Environmental regulations – Determining substances of concern for electronics
By Walter Jager, principal consultant, ECD Compliance, Ottawa-based consulting servicesElectronics Environmental
Environmental compliance is a moving target — new regulations continue to emerge creating significant challenges for the EEE industry. Substances added twice a year to the REACH SVHC Candidate List, the Denmark phthalates ban and the additional RoHS substances are prime examples of new requirements.
The first step in achieving compliance to substance regulations is knowing the substances of concern.
Substances of Concern for EEE
To identify the substances that need to be considered during the design, procurement, and manufacturing of a product, the IEC 62474 declarable substance list (DSL) provides an valuable starting point. It consolidates many of the regulated substances applicable to EEE, helping companies focus their effort on substances that are most relevant to their products and, thus, avoid effort on low risk substances. For example, many of the current 151 SVHCs are intermediate chemicals which – if fully reacted – should not remain in a finished product.
IEC 62474 is an International Standard on material declaration that includes an internationally recognized DSL (based on the Joint Industry Guide (JIG-101)), a material declaration procedure and an XML-schema for data exchange. The JIG-101 was the EEE industry’s de-facto substance list from 2005 through 2012; it was integrated into IEC 62474 to provide broader International acceptance. The JIG-101 document, itself, has not been maintained since 2012 and should no longer be used by organizations.
A unique aspect of IEC 62474 compared to most other IEC and ISO standards is that it includes an online database for the contents of the standard that may need to be updated regularly. The IEC 62474 database is publicly available at http://std.iec.ch/iec62474/
Material declaration is a methodology for suppliers to provide information about the substance and material content of their products. Material declarations can help organizations assess compliance and provide valuable evidence as part of the technical documentation requirement for regulations such as RoHS-2.
As an International Standard, IEC 62474 is intended to have a global harmonizing effect. Several jurisdictions (including Europe) have adopted IEC 62474 as a regional/national standard and it is referenced in the RoHS-2 harmonized standard EN 50581. The IPC 1752 and the Japanese JGPSSI and JAMP material declaration systems are leveraging the IEC 62474 specification.
The IEC 62474 DSL is a list of regulated substances and substance groups (e.g. lead and lead compounds) that a manufacturer should declare to downstream manufacturers if present in the product. The DSL may be accessed from the IEC 62474 database via the menu bar on the left side of the introduction webpage (Figure 1) – click on “Declarable substance groups and declarable substances” and then select the substance from the drop down list. There is also an option to export the entire DSL. (*See Figure 1)
Each substance or substance group entry in the list is accompanied with a reportable application and a reporting threshold level. For example, selecting “Lead/Lead Compounds” presents five entries with different reportable application / reporting threshold combinations – the first entry corresponds to the RoHS restriction. Clicking on the “Details” button reveals information about reference substances; typical EEE applications, regulations, and other information (*See Figure 2).
Declaration procedure and data exchange
IEC 62474 includes a material declaration procedure (rules) and an XML schema for data exchange. The procedure is specified in the document portion of IEC 62464 and the XML schema is available from the IEC 62474 database.
A key objective in the development of IEC 62474 was to ensure that the recipient of a material declaration has sufficient information to properly assess the conformity of a material or product – this overcomes a limitation of several earlier material declaration systems. For example, a material declaration that reports only a single ‘highest’ concentration of lead in the product can be deceiving – the highest concentration may be covered by a RoHS exemption, potentially masking a lower concentration of lead in another material.
Updates to the declarable substances
The key challenge with publishing a list of substances is keeping it up to date with environmental regulations. The IEC 62474 DSL is maintained by a Validation Team (VT62474) consisting of 39 representatives from 14 countries, including 3 representatives from Canada.
An evaluation is normally triggered upon submission of a formal change request; however, the VT will also proactively screen new substances added to existing regulations (such as substances being considered for the EU REACH SVHC Candidate List). One of the evaluation criteria that requires significant technical assessment is whether the substance could realistically be present in the product above the regulatory threshold.
Updates to the IEC 62474 database content were made in June 2013 and September 2013. Another maintenance cycle was launched in October 2013 and is in final validation. The June and September updates included 35 additions and 10 modifications to the DSL. Most of the updates were the result of additional substances added to the REACH SVHC Candidate List, but there were also a few modifications and a couple of substance deletions.
A comprehensive summary of the changes is available at: http://rohs.ca/IEC62474.html
The maintenance cycle that was started in October 2013 is focusing on the REACH SVHCs that were added to the SVHC Candidate List on December 16, 2013. The screening and evaluation phases have been completed and the change requests are in the final validation phase. The update is expected in March 2014.
Maintaining compliance of products to environmental regulations has become a significant challenge and effort for product manufacturers. Internal processes are needed to identify requirements, obtain information from a global supply chain, assess conformity/risks, and to maintain documentation. This needs to be accomplished efficiently and cost effectively and be flexible enough to accommodate new regulations. Leveraging industry best practices, including the use of risk assessment can be particularly valuable.
For substance restrictions and disclosure, identifying the substances of concern that need to be considered during the design, procurement and manufacturing phases of a product is an important and practical first step to help focus the conformity efforts. The DSL included in IEC 62474 provides a convenient starting point for engineering and procurement specifications and helps organizations focus on key substances for market acceptance. The DSL is updated regularly to reflect changing regulations.