The Weekly Pulse: 23rd – 27th January

What’s HOT in our Regulatory World

What are our clients looking at?

This week’s trending sources in C2P

• EU: Batteries and Waste Batteries, Draft Regulation, January 2023
• Rhode Island: Towards a Comprehensive Ban of PFAS in Products, Senate Bill 16, 2023
• Spain: Packaging and Packaging Waste, Royal Decree No. 1055/2022

What is our Content Team talking about?

CONAI Publishes New Guidelines for the Italian Environmental Labelling of Packaging for the Electrical and Electronic Equipment Sector – Freida Gubbins

On 13 January 2023, the Italian National Packaging Consortium (CONAI) published new Guidelines on the environmental labelling of packaging for the electrical and electronic equipment sector. These Guidelines are available in Italian and for download here.

The Guidelines contain a detailed FAQ section and example labels. Questions answered by the Guidelines include:

• What is meant by household EEE sales packaging?
• What is meant by professional EEE sales packaging?
• Are the instruction manuals typically found in electrical and electronic products considered packaging?
• In the case of large appliances (e.g. refrigerators, washing machines, ovens) for which an installation service by a professional is generally required, what should I do with regard to the environmental labelling obligations for the packaging of these products?
• In the case of purchasing electronic products already packaged abroad and then distributed as they are without adding other packaging, who is responsible for the correct affixing of the environmental labelling?
• Electronic products already packaged from abroad and re-packaged before distribution on the national territory, who is responsible for the correct affixing of the label?
• How can so-called «neutral» packaging (such as: protective corners, shrink films and interlayers) used as transport packaging for washing machines be labelled?

The Guidelines also provide example labelling instructions for the following products:

• TV/ B2C packaging
• Washing machine/ B2C packaging
• Smartphone/ B2B and B2C packaging

In addition to the above Guidelines CONAI has published a full series specific to different sectors and product packaging. The full series of Guidelines are as follows;

• Packaging Labelling Guidelines for Packaging manufacturers, October 2022 – available in Italian only here.
• Packaging Labelling Guidelines for Self-Adhesive Tapes, October 2022 – available in Italian only here.
• Packaging Labelling Guidelines for the Chemical Sector, October 2022 – available in Italian only here.
• Guidelines for Businesses: Environmental Labelling for Packaging, October 2021 – available in English here.

What are our Knowledge Partners talking about?

IEC 62474 Updates to Declarable Substances List (DSL) – 2023 January – Walter Jager, ECD Compliance

The IEC 62474 declarable substance list (DSL) was updated to Version D26.00 on January 17, 2023, coinciding with ECHA’s update to the EU REACH Candidate List.  

• All nine SVHCs that were added to the Candidate List are included in the DSL update based on the potential use of the substances in EEE;
• A significant addition to this update is a new substance group for Per- and poly-fluoroalkyl substances (PFAS) based on the U.S. State of Maine regulation.

IEC 62474, the International Standard for material declaration for the electrical and electronics industry includes the EEE industry DSL, material declaration data exchange requirements and format, material classifications and exemption lists.  The parts of the standard that require periodic updates (such as the lists) are published online in the IEC 62474 database and are updated using an expedited IEC process.

EU REACH Candidate List SVHCs

The nine recently added SVHCs are listed in the first nine rows of Table 1 below. Two of the entries are substance groups with reference substances provided in the Reference Substance List (RSL). These are:

• Perfluoroheptanoic acid and its salts with four reference substances
• Bis(2-ethylhexyl) tetrabromophthalate with one reference substance

PFAS Declarable Substance Group (DSG)

The new substance group for Per- and poly-fluoroalkyl substances (PFAS) is essentially a super group of fluorinated organic chemicals containing at least one fully fluorinated carbon atom. The addition is significant given the large number of individual substances in the group and the broad range of applications in the electronics sector.

The basis for adding the entire PFAS substance group to the DSL is the USA State of Maine Public Law, Chapter 447 (LD 1503, 2021) PFAS regulation – reporting obligations came into effect on January 1, 2023. The reporting threshold is “Intentionally added”, potentially triggering reporting obligations for even small levels of PFAS.

The challenge for many downstream product manufacturers is determining which of these substances are used in their supply chain and the applications in which they are used. Many manufacturers request their suppliers to provide a material declaration that includes at least the substances on the IEC 62474 DSL.  By adding PFAS to the DSL, it signals to the EEE supply chain that they need to declare all PFAS substances that were intentionally added anywhere in the supply chain so that their customers can meet their regulatory obligations.

However, identifying a reasonable set of PFAS reference substances that may be used in electronic products was a challenge given the large number of potential PFAS (over ten thousand) and that the scope of potential applications in EEE is not fully understood. A total of 629 PFAS reference substances were added to the IEC 62474 RSL. It provides an initial (indicative) set of reference substances; however, the list is not complete and is expected to be modified periodically over the next few years as additional PFAS substances are identified in EEE and other substances on the list are determined to not be relevant to EEE. 

(For the full commentary, including the table, please refer to C2P)

What are our clients asking about?

“Do you know if the Jordan WEEE regulation requires products to have the “crossed out wheelie bin” mark as is required in the EU?”

Answer by Michelle Walsh & Yasmin Ali

We have reviewed the following law for you: “Jordan: Waste Electrical and Electronic Equipment, Instruction, February 2021”. There is no requirement to have the crossed out wheelie bin mark under this regulation.

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