How to Control Hazardous Substances within the Supply Chain

Transcription

1 How to Control Hazardous Substances within the Supply Chain

2 General concept Control of Hazardous Substances = Management of the Supply Chain 2

3 International environment Canada Env. Protection Act California Proposition 65 California RoHS Mexican lead restriction standard Norway PFOArestriction RoHS REACH Battery China RoHS K-REACH Regulation J-Moss PCBs Phase-out Regulation 3

4 Manufacturers and importers of EEE * - Questions Is there a regulation on Hazardous Substances (HS) applicable to the EEE in the country where we sell it? What are the technical requirements? What are our obligations? How can we meet the relevant requirements? How can we meet our clients specifications? What are the solutions accepted by authorities? Are my suppliers declarations acceptable for compliance? Are there harmonized and/or non-harmonized standards? What are the notified and/or accredited laboratories, if any? *EEE Electrical Electronic Equipment 4

5 Management of the supply chain Supplier declara,on Test results Process cer,fica,on (HSPM*) Material declara+on AND/OR AND/OR AND/OR AND/OR The reliable and las+ng solu+on is not based on one solu+on *Hazardous Substances Process Management 5

6 Main issues Constant evolution of substance lists Complexity of the supply chain Lack of knowledge of markets regulations Transparency required by end-user customers 6

7 An new answer Reference standard: IEC 62474: Material declaration for products of and for the electrotechnical industry 7

8 - Copyright Bureau Veritas Ø IEC 62474

9 IEC Material declaration for products of and for the electrotechnical industry Exchange material and subtance data between suppliers and their customers for electrical and electronic product l International standard l Applies to products, components, and materials that are supplied to producers of electrical and electronic products l Covers declarable substances and substance groups covered by international regulations l Allows declaration of other substances listed in customers or industry specifications l All declarable substances and materials are listed in the relevant IEC database l Applies to business-to-business transactions 9

10 Intended use of IEC Provide data to downstream manufacturers that: l allows them to assess products against substance restriction compliance requirements Compliance declaration: base requirements l they can use in their environmentally conscious design process and across all product life cycle phases Composition declaration: full requirements 10

11 Structure of IEC Part 1 l Procedure, content, and form relating to material declarations For companies operating in and supplying the electrotechnical industry Part 2 l Database of declarable substances worldwide Regularly updated by the IEC Validation Team For software developers 11

12 Benefits of IEC For manufacturers l Assess products against international compliance requirements l Use declarations in ecodesign process and through all the product life cycle phases l Benefit from a lasting solution compared to test results l Benefit from harmonized supplier declarations compared to mere selfdeclarations l Provide customers and authorities with an international standardized solution l Have access to updated lists of regulated substances and relevant concentration values (regulatory watch) l Already used by Japanese electrotechnical industry (supported by METI*) l Meet some of the requirements of a Quality Management System eg. HSPM *METI: Ministry of Economy, Trade and Industry 12

13 Material declaration versus HSPM Certification A few examples of requirements within HSPM Plan-Do-Check-Act cycle: Ø Art. 4 Context of the organization 4.3 Determining the scope of the HSPM system Ø Art. 7 Support l Organizational knowledge Ø Art. 8 Operation l Customer communication Ø Art. 9 Performance evaluation l Customer satisfaction Ø Art. 10 Improvement l 10.1 General Determine and select opportunities for improvement The answer could be: Ø Art. 7.5 Documented information l Material declaration, eg. IEC (in addition to the already listed ones) 13

14 Electrotechnical Industry - Standardization Testing methods IEC Hazardous Substances Management Material declaration IEC HSPM IECQ QC

15 Ø Bureau Veritas Answer

16 Our business Regulatory Watch Consultancy HSPM* Certification Tests & Analysis Software tools Training Training Third party review Hazardous Substances Expertise Ecodesign Expertise *Hazardous Substances Process Management 16

17 LCIE & CODDE Collaboration Regulatory approach Voluntary approach Follow and anticipate regulations and standards applicable to the products Follow and declare substances in the products Estimate and reduce the environmental impact of the products 17

18 «HASAP - Hazardous Substances Assessment Platform» DATA COLLECTION MATERIAL DECLARATION Online accessible platform for the manufacturer and his suppliers Provision of regulated and other substances of concern database Automatic and configurable tracking system of suppliers and resending system Tracking of substances and authorized concentration limits in products Storage of all exchanged information and traceability of declarations Material declaration based on harmonized IEC format 18

19 Ø Conclusion

20 HASAP software tool For licence holders, the service includes: l l l l Updating of regulated substances and their limit values Maintenance of the software tool: provision in real time of new functionalities for all the users Training on the use of the software tool at all use stages Access to the help desk provided by experts: IT support for questions related to the software tool Technical assistance related to material declaration Regulatory assistance for regulatory questions l Users community (Userclub, webinars for new functionalities, ) 20

21 - Copyright Bureau Veritas 21