New York joins in the club of PFAS substance’s ban in Apparels and Clothing
What is PFAS? PFAS, or per- and polyfluoroalkyl substances, are a group of manufactured chemicals that have been widely used in a variety of industrial and consumer products that leads to cause health problems such as cancer, liver damage, and developmental issues. As a result, US (United States) Environmental Protection act (EPA) has taken the necessary actions which as follows. Developing new drinking water standards for PFOA and PFOS, two of the most well-studied PFAS compounds. PFAS monitoring in public water systems is required New York PFAS restriction: New York also started banning of per-and polyfluoroalkyl substances which are comes up in clothes and apparels after California’s steps. The New York has banned the PFAS’s substances in food packaging will be effective from December 31st, 2022. After that on December 30th, 2022, Kathy Hochul who is New York Governor has signed a bill which will help to restrict the PFAS’s substances in Clothing and apparels effectively by December 31st, 2023. Even on last year Q3, California’s government has banned the PFAS substances in Clothing. The Golden States’ law also starts restricts the PFAS Substances on the Sales & Distribution on Clothing’s & apparels effectively by Jan 1st, 2025. Compared to California’s laws and some other similar laws, New York Law is less detailed. There are few details about finding the alternate with less toxic where are California’s Law prescribes the submission of ‘Certificate of Compliance’ by the distributors and manufactures. The main difference between the two laws is, both intended to restrict the use of PFAS Substances in Clothing where California also address the use of PFAS substance levels 100ppm by 2025 & 50 ppm by 2027. While other states laws also restrict the PFAS in garments which included California & Washington in addition to their existing regulations. And Vermont and Massachusetts states could affect the PFAS garments with pending legislation. However, this Law is not applicable to the Professional uniforms or the outerwear which are intended for extreme conditions. The detailed instructions will release to explain this law which will address both the dangerous firefighting and wet-weather conditions. However, for now, PFAS will provide double functionality in firefighter clothing, as it can be used as flame-suppression foams and fire-suppressive clothing. In addition, PFAS also have a water-resistance, which means the material does not become wet and heavy while being used. This bill going to ban the use of PFAS substances in all clothing’s by December 31st, 2023. A better understanding of the use of PFAS in apparel products is still developing, but New York apparel companies will need to ramp up their analysis in order to meet the December 31, 2023, compliance deadline.Speak with our PFAS specialists if you would like more information about these chemicals and the potential regulatory and litigation risks associated with them.
Benefits of Outsourcing Compliance Documentation
Material compliance documents are an obligation for whole supply chain irrespective of their role as either producers/distributors/importers/exporter. Compliance documents are the only and main source of hazard communication declaring the material composition and the threshold of their presence. These declarations in turn help measure the impact of materials on environment and health through various regulations and directives. Regardless of industry, all manufacturers/importers are required to obtain compliance documents as required by applicable regulations / directives regarding parts, components, and chemicals of finished goods. The suppliers of these parts or components have to certify that these components are devoid of certain harmful substances which are restricted or banned. Around the globe, there are many regulations/directives that set threshold levels for the use of these hazardous substances in components. Some of the regulations / directives are RoHS, REACH, Prop 65, SDS, IMDS, TSCA and Conflict Minerals which are exclusive to particular countries. Besides this, there are other global regulations. Challenges with Compliance Documentation. Managing multiple documentation requirements is cumbersome, and it poses a huge challenge to all stakeholders, such as suppliers, manufacturers and sellers. It’s generally not a feasible option to have dedicated teams spread across the globe to handle the compliance document details and maintain a repository of the same. Needless to say, Compliance regulations are ever changing and monitoring change can be quite tough Multiple suppliers mean multiple compliance documents. Ensuring that they are all valid, duly updated is a big concern for manufacturers. Benefits of outsourcing compliance Documentation The basic need of outsourcing compliance documentation boils down to addressing the challenges above. Having a structured compliance program is essential to any process. It’s wise to outsource the entire management and maintenance of compliance documentation to a centralized system which has the ability to handle all challenges, thereby saving money and time which is extremely crucial to the company. It also reduces the burden and improves the focus of the company on relevant and critical areas that need attention. High Availability of compliance specialists: Lack of locally available resources is one of the primary reasons for outsourcing. The utilization of structured processes, combined with access to subject matter experts, produces a significant increase in efficiency and quality, and facilitates seamless execution of end-to-end processes, from compliance assessment to corrective action. Keep track of dynamic needs of compliance regulations: The task of tracking rapid, continuous, global regulatory changes is not only difficult but also expensive. Therefore, organizations often experience higher operating costs and lower quality compliance solutions. Deploying compliance technology platform: By letting experts handle compliance processes, you can take advantage of already existing technology platforms with your outsourcing partner, instead of reinventing them. Flexibility to scale deployment of technology, implementation engineers and reporting resources as needed, supported by tools that provide predictive trends and insights. Effective cost reduction: By reducing the burden on internal infrastructure and resources, organizations can focus on their day-to-day business and let compliance specialists solve issues for them. A third-party company can be used to deliver operational processes at high levels of quality, while providing cost-effective services and releasing internal resources for revenue- generating activities. The business case for outsourcing compliance versus running an in-house compliance operation may need to be developed and considered by each organization, which may require investing ever more talent and resources. We can help you understand how to benefit most from outsourcing compliance documentation. Talk to one of our Compliance experts today.
All you need to know about Extended Mineral reporting template (EMRT) by RMI
In October of this year, the Responsible Mineral Initiative released a free, standardized report template, EMRT (Extended Mineral reporting template) v1.0. The purpose of this report is to gather compliance documents about Mica and Cobalt to be used in due diligence. In order to reduce costs and simplify supply chain surveying for downstream stakeholders, the EMRT was developed collaboratively by RMI members. The EMRT facilitates the exchange of information, such as the country of origin and the processors used to process minerals, along the supply chain. As a result, the company will be able to perform its due diligence for ensuring a responsible supply chain of minerals, refiners, and processors from high-risk and conflict-affected areas. EMRT focuses on the cobalt supply chain and natural mica supply chain at the moment. CMRT and EMRT are fundamentally different in that CMRT facilitates data exchange necessary for Dodd-Frank Act compliance through section 1502 of the Act. In the meantime, there are currently no regulatory requirements in place to ensure compliance for cobalt or mica. In addition to being provided to the customers, completed EMRTs can be posted on the company’s website as a good practice measure. Currently, RMI does not collect EMRTs. High-risk and conflict-affected areas are defined by the OECD as those with an armed conflict, widespread violence or other risks of harm to people. It can be an international or non-international conflict, involving two or more states, or it may be a liberating conflict. In high-risk areas, potential instabilities, institutional weaknesses, breakdowns in civil infrastructure, and widespread acts of violence are common. Cobalt refiner due diligence standard Version 1.0 was developed jointly by RCI (Responsible Cobalt Initiative) and RMI (Responsible Mineral Initiative). The standard is in effect until December 31, 2021. A new version of the Cobalt refiner due diligence standard, Version 2.0, will take effect on January 1, 2022. According to the schedule of release, the next version of EMRT is expected to arrive in 2022.
Key elements of Material compliance documentation
A Material compliance document is a comprehensive list of all the ingredients and substances within a product or a part. The document provides the percentage weight of each individual substance or material in the part and the percentage weight of each substance that has been intentionally to mixed with other substances. A typical example of Material compliance document is here: The important elements in a Material Compliance Document are: Component: A component is a combination of materials that are formed into a single mechanical or electrical part produced to support to bigger product. The major components could be microprocessors, plastic enclosures/boxes, batteries, capacitors, fan belts, gaskets, etc. Homogeneous Material: Any material that is made of uniform properties and which cannot be separated by actions such as cutting, crushing, heating, or electrocuting processes. For example: Mold Compound, Lead frame, Ceramic, and many more. Substance: Any element and its compounds in the natural state or produced as a composition by any manufacturing process can be defined as substance. For example: Fused Silica, Carbon Black etc. CAS number (#): Chemical Abstract System (CAS) registry numbers acts as identifier of various chemical compositions and are assigned to each chemical to keep it unique. The CAS is assigned in sequential system and is an international standard as since 1957 and made available under CC-BY-NC license at ACS Commons Chemistry. For example: the CAS# for Graphite is 7782-42-5. PPM: PPM is the abbreviation for “parts per million”, this is the standard measuring unit for chemical and its composition concentrated in a product or a part. The weightage percentage is calculated like this: 1 ppm = 1 mg/kg = 0.0001 % by weight. Are you struggling with accurate compliance document creation and collection COCs from suppliers? Talk to one of our Compliance Documentation Specialists today!
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.
Annex II of the ELV directive relaxes rules for automotive system development
Automotive hardware design is a lucrative area for mechanical engineering professionals – but fraught with environmental compliance management issues. As well as GADSL and the international material data system, there’s also the ELV (end of life vehicle) directive. Like the RoHS and WEEE compliance schemes, ELV restricts the use of four toxic metals – lead, cadmium, mercury, and hexavalent chromium. However, the EU now realizes there are certain applications where the use of these substances cannot be avoided and have relaxed the rules accordingly. ELV includes mechanical design (Unlike the WEEE/ROHS directives, which focus on electronic and electrical equipment). For example, ELV covers the use of lead in galvanized steel; not just sheet metal, but that used for machining purposes and hot-dip galvanized steel components. These have been subcategorized and clarified. Other exemptions cover the use of lead in vibration dampers and lead in glass and ceramics. The latter category covers VHDL design and even FPGA design, as it describes lead used in dielectric ceramic materials of capacitors, both in integrated circuits and as discrete semiconductors. Interestingly, a new exemption has been added for lead-containing thermoelectric materials used in automotive system designs which reduce CO2 emissions. New changes regarding the use of hexavalent chromium in absorption refrigerators (used in motor caravans) and mercury in lamps were also described. In many cases, existing exemption dates have simply been shifted, or wording changed. In others, the changes are more significant. We at Enventure Technologies offer a wide range of services to the auto industry, including data cleansing solutions to aid ELV compliance management.