PCB007 Magazine

PCB007-Sept2019

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52 PCB007 MAGAZINE I SEPTEMBER 2019 • European Waste directive (EC 2018/851) defines new REACH "right to information" for recyclers and to the public on demand with all SVHC in products; manufacturers shall declare them to the ECHA authority and EU member states shall ensure the articles suppliers provide relevant information to ECHA New directives are coming on circular econ- omy, material efficiency, and critical materials resources. The proposed coverage for the materials and substances declaration for products includes a data exchange format for the declaration sup- porting the regulations and sectorial require- ments based on inventories of substances and materials in products and their properties, whether they are articles under REACH or not, substance or mixture (like formulated products), or raw materials. It also includes rules and data exchange formats for any data lists used in the context of such declarations: regulated/declar - able substance lists (RSL/DSL), substance class- es and materials classes, applications, exemp- tions and authorizations, product types, and use descriptors (as defined by ECHA). Some of the above regulations are clearly in that scope: various RoHS, EU ELV, EU REACH, US TSCA, California Proposition 65, and all sector-specific prohibited and/or declarable substances lists. Other than the previous regulations on recy- cling and recovery performance of products in automotive (ELV/RRR) or in electrotechnical (WEEE), batteries and packaging could also benefit from such data exchange formats that may include data on materials weight and clas- sification in products. Those regulations could be partially covered by standards, such as IPC- 1752A class B or IEC 62474 material classes. U.S. and EU regulations on conflict minerals re- ly on conflict minerals declarations (CMD) from the supplier companies regarding their smelter suppliers; they are supported by the specific IPC- 1755 and conflict mineral reporting tool (CMRT) standards based on a spreadsheet. They could al - so benefit from the material declaration standards, such as IPC-1752, IPC-1754, and IEC 62474: • Product statements may include a query on presence of conflict minerals (for in- stance, the "3TG": tungsten, tin, tantalum, and gold); the aerospace and defense query list, version 1.0 (see iaeg.com) contains this query: "Product contains conflict mineral(s) that could be stated 'true,' 'false,' or 'unknown' under the IPC-1754 standard" • Substance declarations could be estab- lished against a conflict minerals declar- able substance list (DSL); if any substance is declared, that could trigger another reporting process regarding CMDs Figure 4: Sectorial substances lists.

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