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Environmental Compliance Roll Up Guide 2022
Ensure compliance with our Roll Up & Compliance Reporting Services
The process of meeting compliance is difficult, time-consuming and often confusing – yet it is an absolute necessity to sell products on global markets. Regulations vary by region and industry. A US medical company will look different than a European automotive company, but regardless both companies will need to make sure they’re compliant on a worldwide scale if they intend on selling their products on global markets.
Using the automotive example, automobile manufacturers are at-risk if vehicles contain conflict minerals or known harmful substances. Major manufacturers can be forced to recall hundreds of thousands of cars or devices due to compliance failures. On average, manufacturers spend approximately $1 million per year hiring consultants and data teams to meet the requirements of laws, regulations and codes designed to protect the environment.
Conflict Mineral Roll Up Report (CMRT):
Companies that supply products to the United States are subject to the Dodd-Frank Act and must submit a full roll up report on the conflict mineral status of their suppliers. Many times, a single product will contain hundreds, if not thousands, of suppliers and the Conflict Mineral Reporting Template (CMRT) and the associated statements and policies from each supplier must be rolled up into a single CMRT form. This roll up is a data exchange between a supplier and a customer and allows the customer to understand high risk suppliers in their supply chain. Customers can follow OEC Due Diligence Guidance for Minerals to mitigate risks, monitor and track progress with high-risk smelters in their supply chains. SiliconExpert has the largest global database on compliance data for electronics parts, including materials and chemical composition reports, smelter factory validation reports, and a full aggregation of Conflict Minerals Reports. To request a full CMRT roll up report, or a materials report on tantalum, tin, tungsten and gold on your entire parts list, please contact us below.
European Union: REACH and RoHS Compliance Reports:
The Restriction of Hazardous Substances (RoHS) is a directive that regulates the manufacturing and distribution of electronics and electrical equipment within the European Union. RoHS regulates 10 restricted materials by weight threshold.
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is broader in scope and applies to all goods manufactured, imported, or sold in the European Union. REACH regulates chemical substances and Substances of Very High Concern (SVHC) which are considered carcinogenic, toxic for reproduction, mutagenic, persistent and bioaccumulative. All manufacturers and importers within the EU must register all substances above a certain weight threshold with the European Chemicals Agency (ECHA). The registration identifies the risks associated with the substances they produce, demonstrates the ability to manage those risks, and establishes safety guidelines for the product so the use does not pose a health risk. Currently, the SVHC list contains 224 harmful substances (as of June 2022).
A full RoHS and REACH Compliance Report identifies non-compliant electronic parts and components and offers alternative parts which do meet compliance. For RoHS reports, the RoHS Exemptions are listed, when applicable, along with the specific Exemption Annex number. REACH Reports will indicate if the component contains SVHC’s and whether the threshold limit is exceeded. Supporting and source documentation is provided in both reports.
North America: Cal Prop 65, TSCA Compliance Reports
Along with Conflict Mineral Reporting, the most heavily enforced compliance legislations are the California Proposition 65 (Prop 65) and the Toxic Substances Control Act (TSCA).
California Prop 65 applies to all products sold or distributed within the state of California. Formerly known as the Safe Drinking Water and Toxic Enforcement Act of 1986, Prop 65 aims to protect Californians from chemicals known to cause cancer, birth defects or other reproductive disorders. Fines of $2,500 per exposure per day may be imposed by Prop 65 for violations and the average settlement cost is approximately $65,000. In addition to the fines imposed by California Proposition 65, there is also a bounty hunter provision that offers a profit incentive for lawsuits to enforce the measure. This means that private plaintiffs are incentivized and rewarded for bringing successful enforcement actions.
Toxic Substances Control Act (TSCA) was passed by the US Congress in 1976 and is enforced by the Environmental Protection Agency (EPA). Violations of TSCA can result in fines of up to $50,000 per day. The TSCA inventory is a list of all chemicals which can be legally manufactured, imported, and used for commercial purposes in the United States. All manufacturers and importers must provide the EPA with information
Both Prop 65 and TSCA Compliance Reports contain a full list of substances, CAS registry numbers, and whether compliance is met or not. Prop 65 Reporting includes No Significant Risk Levels (NSRL), Maximum Acceptable Dose Level (MADL), and the type of toxicity.
Full Material Declaration (FMD) Report
Full Material Declaration, otherwise known as Full Material Declaration Disclosure, is a comprehensive list of the substances contained within a component. Details include the percentage weight of each substances’ composition, the levels of concentration of the substance, and if the concentration exceeds any regulatory levels.
An FMD is recommended with every compliance report to provide transparency for all substances within a part. A complete and updated FMD is often difficult to source from suppliers, but the SiliconExpert data team diligently collects up-to-date information.
References
- https://electrek.co/2018/08/06/electric-hybrid-cars-vw-audi-porsche-recall-cadmium/
- https://infinitediaries.net/124000-electric-and-phev-cars-from-vw-audi-and-porsche-could-be-recalled-due-to-poisonous-cadmium/
- http://www.green-charger.com/en/news/18b9fe2d36e0911c7776793956b7b2a5
- https://www.cnet.com/roadshow/news/volkswagen-toxic-cadmium-charger-ev-plug-in/
- https://www.imds-professional.com/en/on-the-current-occasion-suspicion-of-cadmium-at-vw-and-streetscooter/
- https://phys.org/news/2018-07-volkswagen-recall-electric-cars.html
- https://www.tva.com/energy/technology-innovation/batteries-for-electric-vehicles
- https://www.autocar.co.uk/car-news/new-cars/volkswagen-group-could-face-ev-and-hybrid-recall-due-carcinogen-chargers
- https://www.rohsguide.com/rohs-faq.htm
- https://www.p65warnings.ca.gov/fact-sheets/cadmium-and-cadmium-compounds
- https://www.motorfinanceonline.com/uncategorized/analysis-vw-unlikely-damaged-ev-battery-scandal/
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