Why do you need a Managed Compliance Program?
Do you have the expertise and up to date knowledge on global regulatory compliance requirement? Increasing volume and complexity of regulations, frequent changes in compliance directives, exemptions and applicable regions, all makes the compliance program more challenging to manage. If you are not aware or not knowledgeable enough of the requirements and regulatory obligations, your product shipment could be stopped, you will be forced to pay high penalties and more over the brand itself will be at stake. A managed compliance program provider always helps to identify the right regulatory obligations you must comply with. The compliance expertise of the service provider will have clear visibility on global regulations and guide you to meet the required obligations. The experience and knowledge coupled with compliance management software platform makes ComplianceXL unique from other service providers.The material compliance platform helps to manage material data and substance compliance information throughout the product lifecycle. It helps in collecting, aggregating, exchanging, and reporting. The automated reporting process will speed up the overall documentation process.ComplianceXL will ensure that you follow all applicable directives, regulations and documentation. Advantages of Managed Compliance Services Below are few key benefits Reduce risk of non-compliance issues – stop shipments, fines and fees Prevention of product/sales held at customs holding up revenue recognition Brand protection and lawsuit protection Provide Insight to global compliance obligations and which will help to expand the markets Reduce compliance program operational costs and software cost that helps to release capital for investment in other areas of your business Improved focus on core business activities – outsourcing with compliance XL can free up your business to focus on its strengths, allowing your staff to concentrate on their main tasks on revenue-generating activities and innovation. Increased efficiency – choosing an outsourcing company that specializes in compliance management can help you to achieve a more productive, efficient service, often of greater quality. Scalability is vital to supporting business growth and development. ComplianceXL can accommodate rapid changes as and when required to meet additional regulatory and documentation requirement. Increased reach –Managed services can give you access to capabilities and facilities otherwise not accessible or affordable Benchmarking – Managed service provider can bring you the best compliance program practiced and leverage on their knowledge and skills. What are differentiators to look for from the managed compliance partner? Expertise in varied global regulations specific to products and regions with up-to-date knowledge Technology platform built on best practices Multilingual supplier engagement team available across time zones Capability to train suppliers on compliance documentation requirements of global regulations Ability to source compliance documentation of custom parts Guaranteed freshness of data Adopting managed services is intended to be an efficient way to stay up-to-date on compliance obligations, have access to knowledge and skills. It also helps to make your business more flexible and agile, able to adapt to changing market conditions and challenges, while providing cost savings and service level improvements. Utilizing the services of Compliance management software allows the client to have all compliance documentation at a central place and keeps the compliance database updated periodically. Required reports can be generated and viewed to ensure corporate governance policies are adhered to. ComplianceXL is your one stop shop to manage all your compliance programs with the proper software. It will ensure that all your compliance needs are catered to and the services utilized in the most appropriate way. ComplianceXL will also ensure that you are updated with the new regulations and the documentation is done on time.
SCIP– A new data base introduced by ECHA
ECHA plans to maintain a database that contains the information on Substances of Concern In Articles or Products. The guideline regarding SCIP database requirements were released on 9th Sep 2019. This information will be available to waste operators and consumers. The idea is to improve the transparency on hazardous substances throughout the lifecycle of an article, including the waste stage. Under the Waste Framework Directive, 2008/98/EC, companies that supply articles that contain SVHC candidates, in concentration above 0.1%w/w, will have to submit enough information to allow safe use of those products/articles to ECHA. The database takes the requirements of Article 33 of the REACH Regulation and provides a mandatory platform for submission of the information as from 5 Jan 2021. Below are the main objectives of database. Decrease hazardous waste generation, by providing substitution for SVHCs. Make information transparent for waste treatment operations. Allowing monitoring use of SVHC in articles and initiating appropriate actions on the overall lifecycle of the products. It includes waste stage also. The information available in SCIP database will help waste operators to understand the hazardous substance, so that material streams can potentially be “cleaned” before recycling and reused in the production of new articles and thus ensure a true and safe circular economy. In addition, the increased transparency on the presence of hazardous substances will help consumers to make better choices when purchasing products and provide information on the best usage and disposal of such articles. ECHA requires information from below categories to SCIP database. EU producers and assemblers EU importers EU distributors, who place articles/products directly to the market. Retailers and other supply chain supplying articles/products directly to consumers are not covered to this obligation. Apart from information on those articles which contain Candidate List substances in a concentration above 0.1% w/w and administrative contact details, suppliers of articles also need to provide the following information to ECHA: information to identify of the article (including picture and characteristics); the name, concentration range and location of the SVHC(s) present in article/Product; An instruction on the safe use of the article, especially to ensure proper management of the article after it becomes waste. Dates to remember: Autumn 2019: launch of a user test group and a stakeholder workshop at ECHA (preliminary date 12 November) Early 2020: launch of the prototype version of the database July 2020: deadline for Member States to transpose the legal requirements into national law 5 January 2021: notification duty kicks in for industry ComplianceXL will help manufacturers, importers and distributers to manage their SCIP database as per ECHA. This will improve the transparency of hazardous substances, while steering clear of any problems related to certain substances and enable more accurate production capabilities.
REACH AUTHORIZATION LIST – 18 NEW SUBSTANCES
On 1ST Oct ,2019, European Commission recommended 18 substances of very high concern for (SVHC) to be added in REACH authorization list. These substances are reproductive toxicants, endocrine disruptors, carcinogens, very persistent and very bio accumulative (vPvB) substances or respiratory sensitizers. They are prioritized due to their high volume and widespread use that can be a threat to human or environment. The European Commission in collaboration with the Member States and the European Parliament, will take final decision on the inclusion of the substances in the Authorization List and on the dates by which companies will need to apply for authorization to ECHA. List of 18 substances included in the ninth recommendation: 4,4′-isopropylidenediphenol (Bisphenol A; BPA) – Toxic for reproduction, Endocrine disrupting properties in human health and environment. It’s found in Epoxy resin hardeners. 1,6,7,8,9,14,15,16,17,17,18,18- Dodecachloropentacyclo[12.2.1.16,9.02,13.05,10]octadeca7,15-diene (“Dechlorane Plus”™) has got vPvB properties .It’s a Flame retardant in adhesives and polymers. Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) with ≥0.1% w/w 4-heptylphenol, branched and linear (4-Hbl) has Endocrine disrupting properties. Affects environment. Used in Lubricants and greases. 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5- dithia-4-stannatetradecanoate (DOTE) is toxic for reproduction. Found as stabilizer in polymers. Reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7- oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2- ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2- oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4- stannatetradecanoate (reaction mass of DOTE and MOTE) – is toxic for reproduction. Found as stabilizer in polymers. 4,4′-bis(dimethylamino)-4”-(methylamino)trityl alcohol with ≥ 0.1% of Michler’s ketone (EC No. 202-027-5) or Michler’s base (EC No. 202-959-2) has carcinogenic properties. Available in printing inks. Dioxobis(stearato) trilead is toxic for reproduction. Used as stabilizer in PVC. Fatty acids, C16-18, lead salts are toxic for reproduction. Used as stabilizer in PVC. Trilead dioxide phosphonate is toxic for reproduction. Used as stabilizer in PVC.; rubber production; mirror backing. Sulfurous acid, lead salt, dibasic has reproductive toxicity. The substance has no registered uses but is recommended based on grouping considerations as it could potentially replace other lead stabilizers in some of their uses. This is to avoid regrettable substitution. [Phthalato(2-)]dioxotrilead has reproductive toxicity. The substance has no registered uses but is recommended based on grouping considerations as it could potentially replace other lead stabilizers in some of their uses. This is to avoid regrettable substitution. Trilead bis(carbonate) dihydroxide is Toxic for reproduction. Found in Artists’ paints. Lead oxide sulfate is Toxic for reproduction. Used in Mirror backing. Cyclohexane-1,2-dicarboxylic anhydride [1], cis-cyclohexane-1,2-dicarboxylic anhydride [2], trans-cyclohexane-1,2-dicarboxylic anhydride [3] (HHPA) has respiratory sensitising properties. Found in epoxy resin hardeners. Hexahydromethylphthalic anhydride [1], Hexahydro-4-methylphthalic anhydride [2], Hexahydro-1-methylphthalic anhydride [3], Hexahydro-3-methylphthalic anhydride [4] (MHHPA) has respiratory sensitising properties. Found in epoxy resin hardeners. Tetraethyllead is Toxic for reproduction. Found as an additive in aviation fuel. 2-methoxyethanol is Toxic for reproduction. Used as a solvent. 2-ethoxyethanol is Toxic for reproduction. Used as a solvent. Once the final dates are out, the selected companies will compulsorily need to apply for Authorization to ECHA. The inclusion of these substances will avoid any further damage and the substances then will be safe to use. Talk to our REACH Compliance Experts – +1 872 529 6162 or Email us at [email protected].
ComplianceXL to help a leading Medical Devices manufacturer in Supply Chain Risk Mitigation and Material Compliance Obligations
Chicago, IL; September 15, 2019 – ComplianceXL is helping a North American Medical Devices manufacturer in their supply chain risk mitigation and material compliance obligations requirements The engagement will cover the entire spread of global compliance regulations such as EU RoHS, EU REACH, CA Prop 65, Medical Devices Regulations, EU Pops, Canada SOR/2014-254, EU Packaging Directive and Natural Rubber Latex compliance data for their complete products/parts in the PLM and ERP systems. The client is a leading manufacturer of medical devices in the North American region, with footprint over 60 countries across the global. The client is specialized in minimally invasive stereoscopic (3D) camera for Neurosurgical, ENT, Arthroscopy and Laparoscopy applications; they are the first to develop 3D-HD System with endoscopes in small diameters. ComplianceXL will run a full managed compliance program that will aggregate, validate, load and maintain all supplier declarations in a central repository. ComplianceXL will constitute a team of compliance engineers who will engage with suppliers to acquire all the necessary information as required by respective compliance regulations. The objective is to gather Full Material Declaration for all parts in the supply chain. Further the data is validated to verify the compliance status of each part: ComplianceXL’s deep expertise in delivering robust supplier engagement programs will benefit from a more secure, scalable and agile supplier communication and compliance documentation. The multi-lingual supplier engagement team at ComplianceXL will engage with suppliers across the globe, at various time zones and ensure accurate compliance documentation. Furthermore, on-demand training is provided to all supply chain stakeholders and ensure proper documentation of compliance records. A web-based proprietary tool – partlinq – by ComplianceXL will enable multi-channel communication and makes the data collection easier. The data flow is controlled by AI enabled algorithms that automates most common parameters and validates compliance information as required. “This approach of combining multi-lingual offline engagement team with an AI enabled online tool will deliver a competitive advantage on a secure platform, enabling the client to accelerate compliance documentation and achieve superior supply chain sustainability”, says C K Bharathan, Head – Compliance Solutions, ComplianceXL. This is a multiyear engagement with the client to cover their entire supply chain and mitigate risks related to global compliance regulations. About ComplianceXL: ComplianceXL is the Compliance Solutions Division of Enventure, a leader in the compliance business since 2003. ComplianceXL is a one-stop solution for all supply chain compliance requirements, ranging from consulting and training to collecting compliance certifications and documentation from suppliers. By implementing a transparent and well-structured compliance program, ComplianceXL enables clients to follow an integrated process, to meet their compliance obligations. Beyond an initial implementation, ComplianceXL also provides ongoing support to maintain compliance to regulations such as RoHS, REACH, CA Prop65, Conflict Minerals, ELV, GHS/OSHA and several other global legislations.
ComplianceXL to help the Communication and Security SystemsMajor in the US with Supply Chain Risk Mitigation and Sustainability
Chicago, IL; August 15, 2019– ComplianceXL has been selected by a Global Leader in Communication and Security Systems to develop a robust strategy for Supply Chain Risk Mitigation and Sustainability, followed by implementation of strong a supplier engagement program. This project is in continuation to the training and consultation program conducted by ComplianceXL to all its stakeholders. In this multi-year contract, ComplianceXL will render services in –material compliance data collection from suppliers across the globe, multilingual supplier engagement across time zones, validating compliance data of standard and custom parts(i.e., both electronic and mechanical), transforming supplier data to match PLM systems, integration to PLM systems and on-going data maintenance. As part of the project, ComplianceXL that provides a more personalized, cross-functional data management platform to improve the client and supplier experience. Supplierlinq.com is a new digitally powered supplier engagement platform by ComplianceXL. It will bring all supply chain stakeholders together in a single, scalable system that makes it easier for the client to accomplish compliance due diligence. Built with over 2 decades of collectively compliance knowledge, the platform helps clients and suppliers to easily and consistently synchronize material data, maintain data standards, respond to requests for Certificate of Conformity, and complete due diligence before the deadline. This engagement between ComplianceXL and the Client will help the client to meet global regulatory requirements for parts and products imported into the European Union.The entire program enables the client to prevent fines,shipment stoppages, as well as create better negotiating capabilities with continued supplier management. “At ComplianceXL, we have developed a robust program by understanding the requirements and expectations of clients and suppliers. Our digitally powered platform evolves with the needs and consolidates the client-supplier touchpoints into a single window that provides standardized processes for material compliance efficiency,” says CK Bharathan, Head – Compliance Solutions, ComplianceXL. About ComplianceXL: ComplianceXL is the Compliance Solutions Division of Enventure, a leader in the compliance business since 2003. ComplianceXL is a one-stop solution for all supply chain compliance requirements,ranging from consulting and training to software deployment and compliance documentation, related to regulations such as RoHS, REACH, Conflict Minerals, CA Prop65, OSHA and other global legislations and directives. By implementing a transparent and well-structured compliance program, ComplianceXL enables clients and all key stakeholders to follow an integrated process, to meet regulatory obligations. Beyond an initial compliance program implementation, ComplianceXL also provides ongoing support to clients for continued compliance to regulations.
Get Ready! European regulation on Conflict Minerals is implemented
The European Union Conflict Minerals Regulation adopted in June 2017, will take effect on 1st Jan 2021, starting with importers, smelters, and refiners of tungsten, tin, tantalum and gold (3TG). It requires the EU companies to ensure they import the minerals and metals from responsible and conflict-free sources only. EU regulation aims at Ensuring EU 3TG importers to meet international responsible sourcing standards, created by Organisation for Economic Co-operation and Development (OECD). Ensuring all the 3TG global/EU smelters & refiners to source the minerals/metals responsibly. Stopping the illegal exploitation of minerals Bringing an end to exploitation and abuse of local communities and mine workers. EU introduces a concept called “Conflict-Affected and High-Risk Areas”. It’s quite different from US conflict mineral reporting. US conflict mineral reporting, which we currently have, is focused exclusively on the Democratic Republic of Congo (DRC) and surrounding areas, but the EU regulation is global in scope, means, not only Central Africa, it could be West Africa (conflict financing in Mali) or Myanmar (problem area for tin). Even though the reporting guideline has been released by EU, they have not specified the exact format and content of reporting. In order to perform due diligence sourcing, importers should have a system in place that provides with the following information. Country of mineral origin, from where minerals come in. Quantity imported. Trade names and types of minerals imported. Supplier name and address. If a mineral is sourced from conflict-affected and high-risk areas, importers must provide additional information and documentation on; Mine from where minerals come in. Where minerals are consolidated, traded and processed. The taxes and fees paid. If an EU importer has not complied with the regulation, then; Member state will order the firm to address the problem within a given deadline and follow up is madeto ensure it does so. Talk to compliance experts at ComplianceXL, to get more insights on the conflict minerals regulation requirements and its effect on your day to day business.
GHS Revision 8 and Major Changes
The UN Economic Commission for Europe has published 8th revised edition of GHS . The electronic version is still not released and is expected to release by end of September 2019. The major changes in the new version are New classification criteria for Chemical under pressure & aerosols New Hazard category A new annex on dust explosion hazards Added Precautionary pictogram Revised precautionary statements New provisions for the use of in vitro/ex vivodata and non-test methods to assess skin corrosion and skin irritation New labelling examples for sets or kits Editorial revision of Sections 2 and 3 of Annex 3 Major changes are summarized below: 1. Classification criteria change for aerosols According to table 2.3.1, aerosols are to be classified in one of the three categories and it will be based on: their flammable properties their heat of combustion if applicable, test results from the ignition distance test, the enclosed space ignition test and the aerosol foam flammability test, performed in accordance with subsections 31.4, 31.5 and 31.6 of the United Nations Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria Listed below are the new aerosol classification criteria Category 1: Any aerosol that contains ≥ 85% flammable components (by mass) and has a heat of combustion of ≥ 30 kJ/g or Any aerosol that dispenses a spray that, in the ignition distance test, has an ignition distance of ≥ 75cm or Any aerosol that dispenses a foam that, in the foam flammability test, has: a heat of combustion of ≥ 20cm and a flame duration of ≥ 2 seconds a flame height of ≥ 4cm and a flame duration of ≥ 7 seconds Category 2: Any aerosol that dispenses a foam that, based on the results of the aerosol foam flammability test, does not meet the criteria for Category 1, and which has a flame height of ≥ 4cm and a flame duration of ≥ 2 seconds or Any aerosol that dispenses a spray that, based on the results of the ignition distance test, does not meet the criteria for Category 1 and which has: a heat of combustion of ≥ 20 kJ/g a heat combustion of < 20 kJ/g and an ignition distance of ≥ 15 cm 2. a heat of combustion of < 20 kJ/g and an ignition distance of < 15cm along with either, in the enclosed space ignition test: a time equivalent of ≤ 300 s/m3 a deflagration density of ≤ 300 g/m3 Category 3: Any aerosol that contains ≤ 1% flammable components (by mass) and that has a heat of combustion of < 20 kJ/g or Any aerosol that contains > 1% (by mass) flammable components or which has a heat of combustion of ≥ 20 kJ/g but which, based on the results of the ignition distance test, the enclosed space ignition test or the aerosol foam flammability test, does not meet the criteria for Category 1 or Category 2. 3. New Hazard category: Chemical under pressure Chemicals under pressure are liquids or solid substances/mixtures, pressurized with a gas at a pressure of 200kPa (gauge) or more at 20 o C in a pressure receptacle other than aerosol dispensers and which are not classified as gases under pressure. Below listed are the classification criteria for chemicals under pressure. Category 1: Any chemical under pressure that contains > 85% flammable components(by mass) and has a heat of combustion of > 20 kJ/g. Category 2: Any chemical under pressure that; 4. contains >1% flammable components (by mass) and has a heat of combustion <20kJ/g or that; 5. contains <85% flammable component (by mass) and has a heat of combustion of <20kJ/g. Hazard statements and pictograms for chemicals under pressure are listed as below. Hazard category Symbol Signal word Hazard statement Symbol 1 Flame & gas cylinder Danger Extremely flammable chemical under pressure. May explode if heated. 2 Flame & gas cylinder Warning Flammable chemical under pressure. May explode if heated. 3 Gas cylinder Warning Chemical under pressure. May explode if heated. 6. New Precautionary Pictograms for “Keep out of Reach of Children” The following pictograms from AISE and JSDA to convey precautionary statement “Keep out of reach of children”. 7. New Labeling Example for Sets or Kits A new example for labelling sets or kit is provided in example 10 appended to Annex7.Small removable inner containers are present in a kit/set. Inner container label The following minimum information mustbe included on the label of each hazardous substance or mixture. Product identifier, and an identifier for each substance or mixture matching the identifier used on the outer packaging label and SDS for that substance or mixture, eg “Reagent 1” and “Reagent 2”. Pictogram(s). Signal word. The statement “Read full label”. Supplier identification (ie name and telephone number). Outer packaging label In addition to the kit identifier, all the required GHS label elements must appear on the outer packaging for each hazard mixture/substance. 8. Dust explosion hazard -A new Annex Annex 11 – Guidance on Other Hazards Not Resulting inClassification, will provide guidance on the identification of dust explosion hazard and need for assessment of risk, prevention, and hazard communication. 9. Minor changes – with regards to precautionary statements for skin irritation and serious eye damage Skin corrosion/irritation- classification to be mentioned as category 1,if the available data is limited & subcategories 1A, 1B or 1C cannot be assigned or as per the competent authority requirement (3.2.2.1.1.2). Serious eye damage/eye irritation-classification category to be mentioned as 2, where the available data is not enough for further categorization, or where the competent authority does not require categorization into 2A or 2B (3.3.2.1.2.1).
ComplianceXL wins Compliance Consulting contract with a leader in manufacturing paper products.
ComplianceXL has been awarded a project to manage compliance consulting, by a global leader in manufacturing paper products. The engagement is designed to perform gap analysis of current compliance practices, develop a customized compliance framework and impart training to client’s stakeholders on EU REACHand CA Prop 65 regulations. The client is known for its products made out of recycling of materials such as cardboard and paper that includes toilet paper, napkin and kitchen towel, thereby promoting environmental responsibility. The client offers a variety of high quality products that are specific to commercial, institutional and individual usage. A Senior Compliance Specialist will perform a detailed Compliance Gap Analysis to – Review compliance procedures, assess current practices, review present compliance documentation and provide a report of gaps thereof. Furthermore, the Compliance Specialist will conduct an in-person training program for all key stakeholders. The Compliance Training includes: Introduction to global compliance regulations, scope of each regulations, substances covered, risks and limits, labelling and reporting requirements. The training will cover REACH and CA Prop 65 regulations and provide insights about various methods, operations, records, reporting of data as per accepted formats. ComplianceXL will provide a tailor-made solution by capturing benefits and downsides for each regulation. A working model and a detailed roadmap will be drafted for easy implementation of compliance practices by the client. “Material Compliance is the significant part of the overall business growth. We have a hard-earned market repute that helps us flourish in the business and assist clients to leverage the experience that we have garnered over a decade. I believe our strength in this area was a key factor in the client deciding to award this contract to ComplianceXL”said CK Bharathan, Head – Compliance Solutions, ComplianceXL. About ComplianceXL: ComplianceXL is the Compliance Solutions Division of Enventure, a leader in the compliance business since 2003. ComplianceXL is a one-stop solution for all supply chain compliance requirements, ranging from consulting and training to collecting compliance certifications and documentation from suppliers. By implementing a transparent and well-structured compliance program, ComplianceXL enables clients to follow an integrated process, to meet their compliance obligations. Beyond an initial implementation, ComplianceXL also provides ongoing support to maintain compliance to regulations such as RoHS, REACH, CA Prop65, Conflict Minerals, ELV, GHS/OSHA and several other global legislations.
Reach SVHC List updated-Four new substances added
On 16th July, the European Chemical Agency (ECHA) has updated REACH SVHC list by adding 4 new substances having properties given below. Toxicity to reproduction Endocrine disruption Very Persistent and Very Bioaccumulative (vPvB) substances Persistent, Bioaccumulative and Toxic (PBT) The decision to include the substances Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) and 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy) propionic acid, its salts and its acyl halides was taken with the involvement of the Member State Committee (MSC). The new substances included in the Candidate List are: 2-methoxyethyl acetate Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP) 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides (covering any of their individual isomers and combinations thereof) 4-tert-butylphenol The last substance on the list that is 4-tert-butylphenol has been added to the list after it was identified as an SVHC by the EUROPEAN commission due to the endocrine disrupting properties it holds. The substances mentioned above are usually used as antioxidants to stabilize polymers, in coating products, polymers, adhesives, as a processing aid in the production of fluorinated polymers and for synthesis of other substances. It is mandatory for any organization dealing with these products in the European Union to communicate the presence of SVHCs in their products above the concentration of 0.1% (weight by weight) within six months of date of substance inclusion in the candidate list by ECHA, for which the latest update is 16th July, 2019. To avoid business continuity risks and to stay compliant, it is best to keep an active check on ECHAs SVHC list. This addition made an increase in total SVHC from 197 to 201. For more information on these obligations, talk to our REACH compliance expert – Call +1 872 529 6162
Does your company fall under expiring RoHS exemptions? Time to check!!!!
When the European Union implemented RoHS, they understood the industry was not ready for a full restriction. As part of the RoHS implementation, exemptions were created for defined specific permitted uses for these substances. Each exemption was assigned an expiry date by which time these specific use cases for restricted substances would no longer be permitted. Below are the exemptions that are getting expired in 2019. Exemption Applicable category * End date 6(a) – Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight 1 to 7 and 10 30 – June – 2019 6(b) – Lead as an alloying element in aluminum containing up to 0.4 % lead by weight 1 to 7 and 10 30 – June – 2019 9(b)-(I) – Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications 1 to 7 and 10 21 – July – 2019 21 – Cadmium in phosphor coatings in image intensifiers for X-ray images until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 8 and 9 31 – Dec – 2019 24 – Lead enabling vacuum tight connections between aluminum and steel in X-ray image intensifiers. 8 and 9 31 – Dec – 2019 30 – Hexavalent chromium in alkali dispensers used to create photocathodes in X-ray image intensifiers until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 8 and 9 31 – Dec – 2019 32 – Lead in solders on printed circuit boards of detectors and data acquisition units for Positron Emission Tomographs which are integrated into Magnetic Resonance Imaging equipment. 8 and 9 31 – Dec – 2019 38 – Lead in solder in one interface of large area stacked die elements with more than 500 interconnects per interface which are used in X-ray detectors of computed tomography and X-ray systems. Expires on 31 December 2019. May be used after that date in spare parts for CT and X-ray systems placed on the market before 1 January 2020. 8 and 9 31 – Dec – 2019 *EU RoHS Categories: Category 1 Large household appliances: refrigerators, washers, stoves, air conditioners Category 2 Small household appliances: vacuum cleaners, hair dryers, coffee makers, irons Category 3 Computing and communications equipment: computers, printers, copiers, phones Category 4 Consumer electronics: TVs, DVD players, stereos, video cameras Category 5 Lighting: lamps, lighting fixtures, light bulbs Category 6 Power tools: drills, saws, nail guns, sprayers, lathes, trimmers, blowers Category 7 Toys and sports equipment: videogames, electric trains, treadmills Category 8 Medical devices and equipment Category 9 Control and monitoring equipment Category 10 Automatic dispensers: vending machines, ATM machines Category 11 All other electrical and electronic equipment Here is the list of Industries that needs to comply before the stipulated deadline. Exemption Material End date Large household appliances Small household appliances Computing and communications equipment Consumer electronics Lighting Power tools Toys and sports equipment Medical devices and equipment Control and monitoring equipment Automatic dispensers All other electrical and electronic equipment 6(a) Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0,35 % lead by weight 30-06-2019 Yes Yes Yes Yes Yes Yes Yes – – Yes – 6(b) Lead as an alloying element in aluminum containing up to 0,4 % lead by weight 30-06-2019 Yes Yes Yes Yes Yes Yes Yes – – Yes – 9(b)-(I) Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications 21-07-2019 Yes Yes Yes Yes Yes Yes Yes – – Yes – 21 Cadmium in phosphor coatings in image intensifiers for X-ray images until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 31-12-2019 – – – – – – – Yes Yes – – 24 Lead enabling vacuum tight connections between aluminum and steel in X-ray image intensifiers. Expires on 31 December 2019. 31-12-2019 – – – – – – – Yes Yes – – 30 Hexavalent chromium in alkali dispensers used to create photocathodes in X-ray image intensifiers until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 31-12-2019 – – – – – – – Yes Yes – – 32 Lead in solders on printed circuit boards of detectors and data acquisition units for Positron Emission Tomographs which are integrated into Magnetic Resonance Imaging equipment. Expires on 31 December 2019. 31-12-2019 – – – – – – – Yes Yes – – 38 Lead in solder in one interface of large area stacked die elements with more than 500 interconnects per interfaces which are used in X-ray detectors of computed tomography and X-ray systems. Expires on 31 December 2019. May be used after that date in spare parts for CT and X-ray systems placed on the market before 1 January 2020. 31-12-2019 – – – – – – – Yes Yes – – 8(b) Cadmium and its compounds in electrical contacts 29-02-2020 Yes Yes Yes Yes Yes Yes Yes – – Yes – 15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages 29-02-2020 Yes Yes Yes Yes Yes Yes Yes – – Yes – 21 Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses 29-02-2020 Yes Yes Yes Yes Yes Yes Yes – – Yes – 27 Lead in — solders, — termination coatings of electrical and electronic components and printed circuit boards, — connections of electrical wires, shields and enclosed connectors, which are used in (a)