Latest Version of CMRT v5.11
CMRT 5.11 is the most recent version of the template and it was released in 27th April 2018. It replaces CMRT 5.10.The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. The template also facilitates the identification of new smelters and refiners to potentially undergo an audit via the RMI’s Responsible Minerals Assurance Process (RMAP). Read more
Conflict minerals in EU – What it means for you and your business.
It’s a most conversable topic in the environment and material compliance space; In 2010, US Congress passed the Dodd-Frank Act, with rules requiring SEC listed companies to disclose their use of conflict minerals viz., Tantalum, Tin, Tungsten or Gold (3TG). The purpose of the rule was to keep a check on exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the DRC region and is contributing to an emergency humanitarian crisis. Starting January 2021, a new law will apply across the EU – “the Conflict Minerals Regulation” As the world’s biggest trading bloc, the European Union has a responsibility to contribute to fair, transparent and value-based trade. This is a big step in that direction. It aims to help stem the trade in four minerals such as Tantalum, Tin, Tungsten and Gold, which are used in the production of everyday products like mobile phones, cars and jewellery; which sometimes finance armed conflict or are mined using forced labor. The structure of this guidance defines frameworks, policies, measures and supplements to determine due diligence processes for responsible supply chain of minerals from conflict-affected and high-risk areas, consistent with applicable laws and relevant international standards. A Five-Step Framework: EU importers will have to carry out checks on their supply chain by following a five-step framework, as defined in the ‘Organisation for Economic Co-operation and Development (OECD)’ guideline: Inside and outside the EU Indirectly, the regulation affects smelters and refiners of Tantalum, Tin, Tungsten and Gold, both inside and outside the EU. This is because EU importers of minerals and metals will need to make sure they source from responsible smelters and refiners i.e.; the regulation focuses on conflict minerals from all “conflict-affected and high-risk areas” around the world. In this way, the EU regulation is different from the US rule, which focuses on conflict minerals only from the Democratic Republic of the Congo and adjoining countries. For “upstream” companies who import raw materials to smelting and refinery plants in the EU. This covers the vast majority of such metals and minerals imported to Europe. The particular needs of small companies will be catered to so as to avoid subjecting them to overly cumbersome procedures, by exempting recycled minerals, and imports of very small volumes. For “downstream” companies, that use the refined forms of these metals and minerals in components and goods, the Commission will now carry out a number of measures. These include the development of reporting tools and standards to further boost due diligence in the supply chain, as well as setting up a transparency database. Those downstream operators who import refined, metal-stage products into the EU will be covered by the mandatory obligations. Through a review clause, there is also the possibility for the Commission to propose further mandatory obligations for the downstream supply chain if deemed necessary. Third party report In addition to the framework, companies are also required to provide third-party audit reports on smelter and refinery diligence practices. They must identify and assess the risks of adverse human rights impacts in their supply chains. Importers that pursue risk mitigation efforts as they continue to trade with, or even if they temporarily suspend trade with, certain suppliers are required to consult with suppliers, government authorities, civil society organizations, and other third parties on a risk mitigation strategy. How do you ensure compliance? One of the key challenges that companies face today is huge gap in supply chain traceability and related documentation, which is critical to make the compliance assessments and declarations. The Supplier base is today not able to deliver the required compliance data, such as Certificates of Compliance or Material Source information, which is critical for a legitimate compliance program. Enventure is today a leader in the compliance space, providing a host of solutions that enable customers to meet their regulatory compliance obligations. With services ranging from Consulting to Gap Analysis to Training and Data Collection, Enventure is able to provide comprehensive solutions, which are tailored to customer specific needs and priorities. Our unique ability to handle standard off-the-shelf parts, as well as custom parts sets us apart from the competition and makes the parts coverage best in class, since 2003, Enventure has assisted over 600 global corporations in fulfilling their regulatory & environmental compliance requirements within stipulated timelines, and with high levels of cost efficiency. Our customers include OE Manufacturers, Contract Manufacturers, as well as Distributors and Retailers.
The Latest Version of CMRT 5.10 – What’s New?
The CMRT or the Conflict Minerals Reporting Template, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information regarding 3TG minerals (Tantalum, Tungsten, Tin, Gold), it’s country of origin and smelters and refiners. In order to help companies improve on their compliance and handle effective sourcing from high-risk areas, RMI has introduced this template for a structured compliance reporting. The CMRT is being revised on a regular basis depending on the supplier requirements and Smelter/Refiner (SOR) analysis, the previous CMRT 5.0 version update was released on May 12, 2017 and now the latest version CMRT 5.10 is released on December 1, 2017. List of changes in the updated version: Corrections to all bugs and errors Update to ISO country, state and province lists Enhancements which do not conflict with IPC-1755, Updates to the Smelter Reference List and Standard Smelter List Change from .xls to .xlsx format Along with this, there have been updates to the smelter list. The next version of the CMRT is expected to be released during April 2018, to make the compliance reporting processes easy and convenient. Click here to Download the CMRT from Responsible Minerals Initiative (RMI) website.
CA Prop 65, Legislation!
What prompted the need for Prop65? Proposition 65, which is officially called the Act of Safe Drinking Water and Toxic enforcement, was first enacted as a part of the ballot initiative in the year 1986. This proposition was designed to protect the sources of drinking water in the State, such that they are safe and are not contaminated with the deadly carcinogenic chemicals that are likely to cause reproductive ailments and birth defects. This enforcement also requires the various businesses to inform and educate the Californians about the exposure to such chemicals. In such situations, businesses should reach out to the right companies that will provide value with regard to the proposition 65 compliance services. The agencies providing these services will assist in the certification as well as the implementation of the process of compliance assurance. And what is the impact if businesses do not comply? The enforcement of this law is carried forward with the civil lawsuits that are posed against the violators. These suits can either be brought by the Attorney General of California or any district or city attorney. Private parties too can bring these lawsuits but they can do so only after they provide a proper notice about the alleged violation. According to this regulation, if any product (including both your food and supplement) which is sold in California comes with chemical substances that has been listed in the list of Prop 65 as a chemical that is likely to cause reproductive ailment or cancer, a warning is issued on the product. This warning becomes even more relevant when the chemical exposure is found to be above the level of average safe harbor. A business charged with violating this policy can be subjected to civil penalties rising up to $2500 every day, for each specific violation. On failing to comply with these regulations, your company will be issued a non-compliance notice of two months (also known as the notice of Violation), which again might lead to a court settlement, if an outside settlement is not worked upon. The fees of settlement can cause your company to lose a staggering sum of ten thousand to hundred thousand dollars. As a result, you cannot ignore complying with this specific regulation. Guidelines to help businesses get compliant Businesses can conduct supply chain analysis which will indicate the areas that require attention. Proper analysis and screening for the chemicals used in formulating the products should be conducted, and businesses can consider outsourcing for California Prop 65 compliance. *Click here to download Enventure’s Case study on Conflict Minerals Compliance* Businesses should conduct analysis and screening for the chemicals used in formulating the products. Proper strategies with regard to compliance should be incorporated. Companies should prepare positional statements with regard to the prop 65 guidelines. Exposure assessments should be conducted for evaluating whether the product is well complaint with the given regulations and whether it might require a warning. Follow these guidelines for proper and consistent prop 65 compliance management and for hassle free legal proceedings associated with it.
Additional Four Elements – ROHS 2015/863
Directive (EU) 2015/863 has Amended EU RoHS to Restrict 4 New Phthalates: DEHP, BBP, DBP and DIBP Bis(2-Ethylhexyl) phthalate (DEHP): max 0.1%: DIBP is an odorless plasticizer and has excellent heat and light stability. It is the lowest cost plasticizer for cellulose nitrate and is widely used in nitro cellulose plastic, nail polish, explosive material and lacquer manufacturing etc Benzyl butyl phthalate (BBP): max 0.1%: BBP is a phthalate that is mainly used as an additive for plasticising PVC , perfumes, hair sprays, adhesives, glues, automotive product and vinyl floor coverings etc. At present, BBP is banned in all toys and childcare articles ( European Directive 2005/84/EC) and in cosmetics which includes nail polish as it is considered to be carcinogenic, mutagenic and toxic to reproduction. Dibutyl phthalate (DBP): max 0.1%: Dibutyl phthalate (DBP) is a commonly used plasticizer and is found naturally in small quantities in cloves. It is soluble in various organic solvents, e. g. in alcohol, ether and benzene and suspected to be an endocrine disruptor. It is also used as an additive to adhesives,printing inks and as an ectoparasiticide (drugs which are used to kill the parasites that live on the body surface). Diisobutyl phthalate (DIBP): max 0.1%: DIBP is a phthalate and an additive used to keep plastics soft or more flexible (plasticiser), often in combination with other phthalates.DIBP has very similar properties to DBP which was banned in toys and childcare articles as well as in cosmetics, it may therefore be used as a substitute for instance in PVC, paints, printing inks and adhesives. Grace Periods are given to DEHP, BBP, DBP and DIBP as they will be restricted from 22 July 2019 for all electrical and electronic equipments apart from medical devices, monitoring and control equipment which will have an additional two years to comply by 22 July 2021.These are chemicals which are added on top of the existing list which consists of the following Cadmium(Cd): 0.01%;Mercury: 0.1%;Lead(Pb) : 0.1%;Hexavalent chromium (Cr6+) : 0.1%;Polybrominated biphenyls (PBB): 0.1 %;Polybrominated diphenyl ethers (PBDE): 0.1 %. It shall be noted that above maximum concentration values apply to each homogeneous material rather than a product or a part itself. Here for instance a homogeneous material means material of uniform composition throughout which cannot be mechanically separated into different materials.Some electrical and electronic products are out the scope of EU RoHS 2. Military equipment, large-scale stationary industrial tools, large-scale fixed installations, active implantable medical devices, and photovoltaic panels are excluded from RoHS.Batteries and package materials are also out the scope of RoHS since they are subject to different directives.In addition to that, certain applications are exempt from RoHS restrictions (For example, Cadmium in helium-cadmium lasers).