EPEAT CONFORMITY ASSESSMENT PROTOCOLS 4.8 Packaging

Transcription

1 EPEAT CONFORMITY ASSESSMENT PROTOCOLS Constituents in packaging Required Elimination of intentionally added heavy metals in packaging Verification Guidance Product Verification Committee Clarifications References and Details None This criterion is drawn from the Model Toxics in Packaging Legislation which is available online through the Toxics in Packaging Clearinghouse. Recycled content exemption is specified in the Model Toxics in Packaging Legislation as the following: packaging components that would not exceed the maximum contaminant levels, i.e., the sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium present in any packaging component shall not exceed 100 ppm by weight but for the addition of recycled materials; and provided that none of the four regulated metals in the packaging components has been recovered and/or separated from other materials for use as a metal or metallic compound; and provided that the packaging components do not exceed a maximum concentration limit of 200 ppm by weight for the sum of the four regulated metals. Analytical testing is not required for verification to this criterion. However if testing is undertaken, the selected test methods should be appropriate for measuring total concentration of the restricted metals in the substrate. For example, energy dispersive X-ray fluorescence spectrometry can be used with limitation to quantitatively determine the amount of heavy metals in polymeric materials (lead, cadmium, mercury, and total chromium) by following ASTM F This method does not determine hexavalent chromium. Materials that exceed 100 ppm chromium with this method should be further analyzed using destructive wet testing methods. Laboratory analysis for total metals in polymeric and other materials can be performed using procedures such as EPA SW-846 Method 3052 and IEC 62321:2008. Verification Requirements a) Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 4.8-1

2 b) Supplier letter(s) for each packaging component that certifies to: 1) No intentional addition of the specified heavy metals in any package or packaging component; and 2) That the sum of the concentration of the four metals present in any packaging component does not exceed 100 ppm by weight, or 200 ppm by weight for recycled content materials, or c) Documentation of a assurance system that demonstrate conformity to this criterion through effective control of the supply chain Verification Requirement b) Supplier letter(s) for each packaging component that certifies to: 1) No intentional addition of the specified heavy metals in any package or packaging component; and 2) That the sum of the concentration of the four metals present in any packaging component does not exceed 100 ppm by weight, or 200 ppm by weight for recycled content materials, or c) Documentation of a assurance system that demonstrate conformity to this criterion through effective control of the supply chain. 1. Request for data submission 1. List of all packages or packaging components, using EPEAT Packaging Material Form or equivalent, and identify suppliers for each package or packaging component identified. 2. Supplier letters and/or declarations of conformity documenting for each supplied packaging piece certification to a and b below: a) No intentional use of the specified heavy metals; and b) The sum of the four metals present in any packaging component do not exceed 100 ppm by weight, or 200 ppm by weight for recycled content materials Description and documentation of conformity assurance system which is used to demonstrate conformity for both the intentionally added and 4.8-2

3 incidental presence requirements of this criterion evidence for such that is adequately demonstrated List of packaging parts/components Supplier records/letters Declarations of Conformity Analytical data/test reports CAS with details of a restricted materials program and auditing program that indicates packaging is under the incidental threshold limits Is there evidence that there are no intentionally added heavy metals for each listed piece of packaging? For incidental presence, was evidence provided showing that each packaging material is under the 100 ppm by weight threshold, or 200 ppm by weight if the recycled content exemption is indicated? Does the described system adequately provide control of the supply chain to the applicable level of incidental presence? Is there an obvious Plan-Do-Check-Act process to the described assurance system? Is there evidence that the described system is in place and providing effective controls for all packaging material and packaging components? 4. Evaluation guidance Multiple packaging components may be made by one supplier and a single supplier letter that covers all packaging parts is fine. Incidental presence needs to be demonstrated for each packaging part or component, not for the sum of all the packaging. The subscriber will need to provide analytical test data for the incidental presence of the four heavy metals OR the details of the assurance system that is in place to control the incidental presence of the four heavy metals, not both. Conformance assurance system is defined in section 3.2 Special Terms of the standard. If the manufacturer chooses to submit documentation of a assurance system, more evidence may be required based on what is provided. An example of a CAS with requirements set appropriately would allow 0 ppm for each or sum of the heavy metals in packaging. This requirement would cover both the no intentionally added and the incidental presence. Any CAS with an allowance of more 4.8-3

4 than 0 ppm for the sum or individual heavy metals (to allow for incidental presence) must also address the requirement of the no intentionally added heavy metals Required Elimination of elemental chlorine as a bleaching agent in packaging material Verification Guidance Product Verification Committee Clarifications References and Details None None Available. Verification Requirements a) Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) b) Copy of manufacturer s environmental packaging requirement Verification Requirement b) Copy of manufacturer s environmental packaging requirement 1. Request for data submission evidence for such that is adequately demonstrated 1. Copy of the manufacturer s environmental packaging requirement with the section addressing elemental chlorine use highlighted. Product and/or Packaging Specification Packaging material purchasing requirements Environmental Policy if the environmental policy is communicated as a requirement to packaging suppliers Has the manufacturer included the statement that elemental chlorine shall not be used as a bleaching agent to bleach virgin or recovered content fibers in product packaging in their environmental packaging 4.8-4

5 requirements? 4. Evaluation guidance This criterion is only verifying that there is a documented statement of the requirement by the manufacturer that elemental chlorine shall not be used in production of product packaging

6 4.8.2 Recyclable packaging materials Required Separable packing materials Verification Guidance Product Verification Committee Clarifications References and Details None None available. Verification Requirements a) Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) b) Documentation demonstrating feasibility of disassembly of dissimilar packaging materials without tools and identifies permissible exemptions. Includes one of the following: Manufacturer s packaging part or assembly drawing Manufacturer s disassembly instructions Trial packaging disassembly report Statement from a minimum of three recyclers individually, or at least one recycler working under an independent entity that is not a trade organization, confirming that the packaging design meets the requirements of this criterion Verification Requirement b) Documentation demonstrating feasibility of disassembly of dissimilar packaging materials without tools and identifies permissible exemptions. Includes one of the following: Manufacturer s packaging part or assembly drawing Manufacturer s disassembly instructions Trial packaging disassembly report Statement from a minimum of three recyclers individually, or at least one recycler working under an independent entity that is not a trade organization, confirming 4.8-6

7 that the packaging design meets the requirements of this criterion 1. Request for data submission evidence for such that is adequately demonstrated 1. List of all packaging material, EPEAT Packaging Material Form or equivalent. 2. List of parts being claimed as exempt and the exemption claimed. 3. At least one of the following pieces of documentation that clearly demonstrates the feasibility of separability of dissimilar packaging materials without the use of tools: Manufacturer s packaging part or assembly drawing; OR Manufacturer s disassembly instructions; OR Trial packaging disassembly report; OR Statement(s) from either a minimum of three recyclers individually, or at least one recycler working under an independent entity that is not a trade organization, confirming that the packaging design meets requirements of this criterion. Written statements should be signed by the recycler(s) on the recycler s letterhead, or if an electronic communication, including demonstration that the source is a recycler. List of packaging materials for the registered product List of any exemptions/exceptions being claimed Packaging drawings Disassembly instructions for packaging Trial Packaging/3R/WEE disassembly report Written recycler statements per criterion Did the documentation provided address that dissimilar packaging could be disassembled without the use of tools? Were all exceptions to meeting the disassembly requirements identified and allowable by the criterion? 4.8-7

8 4. Evaluation guidance Independent means that the individual does not have an ongoing business relationship with the manufacturer. Entity could be a recycler or another entity that has expertise in electronics recycling. Exemptions include: a) Plastic bags (or wrap) affixed with paper labels that meet either of the following criteria: 1) Combined weight of single bag (or wrap) and label is less than 25 g. 2) Surface area of label is less than 50 cm 2. b) Pallets or pallet assemblies that are part of the primary package. c) Tape, glue, or staples used to construct or close a fiber-based container Optional Packaging 90% compostable/recyclable Verification Guidance This criterion will be verified for in geographic regions or countries. Subscriber will be notified during the verification process to provide verification information that supports in a specific region/country that is specified by the Verifier. Product Verification Committee Clarifications References and Details None The following resources provide information on material collection rates and/or collection accesses data. This list may not be comprehensive and in no way shall it be interpreted to limit options for supporting recyclable claims. The European Organization for Packaging and the Environment - European Official EU-27 plus Iceland, Liechtenstein and Norway Packaging and Packaging Waste Statistics - Topics&categorie=2&item=19 Japan Ministry of the Environment Implementation Status of Sorted Collection and Recycling by Municipalities; State of Sorted Collection 4.8-8

9 and Recycling of Used Containers and Packaging. United Kingdom WRAP and British Retail Consortium. On-pack recycling label. United States US EPA Municipal Solid Waste Generation, Recycling, and Disposal in the United States: Detailed Tables and Figures. Verification Requirements a) Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) b) List of all packaging materials with designation of whether material is compostable, fiber-based, or recyclable c) Documentation of calculation showing total weight of nonrecyclable or non-compostable material is less than 10% of total package weight d) Documentation supporting claim for materials, excluding fiberbased materials, considered compostable and/or recyclable 1) For a compostable material, provide one of the following indicating that the material meets ASTM D6400, ASTM D6868, EN or ISO 17088: data sheet, supplier letter with reference to specification met, or test results from an accredited laboratory 2) For a recyclable material, provide documentation that is applicable to the country in which the product is declared, from a governmental or non-governmental organization, but not a material trade association, that: i. the material is recycled at a national rate of at least 15% by weight; or ii. 65% of the country s population has local access to drop-off or collection services for the material in its converted form; or iii. manufacturer participates in a nationally mandated packaging recycling scheme that includes collection of the material with a minimum recycling goal of 15% by weight

10 Verification Requirement b) List of all packaging materials with designation of whether material is compostable, fiberbased, or recyclable 1. Request for data submission to subscriber 2. Examples of potential evidence for more than one item of evidence may be provided such that is adequately demonstrated 1. List of all packaging material, EPEAT Packaging Material Form or equivalent with designation of whether material is compostable, fiber-based or recyclable. 2. If fiber based material is claimed, demonstration that it is fully derived from natural fiber such as wood, hemp, kenaf, palm, bamboo and bagasse. Packaging Materials List with material designation. EPEAT Packaging Form Does the packaging list contain all packaging materials in the product and identify whether the material is compostable, fiber-based or recyclable? 4. Evaluation guidance See criterion for detailed determination criteria of compostable, fiber-based and recyclable. Pallets that are part of primary packaging, including integrated pallets, must be included in this list Verification Requirement c) Documentation of calculation showing total weight of non-recyclable or non-compostable material is less than 10% of total package weight 1. Request for data 1. Calculation documentation with the following data:

11 submission to subscriber 2. Examples of potential evidence for more than one item of evidence may be provided such that is adequately demonstrated Total weight of non-recyclable or non-compostable material; OR Total weight of recyclable or compostable material Total weight of all packaging Percentage of the packaging material that is non-recyclable or noncompostable by weight of the total packaging weight. This percentage must be less than 10%. Spreadsheet of calculations EPEAT Packaging Form 3R/WEEE/Recycling report Do the provided calculations include the total packaging weight, the weight of non-recyclable or non-compostable materials and the % that is non-recyclable or non-compostable? Is that % less than 10%? 4. Evaluation guidance Pallets that are part of primary packaging may be included in this calculation if they are part of the product delivery system. However, the weight of a pallet cannot be allocated to the weight of the packaging of a single product if the pallet would normally carry several products. The weight of the pallet shall be apportioned equally to a reasonable number of products that the pallet would carry Verification Requirement d) Documentation supporting claim for materials, excluding fiber-based materials, considered compostable and/or recyclable 1) For a compostable material, provide one of the following indicating that the material meets ASTM D6400, ASTM D6868, EN or ISO 17088: data sheet, supplier letter with reference to specification met, or test results from an accredited laboratory

12 2) For a recyclable material, provide documentation that is applicable to the country in which the product is declared, from a governmental or non-governmental organization, but not a material trade association, that: i. the material is recycled at a national rate of at least 15% by weight; or ii. 65% of the country s population has local access to drop-off or collection services for the material in its converted form; or iii. manufacturer participates in a nationally mandated packaging recycling scheme that includes collection of the material with a minimum recycling goal of 15% by weight. 1. Request for data submission to subscriber 2. Examples of potential evidence for more than one item of evidence may be Documentation supporting the classification claimed for the packaging materials for compostable and/or recyclable materials as follows: 1. For each compostable material, provide documentation in one of the following forms that clearly indicates the material meets ASTM D6400, ASTM D6869, EN or ISO 17088: Data Sheet Supplier Letter Test results from accredited lab 2. For each recyclable material, provide documentation that is applicable to the country being verified, from a governmental or non-governmental organization (not a material trade association) that shows one of the following: The material is recycled at a national rate of at least 15% by weight; OR 65% of the country s population has local access to drop-off or collection services for the material in its converted form; OR Manufacturer participates in a nationally mandated packaging recycling scheme that includes collection of the material with a minimum recycling goal of 15% by weight. Technical data sheets on the material Letters from packaging suppliers Lab test results Government/non-government packaging scheme participation, details

13 provided such that is adequately demonstrated and/or report National recycling reports for packaging Collection reports Has evidence been provided that is sufficient for supporting the classification of each individual packaging material as recyclable and/or compostable? 4. Evaluation guidance Fiber-based materials are not included in this verification requirement; however they shall be documented in verification requirement b) Required Plastics marked in packaging materials Verification Guidance For products with packaging that does not contain any plastics, manufacturers may declare Not Applicable on the MSE Registry. Product Verification Committee Clarifications None References and Details None Available. Verification Requirements 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Photographs, physical evidence, or engineering specifications of the plastic components Verification Requirement b) Photographs, physical evidence, or engineering specifications of the plastic components 1. Request for data submission 1. List of all non-exempt plastic packaging material, EPEAT Packaging

14 evidence for such that is adequately demonstrated Material Form or equivalent with which material type is marked on the packaging and what specification is being followed in the marking (ISO 11469/ISO 1043, Resin ID Codes, SPI, DIN or other country specific codes). 2. Documentation supporting the claimed plastic marking: Photographs of the packaging and markings; OR Physical evidence of the markings; OR Engineering specifications for markings Packaging Materials List EPEAT Packaging Form Packaging Photographs Samples of Packaging Marking stamps and/or stickers Engineering drawings/cad drawings calling out the markings Packaging Marking specification Inspection, Quality Control Reports Audit reports Are all non-exempt plastic packaging parts demonstrated as marked according to the identified specification? 4. Evaluation guidance Marking requirement does not apply to plastic parts weighing less than 25 g or with surface area less than 50 cm2; tape; plastic protective and stretch wraps and labels; or plastic pieces when due to shape marking is not possible

15 4.8.3 Recycled content in packaging materials Required Recovered content in select fiber-based packaging materials Verification Guidance For products with packaging that does not contain any of the materials identified, manufacturers may declare Not Applicable on the MSE Registry Product Verification Committee Clarifications References and Details None None Available. Verification Requirements a) Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) b) List of applicable packaging materials with corresponding category as specified c) Supplier letter(s) from first tier suppliers of each applicable material that: 1) Names the manufacturer to which the material is being supplied; and 2) Specifies the material and attests that it has a recovered fiber content of at least x% (as specified in the table in the criterion) by weight over the course of a year using a weighted average, or as a minimum percentage. d) Copy of manufacturer s environmental packaging requirement Verification Requirement b) List of applicable packaging materials with corresponding category as specified 1. Request for data submission 1. List of all applicable packaging materials with the category of material (e.g. paperboard, corrugated fiberboard, solid fiberboard

16 and spiral wound tube) identified. evidence for such that is adequately demonstrated Packaging Materials List EPEAT Packaging Form Does the list of packaging material have the category identified for each? 4. Evaluation guidance None Verification Requirement c) Supplier letter(s) from first tier suppliers of each applicable material that: 1) Names the manufacturer to which the material is being supplied; and 2) Specifies the material and attests that it has a recovered fiber content of at least x% (as specified in the table in the criterion) by weight over the course of a year using a weighted average, or as a minimum percentage. 1. Request for data submission evidence for such that is 1. List of the first tier suppliers of each packaging material 2. Documentation from each supplier identified that: Identifies the supplier; AND Identifies the packaging material; AND Confirms that the packaging material has a recovered fiber content percentage at least equal to that specified for the category in the criterion by weight over the course of a year using a weighted average, or as a minimum percentage Packaging form with suppliers identified Packaging Bill of Materials Letters from suppliers

17 adequately demonstrated Packaging Tech sheets Do all of the applicable packaging materials meet at least the minimum amount of recovered fiber content specified in the criterion? Does the documentation clearly identify that the recovered fiber percentage is calculated over the course of a year using a weighted average, or as a minimum percentage? 4. Evaluation guidance There may be multiple first-tier suppliers for the material. Supplier letters are required from EACH of these suppliers. This criterion DOES NOT vary by country so subscribers will need to show how the packaging is meeting the requirements of this criterion everywhere the product is sold Verification Requirement d) Copy of manufacturer s environmental packaging requirement 1. Request for data submission evidence for such that is adequately demonstrated 1. Copy of the manufacturer s environmental packaging requirement with the section addressing the preference for the use of postconsumer content in packaging highlighted. Product and/or Packaging Specification Packaging Material purchasing requirements Environmental Policy if the environmental policy is communicated as a requirement to packaging suppliers Has evidence been provided that is sufficient for supporting the classification of each individual packaging material as recyclable and/or compostable? 4. Evaluation guidance None

18 4.8.4 Take-back option for packaging materials Optional Provision of take-back service for packaging Verification Guidance Manufacturers that do not sell products to institutions shall declare Not Applicable for this criterion on the MSE Registry. This criterion will be verified for in geographic regions or countries. Subscriber will be notified during the verification process to provide verification information that supports in a specific region/country that is specified by the Verifier. Product Verification Committee Clarifications References and Details None Region or country-specific take-back schemes shall provide an infrastructure for recycling or reuse in the specific country (ies) being declared to in the product declaration. Verification Requirements a) Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) b) Documentation indicating that the manufacturer gave consideration to reuse options c) Documentation of take-back service available at the time of service for all packaging that are not fiber-based, which can include evidence of the manufacturer s bona fide participation in a region or country-specific packaging take-back scheme d) Declaration stating if there will be any direct costs to commercial customers for this packaging take-back service e) Documentation of notification to purchaser of take-back service f) Documentation that packaging materials collected through the take-back service are delivered to a processor for reuse or recycling Verification Requirement b) Documentation indicating that the manufacturer gave consideration to reuse options

19 1. Request for data submission evidence for such that is adequately demonstrated 1. Documentation of consideration of reuse options for packaging. Environmental Packaging Requirement Packaging Take-back Policy Packaging Take-back service requirements Contracts with recycler demonstrating material recovery specifically for reuse Corporate environmental policy Internal or external memo or study that demonstrates consideration of reuse Documentation of consideration of reuse including corporate statements or reports Data on reuse rates of packaging by subscriber Has the subscriber provided evidence that reuse options for packaging are considered by either evaluating the take back options accordingly or communicating a hierarchy of preferences to the system? 4. Evaluation guidance None Verification Requirement c) Documentation of take-back service available at the time of service for all packaging that are not fiber-based, which can include evidence of the manufacturer s bona fide participation in a regional or country-specific packaging take-back scheme 1. Request for data submission Provide the following information for the following countries (GEC specifies countries for verification): 1. Description of provision or participation in non-fiber based packaging take-back program(s) for institutional purchasers

20 2. Evidence that the manufacturer is participating in a region or country-specific packaging take-back scheme that covers the entire country or region being verified OR, evidence that subscriber provides that service evidence for such that is adequately demonstrated Recycling program participation/provision records List of first-tier take-back service providers for the country that is being verified Website information / Company literature List/map of how the take-back service applies to the entire country, may include drop-off sites and/or mail-back program descriptions Website listing participation in regional/country packaging takeback schemes A listing showing relationships of all the first tier service providers that participate in the take-back program Evidence that the business relationship exists with the listed takeback service provider (s) including any of the following, or equivalent: i. Contract with each take-back service provider ii. Invoice from each take-back service provider iii. Receiving documents from each take-back service provider Other purchasing related documents from each take-back service provider Registration/contracts with regional schemes (such as Green Dot) Has a description of provision or participation in non-fiber packaging take-back program(s), been provided for each specified country? Is the subscriber a participant in a regional or country specific take-back scheme that operates in the country being verified and has provided evidence that they are in current compliance with that scheme? Is there adequate evidence that a business relationship exists with each listed take-back service provider? Is there adequate evidence that the take-back service does apply to the entire country being verified? 4. Evaluation guidance Take-back service providers do not need to be resident in the country

21 being verified however it must be shown that they are providing service for the country being verified Verification Requirement d) Declaration stating if there will be any direct costs to commercial customers for this packaging take-back service 1. Request for data submission evidence for such that is adequately demonstrated 1) Declaration stating whether or not there are any direct costs for commercial purchasers for this take-back service Declaration or from manufacturer Website indicating any costs for institutional purchasers associated with utilizing the take-back program Is the declaration provided adequate to determine if there is a direct cost to the commercial purchaser for using the take-back program? 4. Evaluation guidance A simple declaration from the subscriber when asked if there is a direct cost that indicates Yes or No is sufficient. It is not required to provide the cost that would be incurred by the commercial purchaser if there were a cost. Definition of Direct Cost cost charged to the customer to utilize the take-back program AND any cost for shipping the packaging to utilize the take-back program OR any cost to the customer in the purchase price for the take-back service Verification Requirement e) Documentation of notification to purchaser of take-back service

22 1. Request for data submission evidence for such that is adequately demonstrated 1. Description of how the purchasers are being informed, at the time of marketing and sale of the product, of the existence of the takeback program for packaging in all specified countries and how they can utilize the program 2. Sample documentation of the notification of program including how purchasers can utilize the program Product literature (user/instructions manual, inserts etc) Website information Samples of communications with users Contracts or service agreements with purchasers Is there adequate evidence that purchasers are notified of take-back system for packaging at the time of marketing and sale of the product, in all specified countries? Does the provided documentation adequately describe how the purchaser can utilize the take-back program? 4. Evaluation guidance Documentation of notification to purchasers must be provided at the time of marketing and sale. This applies to both publically available documents and other documents such as contracts and service agreements. Notification can be through written OR online documentation Verification Requirement f) Documentation that packaging materials collected through the take-back service are delivered to a processor for reuse or recycling 1. Request for data submission evidence for 1. Documentation that packaging materials collected through the take-back service are delivered to a process that performs reuse or recycling Contracts/Agreements with take-back service provider(s) that indicate materials are delivered for reuse and recycling of

23 such that is adequately demonstrated packaging. May also be shown with evidence of internal take-back service provider procedures/operating guidelines that show reuse and recycling. Environmental Policy and procedures indicating reuse and recycling of packaging. Have documents been provided that support that the take-back program covers reuse and recycling of packaging materials? 4. Evaluation guidance None