Ask the Experts: June 7 Edition

Ask the Experts: June 7 Edition

Our regulatory subject matter experts are always helping a range of stakeholders solve compelling regulatory challenges associated with supply chain data management. This insight is compiled to educate compliance professionals through content, webinars and events. They also provide advice to Assent clients. Here are four interesting questions our Regulatory team has responded to over the past month.

My supplier has concerns about sharing data with Assent due to European data protection laws such as the European Union (EU) General Data Protection Regulation (GDPR). How does Assent Compliance align with global laws regulating data privacy?

Assent is a Canadian company and, as such, is subject to strict Canadian privacy laws that the EU considers compliant with the GDPR and other data privacy regulations. Furthermore, Assent forms data processing agreements with any concerned customers, and solicits and stores compliance certifications and business information, both of which are exempted in GDPR.

Are battery manufacturers in scope of the EU Restriction of Hazardous Substances (RoHS) Directive?

Batteries are not in scope of the RoHS Directive because they are sufficiently regulated through other means, such as the Battery Directive 2006/66/EC, which restricts some but not all RoHS Directive substances. Some companies may not understand the separation of scope and therefore request RoHS substance information for all components in their electronic products, including batteries.

As a supplier, if I’m required to buy only customer-approved materials, am I responsible for ensuring compliance with restricted/declarable substances, or is my customer?

In many cases, the materials have been evaluated for performance and quality without taking chemical composition into consideration. As such, the chemical composition may be unknown. If you are commercially responsible for purchasing the materials, the respective supplier(s) of the materials will be duty bound and/or contractually bound to support your substance information request. In addition, there may be multiple materials qualified for use, but you as the supplier may choose which ones to use. In this instance, you control the substance composition of the product in question.

Is a company able to claim halogen-free status on their products if those products are REACH and RoHS compliant?

A company can’t claim halogen-free status solely due to REACH or RoHS compliance, and will need to comply with halogen-specific standards, such as IEC 61249-2-21 and JS709C, to make such a claim. The IEC 61249-2-21 standard is used to indicate halogen-free printed circuit boards, while JS709C covers all other aspects of electrical products.

To meet the IEC 61249-2-21 standard, printed boards and their reinforcing matrices may not contain more than a total of 1,500 parts-per-million (ppm) of halogen. This standard limits the use of bromine and chlorine to no more than 900 total ppm of either element. The 1,500 total halogen cap is cumulative/ For example, a printed board containing 800 ppm of bromine and 800 ppm of chlorine would remain under their respective limits, but added together, they exceed the total halogen restriction.

To meet the JS709C definition of low halogen, each material within an electronic product (excluding printed board laminates) must contain less than 1,000 ppm (0.1 percent) by weight of bromine from brominated flame retardants (BFRs), and less than 1,000 ppm by weight of chlorine from chlorinated flame retardants (CFRs), polyvinyl chloride (PVC) congeners and/or PVC block polymers, copolymers or polymer alloys containing PVC. Higher concentrations of bromine or chlorine are permitted in plastics contained within electronic devices as long as they are not flame retardants, PVC or substances containing PVC.

The marking standard J-STD-609B is also occasionally cited with regard to low halogen compliance.

For more questions and answers, visit the last edition of Assent’s Ask the Experts blog.

Assent’s regulatory subject matter experts frequently participate in events such as webinars to educate compliance professionals. They also inform our clients’ regulatory programs. To learn more, contact  

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