conformity packet 1680.2 4 - green electronics council...sample conformity packet 1680.2 4.1.1.1...
TRANSCRIPT
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Conformity Guidance 1680.2: 4.1.3.1 Required: Reporting on amount of mercury content in light sources
1680.2 4.1.3.1
Applicable Interpretations,
Clarifications, Outcome Reports
Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember
No EPEAT Clarifications or IEEE
Interpretations Available
Outcomes Reports
IE 2015-03
IE 2014-02
IE 2013-04
Declaration of number of mercury
containing light sources in product with
the amount of mercury1 in each light
source AND
Document to support listed mercury
amounts (e.g. analytical test data,
supplier tech sheets) for each light
source.
OR
Copy of representative aggregated
mercury content report
If declaring that this criterion is not
applicable (N/A), evidence that the
product does not contain light sources
The number and amount of mercury in light sources
must match what is declared on the registry.
Document should confirm the declared mercury content
for each light source. If lab reports are presented, they
must be dated, contain the lab method used, and show
the detection limit.
Report must confirm the declared mercury content for
each light source.
If N/A is declared, evidence must support that no light
sources are used in the product (e.g. design documents,
BOM)
Manufacturer may declare N/A to this
criterion.
Currently, LED light sources do not contain
mercury. If the product contains LED light
sources, documentation must be
presented to support that (e.g. spec sheet,
product manuals).
To date, no representative aggregated
mercury content reports have been used
to show conformance to this criterion.
1 Mercury content can be reported in actual amounts per light source or in accordance with the following ranges: 0 mg (less than lower limit of detection; >0 mg to ≤ 5 mg; > 5 mg to ≤10 mg; > 10 mg to ≤50 mg; > 50 mg to ≤100 mg; > 100 mg to ≤1 g; Greater than 1 g.
Easy to demonstrate conformance
http://www.epeat.net/documents/verification-round/2015-03/IE-2015-03-outcomes-report-final.pdfhttp://www.epeat.net/documents/verification-round/2014-02/outcomes-report-ie-2014-02-final.pdfhttp://www.epeat.net/documents/verification-round/2013-04/outcomes-report-ie-2013-04-final.pdf
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Sample Conformity Packet
1680.24.1.3.1: Required–Reporting on amount of mercury content in light sources
1680.2 4.1.3.1
The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.
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# of mercury containing light sources and amount of mercury in each
1680.2 4.1.3.1
The # of mercury containing light
sources and amount of mercury in each must match what is declared on the EPEAT registry
Light Source #Product X Model Z
Mercury Content
1 >0mg to 5mg
2 >5mg to 10mg
3 >5mg to 10mg
During desk review or verification, provide a declaration of # of
mercury containing lights and amount of mercury in each
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Evidence to Support Mercury Content in Light Sources
1680.2 4.1.3.1
This lab report supports that this light source contains 0-5mg mercury, as
reported on the EPEAT registry. Documentation like this must be provided
for each light source. Notice the report contains the detection
limit, test method, and date.
Scanner lamp homogenous materials
If the product contains light sources that are free of mercury content (e.g. LED lights), documentation must be presented to support that. This list of light sources from a product manual confirms that all light
sources are LEDs.
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Conformity Guidance 1680.2: 4.1.3.2Optional—Use of non-mercury containing light sources
1680.2 4.1.3.2
Applicable Interpretations,
Clarifications, Outcome Reports
Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember
No EPEAT Clarifications or IEEE
Interpretations Available
Outcomes Reports
IE 2014-02
IE 2013-04
List of all light sources in the product
If all light sources use only non-mercury
technology (e.g. LED), provide evidence
showing that only those light sources are
used (e.g. spec sheet, block diagram,
BOM)
List must indicate the type of light source (e.g. CCFL, LED,
OLED).
Documentation must show that all light sources use non-
mercury technology such as LED, OLED, etc.
Currently, some light sources do not contain
mercury (e.g. LED backlit, OLED backlit). If
the product contains these light sources,
supporting documentation must be
provided (e.g. tech specifications, product
manuals).
In the unlikely event that the product
contains light sources that could potentially
contain mercury (e.g. CCFLs), a CAS1 and
supporting documents for this criterion may
be required to show conformity.
1Conformance Assurance System (CAS): A process to ensure conformity to a design requirement where the key consideration is control of the supply chain of components, materials, packaging and/or services, and can also include recyclers, test laboratories and even internal designers. A CAS will include elements addressing the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
Easy to demonstrate conformance
http://www.epeat.net/documents/verification-round/2014-02/outcomes-report-ie-2014-02-final.pdfhttp://www.epeat.net/documents/verification-round/2013-04/outcomes-report-ie-2013-04-final.pdf
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Sample Conformity Packet
1680.24.1.3.2 Optional—Use of non-mercury containing light sources
1680.2 4.1.3.2
The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.
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# of Mercury Containing Light Sources and Amount of Mercury in Each
1680.2 4.1.3.2
The # of mercury containing light
sources and amount of mercury in each must match what is declared on the EPEAT registry.
This data is declared under
4.1.3.1
Light Source #Product X Model Z
Mercury Content
1 None/LED
2 None/LED
During desk review or verification, provide a declaration of # of
mercury containing lights and amount of mercury in each. Indicate
if mercury content is 0.
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Evidence Demonstrating LED Light Sources
1680.2 4.1.3.2
If the product only contains LED light sources, evidence showing those light sources must be
provided. This technical specification is an example of documentation proving the light sources are only LED.
Note: If the product contains light sources known to utilize mercury (e.g. CCFL) but mercury has been eliminated from the light source, you must also provide a CAS and supporting documents for those light sources. See Conformity Guidance 4.1.1.1 for information regarding CAS.
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Conformity Guidance 1680.2: 4.1.5.1Required: Compliance with provisions of EU Battery Directive
1680.2 4.1.5.1
Applicable Interpretations,
Clarifications, Outcome Reports
Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember
No EPEAT Clarifications or IEEE
Interpretations Available
Outcomes Reports
IE 2014-02
Description and documentation of the
Conformance Assurance System (CAS)1
that covers the material restrictions of
the EU Battery Directive2 used by the
manufacturer for all relevant
manufacturing operations and/or
suppliers
Provide list of batteries in the product
from which auditor will select one or
more (if applicable). If product does not
contain batteries, manufacturer may
declare N/A on the registry.
For batter(ies) selected by auditor (at
the time of desk review or verification),
evidence that supports active
implementation of the CAS (e.g. audit
reports, analytical or empirical data,
component supplier declarations of
conformity, corrective action reports)
The CAS should include all elements of Plan-Do-Check-
Act for the specific restricted material requirements and
should demonstrate control of the supply chain.
List should include all batteries in the product. If N/A is
declared, evidence should support that the product
does not contain batteries (e.g. BOM, specification).
Evidence/data must demonstrate that the manufacturer
checking/monitoring assures conformity to the
requirements of the criterion.
The CAS must be designed for the
restricted materials.
All elements of a CAS must be proven.
These include Plan, Do, Check, and Act.
If no non-conformances have ever been
found and therefore no corrective actions
have been taken, manufacturer must still
provide evidence of a corrective action
process.
There is no threshold for lead in the EU
Battery Directive. Consequently, test
results are not required for lead.
1Conformance Assurance System (CAS): A process to ensure conformity to a design requirement where the key consideration is control of the supply chain of components, materials, packaging and/or services, and can also include recyclers, test laboratories and even internal designers. A CAS will include elements addressing the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action). 2 European Commission Directive 2006/66/EC - Also known as the “EU Battery Directive”. Thresholds for mercury: 5 ppm (0.0005%) by weight of battery and for cadmium: 20 ppm (0.002%) by weight of battery. There is no stated lead threshold.
Somewhat difficult to
demonstrate conformance
http://www.epeat.net/documents/verification-round/2014-02/outcomes-report-ie-2014-02-final.pdfhttp://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32006L0066&from=EN
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Sample Conformity Packet
1680.24.1.5.1 Required—Compliance with provisions of EU Battery Directive
1680.2 4.1.5.1
The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.
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Elements described by Conformity Assurance System - Plan
1680.2 4.1.5.1
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
CAS Element
Description of CAS for each element
PLAN Describes and communicates requirements that the supply chain must meet.
System to specify environmental requirements to suppliers:
• Description of the requirement (e.g. specification for specific criterion)
• What suppliers must submit to show the requirement is met (e.g. declarations, test data, samples, MSDS, etc.)
• Method of communication to suppliers (e.g. on-line training, supplier summits, written specification available for web download, etc.)
• Periodic review of requirement (e.g. written policy that indicates the frequency of review and requirement to update relevant documents, annual review of the restricted materials specification, etc.)
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Elements described by Conformity Assurance System - Do
1680.2 4.1.5.1
CAS Element Description of CAS for each element
DO Collect documents from the supply chain that show conformance.
System to ensure suppliers understand and meet requirements, and to receive and manage submitted documents/data:
• Documents collected (e.g. supplier letters, declarations of conformity, analytical test data, tech sheets, certificates, purchasing records, online declarations, Joint Industry Guides, etc.)
• Process / procedure for collecting documents that indicate conformance.
• Controls to ensure all documents are collected prior to production.
• System for storing supplier data.
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
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Elements described by Conformity Assurance System - Check
1680.2 4.1.5.1
CAS Element Description of CAS for each element
CHECK Verifying that the supply chain is conformant.
System to audit, monitor and inspect suppliers against the requirements.
• Description/details of the program to validate supplier submissions:
− Actions for auditing, monitoring and/or sampling.
− Frequency of sampling and percentage of parts/materials to be sampled.
− Types of data (requesting test data from suppliers, sampling components and performing testing, etc.)
− Corrective action procedures for non-conformant findings.
• Samples of test results to support the auditing/monitoring/sampling program.
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
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Elements described by Conformity Assurance System - Act
1680.2 4.1.5.1
CAS Element Description of CAS for each element
ACT Describes how corrective actions will be taken.
System to communicate results of corrective actions.
•Identification / description of corrective action plans that will be taken in order to meet requirements if a finding of non-conformance was found.
•If applicable, evidence of actions taken in past.
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
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Evidence of Active Implementation of CAS
1680.2 4.1.5.1
Jan 20, 2013
Notice to Supplier: We, Company XYZ, hereby notify Supplier 123 that batteries supplied to us cannot exceed thresholds (by battery weight) for cadmium and mercury in the current EU Battery Directive.
Signature
Joe SmithGeneral Manager, Components Department
Once the auditor selects batter(ies), evidence of ALL elements of the CAS must be supplied to show active implementation
for them.
This supplier notification shows implementation of “Plan”.
Notice that the notification is specific to the criterion requirements and selected part(s).
From the BOM (or equivalent list), the auditor will select batter(ies) for which the manufacturer must provide evidence of active implementation of each
element of the CAS
Battery
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Evidence of Active Implementation of CAS
1680.2 4.1.5.1
Jan 20, 2016
Supplier Self Declaration of Conformity EPEAT4.1.5.1
We, Company XYZ, declare that Part XYZ supplied to Company 123 are as follows:
Do not exceed thresholds for restrictive substances in the current EU Battery Directive.
All changes to batteries are declared to manufacturer to ensure continued compliance with the EU Battery Directive.
Signature
Joe SmithGeneral Manager, Components Department
Once the auditor selects parts, evidence of ALL elements of the CAS must be supplied to show active implementation for
those parts.
This supplier declaration shows implementation of “Do” and the audit report shows implementation of “Check”
Notice that the declaration and audit report are specific to the criterion requirements and selected part(s).
Audit Report Jan 1, 2015Battery XYZ
EU Battery Directive Thresholds
Conformant Mercury (0.1 %)
Conformant Cadmium (0.01 %)
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Evidence of Active Implementation of CAS
1680.2 4.1.5.1
Date Supplier Part(s) Relevant regulatory citationDescription of Nonconformance Root Cause Analysis Action
4/12/2014 Supplier 123 Part 123 RoHS Battery Directive
Failed to provide annual declaration of "no changes" to relevant parts
Supplier was not sent an annual reminder to provide declaration.
Create automatic annual reminders for declarations; follow up with additional reminders if necessary
5/16/2015 Supplier XYZ Part XYZ RoHS Battery Directive
Supplier audit report shows battery contains mercury exceeding threshold in RoHS Battery Directive
Supplier indicates that part was manufactured with alternate material resulting in increasedmercury content.
Discontinue use of Supplier XYZ for Part XYZ until two audits are received free of nonconformances
Once the auditor selects batter(ies), ALL elements of the CAS must be supplied to show active implementation for those
parts.
This corrective action log shows implementation of “Act”. In cases where nonconformances have never been found with a part, it is acceptable to have no record of corrective actions.
However, you must still show a plan in place to conduct corrective actions.
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Evidence of Active Implementation of CAS
1680.2 4.1.6.1
Jan 20, 2013
Notice to Supplier: We, Company XYZ, hereby notify Supplier 123 that components supplied to us cannot contain more than 0.1% by weight of bromine or chlorine attributed to BFRs, CFRs, or PVC.
Signature
Joe SmithGeneral Manager, Components Department
Once the auditor selects parts, evidence of ALL elements of the CAS must be supplied to show active implementation for
those parts.
This supplier notification shows implementation of “Plan”.
Notice that the notification is specific to the criterion requirements and selected part(s).
From the Annex 1 (or equivalent list), the auditor will select part(s) for which the manufacturer must
provide evidence of active implementation of each element of the CAS
Description of Component Weight [g]paper tray, front cover 108
Paper tray (frame cassette) 270
back cover 106
Front Cover, clap (cover manual) 33
Front Cover, clap (cover front) 160
Cover Harness Front 82
cover right 215
cover left 197
cover rear 82
cover exit 30
cover top 484
Frame Exit 101
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Evidence of Active Implementation of CAS
1680.2 4.1.6.1
Jan 20, 2016
Supplier Self Declaration of Conformity EPEAT4.1.6.1
We, Company XYZ, declare that Part XYZ supplied to Company 123 are as follows:
Do not contain bromine or chlorine in excess of 0.1% by weight attributed to BFRs, CFRs or PVC.
All changes to parts are declared to manufacturer to ensure continued compliance with these thresholds.
Signature
Joe SmithGeneral Manager, Components Department
This criterion requires risk-based analytical testing –therefore some analytical testing must be provided. See Clarification 28
Black plastic casing
Evidence of ALL elements of the CAS must be supplied to show active implementation.
This supplier declaration shows implementation of “Do” and the analytical test data shows implementation of “Check”
Notice that the declaration and test results are specific to the criterion requirements.
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Evidence of Active Implementation of CAS
1680.2 4.1.6.1
Date Supplier Part(s) Relevant regulatory citationDescription of Nonconformance Root Cause Analysis Action
4/12/2014 Supplier 123 Part 123 BFRs, CFRs, and PVC
Failed to provide annual declaration of "no changes" to relevant parts
Supplier was not sent an annual reminder to provide declaration.
Create automatic annual reminders for declarations; follow up with additional reminders if necessary
5/16/2015 Supplier XYZ Part XYZ BFRs, CFRs, PVC
Supplier audit report shows part contains brominated fire retardant
Supplier indicates that part was manufactured with alternate plastic resulting in use ofdifferent fire retardant.
Discontinue use of Supplier XYZ for Part XYZ until two audits are received free of non-conformances
Once the auditor selects parts, ALL elements of the CAS must be supplied to show active implementation for those parts.
This corrective action log shows implementation of “Act”. In cases where non-conformances have never been found with a part, it is acceptable to have no record of corrective actions.
However, you must still show a plan in place to conduct corrective actions.
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Conformity Guidance 1680.2: 4.1.6.3Optional: Eliminating or reducing BFR/CFR/PVC content of product
1680.2 4.1.6.3
Applicable Interpretations,Clarifications, Outcome Reports
Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember
EPEAT ClarificationsClarification 28
Outcomes ReportsNever been verified (as of May 2016)
Description and documentation of the Conformance Assurance System (CAS)1 that covers the thresholds2 for brominated flame retardants (BFRs), chlorinated flame retardants (CFRs), and polyvinyl chloride (PVC) in all plastic materials used in the product used by the manufacturer for all relevant manufacturing operations and/or suppliers
Provide list of all parts containing plastic materials in the product (e.g. Annex 1) from which auditor will select materials.
For parts selected by auditor (at the time of desk review or verification), evidence that supports active implementation of the CAS (e.g. audit reports, analytical or empirical data, component supplier declarations of conformity, corrective action reports). The CHECK element must include analytical test data.
The CAS should include all elements of Plan-Do-Check-Act for the specific restricted material requirements and should demonstrate control of the supply chain. The CHECK element must include analytical data collection.
List should include all plastic materials and should include printed circuit board laminates.
Evidence/data must demonstrate that the manufacturer checking/monitoring assures conformity to the requirements of the criterion. Analytical test data provided for the CHECK element must show that selected parts/articles do not contain >0.1% by weight of bromine or chlorine due to brominated and chlorinated flame retardants or PVC. Analytical testing means for this criterion: performing risk-based screening procedures in order to exclude the presence of the restricted materials. See Clarification 28 for more details.
The CAS must be designed for the restricted materials.
All elements of a CAS must be proven. These include Plan, Do, Check, and Act.
If no non-conformances have ever been found and therefore no corrective actions have been taken, manufacturer must still provide evidence of a corrective action process.
Minor plastic materials such as solder masks and plastic glues are included in the scope of this criterion.
1Conformance Assurance System (CAS): A process to ensure conformity to a design requirement where the key consideration is control of the supply chain of components, materials, packaging and/or services, and can also include recyclers, test laboratories and even internal designers. A CAS will include elements addressing the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action). 2 Plastic materials in the product shall not contain more than 0.1% (1000ppm) by weight of bromine or chlorine attributable to BFRs, CFRs, or PVC with exceptions. See IEEE standard for exceptions.
Very difficult to
demonstrate conformance
http://www.epeat.net/documents/Clarification28_v2_CDP_approved.pdf
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Sample Conformity Packet
1680.24.1.6.3: Optional– Eliminating or reducing BFR/CFR/PVC content of external plastic casings
1680.2 4.1.6.3
The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.
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Elements described by Conformity Assurance System - Plan
1680.2 4.1.6.3
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
CAS Element
Description of CAS for each element
PLAN Describes and communicates requirements that the supply chain must meet.
System to specify environmental requirements to suppliers:
• Description of the requirement (e.g. specification for specific criterion)
• What suppliers must submit to show the requirement is met (e.g. declarations, test data, samples, MSDS, etc.)
• Method of communication to suppliers (e.g. on-line training, supplier summits, written specification available for web download, etc.)
• Periodic review of requirement (e.g. written policy that indicates the frequency of review and requirement to update relevant documents, annual review of the restricted materials specification, etc.)
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Elements described by Conformity Assurance System - Do
1680.2 4.1.6.3
CAS Element Description of CAS for each element
DO Collect documents from the supply chain that show conformance.
System to ensure suppliers understand and meet requirements, and to receive and manage submitted documents/data:
• Documents collected (e.g. supplier letters, declarations of conformity, analytical test data, tech sheets, certificates, purchasing records, online declarations, Joint Industry Guides, etc.)
• Process / procedure for collecting documents that indicate conformance.
• Controls to ensure all documents are collected prior to production.
• System for storing supplier data.
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
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Elements described by Conformity Assurance System - Check
1680.2 4.1.6.3
CAS Element Description of CAS for each element
CHECK Verifying that the supply chain is conformant.
System to audit, monitor and inspect suppliers against the requirements.
• Description/details of the program to validate supplier submissions:
− Actions for auditing, monitoring and/or sampling.
− Frequency of sampling and percentage of parts/materials to be sampled.
− Types of data (requesting test data from suppliers, sampling components and performing testing, etc.)
− Corrective action procedures for non-conformant findings.
• Samples of test results to support the auditing/monitoring/sampling program.
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
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Elements described by Conformity Assurance System - Act
1680.2 4.1.6.3
CAS Element Description of CAS for each element
ACT Describes how corrective actions will be taken.
System to communicate results of corrective actions.
•Identification / description of corrective action plans that will be taken in order to meet requirements if a finding of non-conformance was found.
•If applicable, evidence of actions taken in past.
Documentation of the conformity assurance system (CAS) should describe the following elements: Plan (i.e. a description of the requirement to the supplier), Do (i.e. the collection of documents that show conformity), Check (i.e. demonstration of how conformance is assured), and Act (i.e. corrective action).
The CAS must be tailored to the specific criterion.
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Evidence of Active Implementation of CAS
1680.2 4.1.6.3
Jan 20, 2013
Notice to Supplier: We, Company XYZ, hereby notify Supplier 123 that components supplied to us cannot contain more than 0.1% by weight of bromine or chlorine attributed to BFRs, CFRs, or PVC.
Signature
Joe SmithGeneral Manager, Components Department
Once the auditor selects parts, evidence of ALL elements of the CAS must be supplied to show active implementation for
those parts.
This supplier notification shows implementation of “Plan”.
Notice that the notification is specific to the criterion requirements and selected part(s).
From the Annex 1 (or equivalent list), the auditor will select plastic part(s) for which the manufacturer
must provide evidence of active implementation of each element of the CAS
Description of Component Weight [g]paper tray, front cover 108
Paper tray (frame cassette) 270
back cover 106
Front Cover, clap (cover manual) 33
Front Cover, clap (cover front) 160
Cover Harness Front 82
cover right 215
cover left 197
cover rear 82
cover exit 30
cover top 484
Frame Exit 101
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Evidence of Active Implementation of CAS
1680.2 4.1.6.3
Jan 20, 2016
Supplier Self Declaration of Conformity EPEAT4.1.6.3
We, Company XYZ, declare that Part XYZ supplied to Company 123 are as follows:
Do not contain bromine or chlorine in excess of 0.1% by weight attributed to BFRs, CFRs or PVC.
All changes to parts are declared to manufacturer to ensure continued compliance with these thresholds.
Signature
Joe SmithGeneral Manager, Components Department
Once the auditor selects parts, evidence of ALL elements of the CAS must be supplied to show active implementation for
those parts.
This supplier declaration shows implementation of “Do” and the analytical test results shows implementation of “Check”
Notice that the declaration and test results are specific to the criterion requirements and selected part(s).
This criterion requires risk-based analytical testing –therefore some analytical testing must be provided. See Clarification 28
ABS plastic, grey
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Evidence of Active Implementation of CAS
1680.2 4.1.6.3
Date Supplier Part(s) Relevant regulatory citationDescription of Nonconformance Root Cause Analysis Action
4/12/2014 Supplier 123 Part 123 BFRs, CFRs, and PVC
Failed to provide annual declaration of "no changes" to relevant parts
Supplier was not sent an annual reminder to provide declaration.
Create automatic annual reminders for declarations; follow up with additional reminders if necessary
5/16/2015 Supplier XYZ Part XYZ BFRs, CFRs, PVC
Supplier audit report shows part contains brominated fire retardant
Supplier indicates that part was manufactured with alternate plastic resulting in use ofdifferent fire retardant.
Discontinue use of Supplier XYZ for Part XYZ until two audits are received free of nonconformances
Once the auditor selects parts, ALL elements of the CAS must be supplied to show active implementation for those parts.
This corrective action log shows implementation of “Act”. In cases where nonconformances have never been found with a part, it is acceptable to have no record of corrective actions.
However, you must still show a plan in place to conduct corrective actions.
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Conformity Guidance 1680.2: 4.1.7.1Optional: Reduce fluorinated gas emissions resulting from flat panel display manufacturing
1680.2 4.1.7.1
Applicable Interpretations,
Clarifications, Outcome Reports
Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember
No EPEAT Clarifications
Available
Outcomes Reports
IE 2014-02
IE 2013-04
List of suppliers for all flat panel displays in
the product
Letter from each supplier regarding current
compliance to F-GHG1 emission control as
specified in the criterion
List must include all suppliers for all flat panel displays in
the product. If the product does not have flat panel
displays manufactured with F-GHGs, the manufacturer
shall declare N/A on registry.
Letter from each supplier must include baseline and
conformity assurance information, including:
1. Declaration that control technologies designed specifically
for F-GHG emission control cover at least 90% of the
equipment used in each and every type of operation that uses
F-GHGs in the production of flat panel displays
2. Declaration that the control technologies are designed
specifically to recover or destroy FGHGs, and are installed,
operated, and maintained in accordance with the control
technology supplier’s specifications
3. Declaration that the control technology supplier and the flat
panel display supplier have created a maintenance plan that
ensures that the specifications are being met
Suppliers may determine success in
recovery, destruction, or removal of 90%
of the F-GHGs by using the U.S. EPA
Protocol for Measuring Destruction or
Removal Efficiency (DRE) of Fluorinated
Greenhouse Gas Abatement Equipment
in Electronics Manufacturing [B23] or
another nationally acceptable method
that has been demonstrated to produce
results equivalent to or exceeding the
accuracy and precision of EPA’s DRE
Protocol, where the relative error of true
fraction emitted does not exceed 5%.
1 F-GHG’s include: CF4, C2F6, C3F8, C-C4F8, C4F8O, CHF3, NF3, and SF6
Easy to demonstrate conformance
http://www.epeat.net/documents/verification-round/2014-02/outcomes-report-ie-2014-02-final.pdfhttp://www.epeat.net/documents/verification-round/2013-04/outcomes-report-ie-2013-04-final.pdf
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Sample Conformity Packet
1680.24.1.7.1: Optional– Reduce fluorinated gas emissions resulting from flat panel display manufacturing
1680.2 4.1.7.1
The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.
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List of flat panel display suppliers using F-GHGs
1680.2 4.1.7.1
List should include all suppliers of all flat panel
displays used in the product. If none of the suppliers use F-GHG’s in the manufacturer of flat
panel displays, then manufacturer must declare N/A on the
registry.
Part (Flat Panel Display) Supplier Uses F-GHG’s?
LCD Module (1) Company XYZ Yes
LCD Module (2) Company ABC None
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Supplier Letter Details
1680.2 4.1.7.1
This supplier letter has an option to declare whether F-GHGs are used in the manufacture of the product. In this case, the supplier does
use F-GHGs and thus more information is needed. If the supplier does not use F-GHGs
in the manufacturing, then no further information is needed to prove conformance.
Column(A) Column (B) Column (C) Column (D)Type of operation using certain Fluorinated greenhouse gases (F-GHGs)
Number of production equipments using F-GHGs
Number of production equipments for which control technology (control equipment) is installed/equipped, out of the number of Column(B)
Percentage of the equipments using F-GHGs covered by the control technology/equipments (C/B x 100)
Dry etching X Yes□No 20 19 95 %
Cleaning of chamber X Yes□No 10 9 90%
Others (Please describe):N/A %
Others (Please describe):%
Supplier letters must assure that the supplier has installed control technologies designed
specifically for F-GHG emission control cover at least 90% of the equipment used in each
and every type of operation that uses F-GHGs in the production of flat panel displays. This table represents the data to help assure this.
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Supplier Letter Details Continued
1680.2 4.1.7.1
This supplier letter (continued from previous page) addresses all aspects of
conformance as stipulated by the criterion.
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Conformity Packet 1680.2 4.1Conformity Guidance 1680 2 4 1 1 1Conformity Guidance 1680 2 4 1 2 1Sample Conformity Packet 1680 2 4 1 3 1 FinalSample Conformity Packet 1680 2 4 1 3 2 FinalConformity Guidance 1680.2: 4.1.4.1�Optional: Reduction of substances on the EU REACH Candidate List of SVHCsSample Conformity Packet���1680.2�4.1.4.1: Optional– Reduction of substances on the EU REACH Candidate List of SVHCsElements described by �Conformity Assurance System - PlanElements described by �Conformity Assurance System - DoElements described by �Conformity Assurance System - CheckElements described by �Conformity Assurance System - ActEvidence of Active Implementation of CASEvidence of Active Implementation of CASEvidence of Active Implementation of CASSample Conformity Packet 1680 2 4 1 5 1 FinalConformity Guidance 1680.2 4.1.6.1Conformity Guidance 1680.2: 4.1.6.2�Optional: Eliminating or reducing BFR/CFR content of printed circuit board laminatesSample Conformity Packet���1680.2 �4.1.6.2: Optional – Eliminating or reducing BFR/CFR content of printed circuit board laminatesElements described by �Conformity Assurance System - PlanElements described by �Conformity Assurance System - DoElements described by �Conformity Assurance System - CheckElements described by �Conformity Assurance System - ActEvidence of Active Implementation of CASEvidence of Active Implementation of CASEvidence of Active Implementation of CASConformity Guidance 1680.2 4.1.6.3Conformity Guidance 1680.2 4.1.7.1Conformity Guidance 1680.2 4.1.8.1Conformity Guidance 1680.2: 4.1.8.1�Optional: Inventory of intentionally added chemicals residing in the productSample Conformity Packet���1680.2�4.1.8.1 Optional—Inventory of intentionally added chemicals residing in the productElements described by �Conformity Assurance System - PlanElements described by �Conformity Assurance System - DoElements described by �Conformity Assurance System - CheckElements described by �Conformity Assurance System - ActEvidence of Active Implementation of CASEvidence of Active Implementation of CASEvidence of Active Implementation of CAS
Sample Conformity Packet 1680 2 4 1 4 1 FINAL V3.pdfConformity Guidance Imaging Equipment: 4.1.4.1�Optional: Reduction of substances on the EU REACH Candidate List of SVHCsSample Conformity Packet���Imaging Equipment�4.1.4.1: Optional– Reduction of substances on the EU REACH Candidate List of SVHCsElements described by �Conformity Assurance System - PlanElements described by �Conformity Assurance System - DoElements described by �Conformity Assurance System - CheckElements described by �Conformity Assurance System - ActEvidence of Active Implementation of CASEvidence of Active Implementation of CASEvidence of Active Implementation of CAS