. The applicant shall submit 1) Declaration letter of compliance 2) Operating manual or procedure of practice 3) Certification letter and/or test report from plastic part suppliers (as supporting evidences) Option 2: The manufacturer does not have the system for controlling the mentioned substances. The applicant shall submit test reports of plastic parts according to IEC or equivalent test methods The list and CAS number of flame retardant used in plastic parts weighing from 25 grams shall be declared in accordance with ISO However, this requirement shall not apply to reused plastic parts. Verification: Declaration letter of compliance The following substances according to Table 3.2 of Annex VI of EC Regulation 1272/2008 in the following categories shall not be added in plastic parts weighing from 25 grams. Carcinogenic category 1 (Carc.1) Carcinogenic category 2 (Carc.2) Carcinogenic category 3 (Carc.3) Mutagenic category 1 (Mut.1) Mutagenic category 2 (Mut.2) Mutagenic category 3 (Mut.3) Toxic to reproduction category 1 (Repr.1) Toxic to reproduction category 2 (Repr.2) Toxic to reproduction category 3 (Repr.3) Verification: Declaration letter of compliance. 14. Photosensitive drums 5.6 Photoconductor drums shall not contain Pb, Hg, and Se Plastic Materials and Photosensitive/Photographic Components Plastic components, plastic additives and pigments shall not contain any substances restricted under DENR AO They are common regarding the prohibition on Pb, Hg, and Se. PH has more control chemical substances. Alignment is not possible/ very difficult. shall be accompanied by the relevant document. Note: DENR AO is Priority chemical list (PCL) according to the Toxic Substance and Hazardous Waste and Nuclear Waste Act There are 48 chemical substances under the list, which also include Pb, Hg and Se. 15. Battery 5.7 Battery for data back up Shall not contain Pb Hg and Cd content in the battery shall be in accordance with the relevant updated version of EU Directive Replacement or removal of battery shall be possible without removing an entire N/A Alignment is not possible. 4

5 Thai Green Label (TH) TGL-37-R2-15_Printers Green Choice Philippines (PH) GCP_ _Multi function printing device (MFPD) Remarks on identifying common core criteria Open questions printed circuit board. 16. Usable with recycled paper The product shall be usable with 50% recycled paper Warranty The equipment shall be capable of using recycled paper made from 100% waste paper and shall not void the warranty of the equipment. shall be accompanied by the relevant document. TH and PH have a requirement regarding recycled paper. Alignment is possible. TH and PH do not have the same amount of recycled content of paper. Consideration is required. Question to TH: Is it possible that TH increase the recycled content to 100%? Since the requirement of recycled paper in the criteria of Photocopier (TGL-37-R4-15) is 100%, an alignment within TGL is recommended. 17. Availability of spare parts The availability of the spare parts supply shall be guaranteed for at least 5 years after the end of the production of the copier machine. N/A Alignment is not possible. 18. Double sided printing Double sided or Duplex unit of the product shall be as followings Product speed (PPM) Minimum Requirements for Duplex Printing and Copying Mono- Color chrome < 19 < 24 The devices must offer a manual copiers) or an additional software-supported (printers, multifunction devices) option for duplex printing and copying. >19 39 >24 44 The devices must be equipped with a component for duplex printing and copying by default or such a component must be offered as supplementary equipment. >39 >44 The devices must be equipped with a com-ponent for duplex printing and copying by default. N/A Alignment is not possible/ difficult. Question to PH: Is it possible to consider adding this requirement? 19. Take back system The applicant shall have a take-back policy for used toner cartridge. The policy shall be noted clearly e.g. in an instruction manual, website, media, etc Take-Back The applicant shall have an established and validated retrieval or take back system equivalent to not less than 10% of its total units sold. Verification: The applicant shall submit its program on take back program. The program shall ensure a 10% retrieval of the annual sales (notarized documents). TH and PH have requirements on take back system. However, TH requires it for used toner cartridges, while PH set a criterion for take back of product (end of life). Alignment is not possible/ difficult. %Retrieval = no. units retrieve (end of life) no. units sold 20. Prohibited substances used in manufacturing process In the production process, do not use chemicals on the list, as shown in Table 8 in the final manufacturing stage of the printer body, printed circuit boards or cleaning products for reuse. Note: Table 4 (please see Appendix 1)is the list of CFCs, HFCs, carbon tetrachloride, and trichloroethane N/A Alignment is not possible/ difficult. Question to PH: Is it possible to consider adding this requirement? 21. Packaging 5.11 Packaging Paper packaging Corrugating medium made from recycle pulp 100% by weight Kraft liner board made from recycle pulp at least 85 % by weight Plastic packaging (1) The substances in Table 8 (see Appendix) shall not be used in manufacturing of plastic packaging. (2) Plastic package must not contain halogenated compounds and organic halogenides. (3) Plastic package must have a symbol indicating the type of plastic according to the standard symbol for recycling plastics TIS 1310 or an abbreviation indicating the type of plastic, according to ISO 1043 or ISO (4) ODP of blowing agent used in shock absorbing material such as EPS (expanded polystyrene), EPE (expanded polyethylene), and EPP (expanded polypropylene) shall be zero Packaging Requirements The packaging material shall be based on its reusability and recyclability. The following requirements have to be fulfilled: Plastic polymers containing halogens shall not be used as packaging material for the machines and its parts. Primary packaging shall have a plastic resin identification code. Packaging materials shall not be treated or made in a manner that would prevent reusing and recycling. Cardboard packaging shall consist of at least 80% recycled content. Partial alignment is possible. The common elements under this requirement are 1) Prohibition of using halogenated compounds 2) Plastic symbols The non-common elements are 1) Prohibited substances in packaging material 2) Packaging materials shall not be treated or made in a manner that would prevent reusing and recycling. 3) Cardboard packaging shall consist of at least 80% recycled content. 5

6 Thai Green Label (TH) TGL-37-R2-15_Printers Green Choice Philippines (PH) GCP_ _Multi function printing device (MFPD) Remarks on identifying common core criteria Open questions 5.12 Total content of heavy metals (Hg, Pb, Cd, and Cr 6+ ) in ink or pigment used for printing on packaging/labels shall not be more than 0.01 % by weight. Verification: Test report by the following test methods or equivalent. parameter Test methods Hg ISO or ASTM D 3624 or IEC Pb ISO or ASTM D 3335 or IEC Cd ISO or ASTM D 3335 or IEC Cr 6+ ISO or IEC User manual The following technical information must be specified in the user's manual /attached paper to consumers: 1) Instructions on the positioning of the machine 2) Take back information about where used products and all parts can be deposited in order to reduce use of resources through recycling and disposal as specified by laws. 3) Print capacity (copies per minute and copying volume per month or per year) 4) Information on the functioning of the energy saving mode by providing information of the Typical Electricity Consumption (TEC) according to the latest version of Energy Star. 5) Information on the use of double-sided copying. 6) Recommendation that the machine be turned off when not in use. 7) Frequency of changing ozone filters (if available), photoconductor, heat roller 8) Instruction on that the product with a sound power level LWAd >63 db is not suitable for use in rooms predominantly used for intellectual activities. They shall be placed in separate rooms Consumer Information The following technical information shall be specified in the user s manual: Instructions on the proper positioning of the machine. Information about how and where each part is used and which decommissioned products/parts can be returned for refilling, recycling and/or disposal. Print Capacity (copies per minute) and copying volume per month or year. Alignment is not possible/ difficult. TH and PH have requirements, but they are different in the detail. 6

7 Appendix TGL-37-R2-15_Requirement 5.3 Checklist of 3R design 7

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14 TGL-37-R2-15_Requirement Table 8 Prohibited substances used in production process and in packaging materials Ref: EU Regulation (EC) No.1907/ December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC 14

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