Design Chain Associates March 2009 Newsletter

It's been a while!

The DCA newsletter has been on hiatus since June last year, albeit with a couple alerts in the interim. It's not that nothing has been happening - on the contrary, plenty of new regulations and requirements have been surfacing and we have been busy supporting clients on them and many other issues. Forcing a breather for newsletters has unfortunately never been our strength - despite our desire to produce them at least quarterly. So we apologize for our absence from your inbox.

This issue contains a wide variety of topics - from a review of our current service offerings, to newly exposed and newly defined ones, as well as discussions of a number of environmental performance issues from Carbon, to RoHS to REACH. Enjoy!

Supply Chain Carbon Footprint Accounting - it's coming

The Carbon Disclosure Project Supply Chain Report 2009 found that there are four key elements to effectively managing carbon and climate change in the supply chain:

Improving suppliers' emissions management, reporting and accuracy of data;
Influencing and supporting decreases in suppliers' actual emissions and impacts;
Reducing own emissions by considering "carbon costs" in procurement decisions; and
Managing supply risks related to future climate change impacts.

The CDP Supply Chain Report 2009 also acknowledged that very few companies have an understanding of the carbon emissions resulting from their supply chains and are looking for information and guidance.

In order to address this problem, the World Resources Institute and the World Business Council for Sustainable Development, via the Greenhouse Gas Protocol Initiative, have started a two year process to develop two new GHG Protocol publications. These are expected to become international standards for product lifecycle reporting and corporate value chain accounting. DCA is actively involved in the development of these standards.

For more information or if you need help in determining your Carbon Emissions visit our Carbon page.

China WEEE - A Free Translation!

China continues implementing its WEEE regimen. The Regulations on Recovery Processing of Waste Electrical and Electronic Products was signed into law on February 25, 2009 and released to the public on March 4, 2009. One of our intrepid clients took it upon themselves to translate it internally and was gracious enough to allow us to make it available to the rest of the industry for free! You may download it from our China RoHS website. So a big "thank you!" goes out to our client, who wishes to remain anonymous.

This is a "framework" regulation, and as such has little in the way of actionable content for the electronics industry. It defines what is needed, which entities need to produce it, and the in-force date: January 1, 2011. Some of the highlights:

A Catalog will identify products subject to the regulation
A fund will be established that will subsidize the cost of recycling. Manufacturers, importers or their agents will pay in to the fund
Products will require a mark of some kind
Recyclers will have to go through a qualification process and will be subject to on-site audits

DCA Services: New and Review

DCA provides services in three primary classes:

We would like to feature a couple service offerings that resonate with our clients today, as well as some that DCA has been inexplicably quiet about in the past.

First, there are two areas where we are offloading some relatively tedious work from understaffed organizations:

Environmental regulation tracking and filtering. This is time-consuming and detail-oriented work. We are providing services at a variety of levels for many clients, from simply letting them know when there is activity on one or more regulations they're particularly interested in to tracking the entirety of worldwide regulation and filtering it down to actionable requirements that could impact their specific product lines in specific markets.
Responding to customer-specific disclosure requirements. IBM has its PCD form; Fujitsu and other Japanese companies have their JGPSSI form; HP has its new REACH form; and there are many others. You may or may not already have all the data in-house but don't have the time to collect, analyze and roll-up the data in the manner required by these customer requests. We have extensive experience dealing with these complex forms and are helping several electronics OEMs with reporting required by their customers. See the next item for more information on this.

Next, there are actually many areas in which we've provided services for clients that have not been represented on our website. We have recently fired our Vice President of Anonymity and are ready to share them with you. The areas are

Surveys
White Papers
Mergers & Acquisitions
Due Diligence Studies
Turnaround & Rapid Review
Investigative Reports
Intellectual Property Services
Benchmarking
EMC/Safety

You can read all about them at our new Expert Services page.

IBM PCD, Fujitsu JGPSSI, JAMP - Substance Reporting Form Madness

So just how tired are you of receiving custom environmental data forms asking for the same, and sometimes different, information on your products from your customers? You can't simply tell them to "go away" - the customer is always right, after all! Having been responsible for a custom form early on ourselves, we understand what the drivers are for them. While we would like to see everyone adopt IPC 1752, that's simply not going to happen for a variety of reasons (but we hope that starts to change with the upcoming release of version 2.0).

In light of this, as well as the fact that we have been doing this sort of work for years, DCA has formalized a standard service offering to help companies manage their response to requests for product material composition. We call it Product Chemical Content Assessment (PCCA). An ever-growing number of environmental compliance regulations require quantitative reporting of substances of concern contained in products. Many companies selling worldwide have developed their own data formats and systems to help them cope with and track this, but that drives the challenge of filling out multiple different forms to their customers. The tasks of data collection, assessment of chemical content, and correct form completion can be especially daunting. DCA, in conjunction with its data partners, provides our clients with data where needed (we can use information you already have), and offloads the tasks of analysis and form completion from them. We provide a complete package, including deliverables to your customers, explanatory notes to help you intelligently respond to the request, and backup/due diligence data as collected. DCA's PCCA Program is available immediately. Contact us for more information.

This Just In: DCA's President selected to join California's Green Ribbon Science Panel

Two laws recently signed by California Governor Arnold Schwarzenegger will provide the foundation for advancing the California Green Chemistry Initiative. Chapters 559 and 560 are first steps in developing the information needed to protect Californians from the adverse effects of toxic chemicals, by providing information about chemicals in consumer products.

Chapter 559 directs the Department of Toxic Substances Control (DTSC) to develop regulations that create a process for identifying and prioritizing chemicals of concern, and to create methods for analyzing alternatives to existing hazardous chemicals. It also allows DTSC to take certain actions following an assessment that range from "no action" to "restrictions or bans."

The law also establishes a Green Ribbon Science Panel made up of experts to provide advice on scientific matters, chemical policy recommendations and implementation strategies. The Panel will ensure that implementation efforts are based on a strong scientific foundation.

We are honored that Mike Kirschner has been selected to be a member of the Green Ribbon Science Panel.

RoHS 2 Updates

Seems that everyone and his mother have been putting on webinars, both paid and free, about what is being called "RoHS 2". Except DCA. To be frank, we considered doing one early on; but in light of the fact that there is a parliamentary election coming up in June and therefore little is expected to occur that is of substantive interest before September, we felt it would be premature to weigh everyone down with what is ultimately little more than speculation. You can be sure that we are on top of it (and judging from the content of some of the aforementioned webinars, more so than many others) and when we have something useful to say we'll let you know.

In the meantime, what may be most useful at the moment is...lobbying. Kris Pollet, our Director of EU Law & Policy, is in fact registered as a lobbyist both at the European Parliament and at the Commission. Contact Kris to discuss how lobbying could be helpful to your company or industry association if you're interested.

And in the "me too" department, both Turkey and Ukraine have issued RoHS regulations. Neither is exactly the same as the EU's...or any other country's for that matter. If you didn't already know this then you might want to talk to us about our environmental regulation tracking and filtering service.

REACH, etc. Update

REACH requires communication along the supply chain of certain substances in order to determine whether their presence needs to be disclosed in articles or not. There are fifteen to be exact, for now, that meet the requirements defined in Article 33 of the regulation for disclosure. The Chemical Secretariat (or ChemSec), a government-funded environmental NGO in Europe, has produced a list of 267 more substances they say meet the definition of "substances of very high concern" (SVHCs) as described in Article 57 of REACH. Could this influence or even drive future candidate SVHC selections? Stay tuned.

As with all other environmental leadership regulations promulgated by the EU government, there are efforts to duplicate, and to leapfrog, REACH. Both China and Korea have expressed their intents to pass a REACH-like regulation, while California has less than two years to determine whether the Green Chemistry Initiative will reflect or build on REACH. The laws mentioned above require development of a regulation by January 2011 as well as a database to disclose chemical information. California's Department of Toxic Substance Control is trying to be very open about the regulation development process (those that liken law-making to sausage-making and how it's better not to know the process of producing either may have a point) and they are looking for input from all stakeholders. If California, the eighth largest economy in the world, is among your markets then you're a stakeholder. Consider getting involved - you can talk to us about how to do so.

Bottom line: As you comply with REACH, think more generally about the problem it's trying to solve and how you should change your business processes to get, and stay, ahead of the EU, China, Korea, California, and who-knows-where-else. See our entry later this week at Technology Forecasters' BLOG for more on developing a long-term strategy for environmental compliance based on projecting regulatory trajectories.

And by the way, a REACH stakeholder comment period is open right now, through April 14. Should you have something to say about any of the seven SVHC substances ECHA has proposed to go through the Authorization process, now is your chance.

DCA Out and About

25 March 2009: Green Manufacturing: Business Strategies for Sustainability Birmingham, UK

Kris Pollet discusses REACH: how to ensure supply chain SVHC disclosure & anything else product manufacturers should beware of. Kris will also provide a legislative overview of issues that are relevant for green manufacturing.

More to come! Stay tuned with our Events page.

Reading Materials

DCA editorials and articles published over the past few months include:

The Greenest Notebook Computer...Fact or Fiction?
February 25, 2009 - Green SupplyLine. Apple's making some pretty extraordinary claims; how true are they?

When Product Safety and the Environment Appear to Collide: The Defeat of the Candle Flame Ignition Requirement
January 2009 - Conformity. In 2000, the U.S. National Association of State Fire Marshals (NASFM) began to promote the idea that electronics in the home could be susceptible to ignition by a candle flame, and proposed that electronic enclosures should be designed to resist ignition from such an event. This is the inside story of why that was a bad idea, and how a world-wide coalition of scientists, researchers, NGOs, firefighters, and others rescued the electronics industry from creating an environmental disaster.

Impact of Environmental Regulations on Electronics Manufacturers
December 2008 - International Conference on Resource Recycling. Mike Kirschner discusses how and why the industry is unprepared for environmental regulation of its products.

One Bad Apple: Counterfeit parts and subassemblies have a major impact on the electronics industry
November 2008 - CIE. Tom Valliere considers the effects of counterfeits on the electronics supply chain.