After a five year respite, Greenpeace has once again assessed the consumer electronics industry for progress in focusing on three areas:

  • Energy: Reduction of greenhouse gases through efficiency and renewable energy
  • Resource Consumption: sustainable design and use of recycled materials
  • Chemicals: Elimination of hazardous chemicals from both the product itself and manufacturing

Greenpeace’s Guide to Greener Electronics 2017 was just published in October. As you may surmise, the industry continues to fare poorly in their measure. While Greenpeace’s goals are noble, I think we have some serious structural challenges to overcome in order to achieve them in a consistent and coherent manner:

  • Transparency: why an NGO – or anybody – would expect any manufacturer to be 100% transparent about their supply base boggles my mind. They don’t really care who your supply base is; they just care that your suppliers meet their requirements, which are hopefully rational and sensible, for social and environmental performance. If all that can be defined, measured and rolled up in a coherent, believable and audited manner – which I believe is certainly possible – then that would probably meet their goals. The Electronic Industry Citizenship Coalition (EICC), recently rebranded as the Responsible Business Alliance (RBA), addresses some of these aspects of the supply chain, but not all. Obtaining data about energy use and sources, chemical use in products (let alone the manufacturing process), and driving incorporation of recycled (primarily non-metal) materials continues to be challenging. Industry must invest in developing more and better standards, control structures and automation in many areas throughout the supply chain to drive this vision of what a high social- and environmental-performance manufacturing system should look like.
  • E-waste: Living in San Francisco (once described, reasonably accurately, by Paul Kantner of Jefferson Airplane as 49 square miles surrounded by reality; it’s actually just under 47 square miles), I sort of hate to see graphics like this:

While I don’t believe that the vast majority of electronic products, even consumer electronics, are explicitly “designed for obsolescence” as a product goal, designing for even rudimentary upgradeability has certainly come under fire in laptops, tablets and smartphones in order to shrink size and improve portability (though recent smartphones no longer fit in pants pockets!). It’s all about trade-offs. Consumers complain about non-removable batteries in their smartphones. We complain about 2GB of DRAM not being enough after a couple years because the Operating System and apps continue to bloat in size. We complain about 16GB of flash memory being inadequate as we try to store photos and 4K videos taken with said phones on the device itself. And so on. Fairphone – a tiny European manufacturer -- claims to have an upgradeable camera module, and that’s a start. But much more can be made modular, perhaps at the cost of size, performance, functionality, or battery capacity. What do consumers want and value more? Apparently it’s not modularity. Greenpeace needs to convince consumers that they want longer product life and upgradeability before manufacturers will listen.

Ultimately, however, the e-waste problem continues only slightly abated. The electronics industry puts an enormous quantity of highly refined substances and materials into the world and fails to systematically reuse much of it. The infrastructure for metal recycling is good (how Greenpeace can give anyone kudos for use of recycled copper or aluminum is curious). But the big picture requires rethinking the very use of plastics (at the very least): the use of a flammable material that requires all sorts of additives to achieve the functionality and performance necessary in a high energy density environment that cannot be readily recycled is problematic. I rank it as one of the electronics industry’s “Grand Challenges” and I will be addressing it at this year’s Green Chemistry & Engineering Conference, taking place in Portland, OR in June.

Many more issues are covered in the report. Check it out and let me know what you think!

Regulation of Short-Chained Chlorinated Paraffins (SCCPs)

At the end of November both Singapore and Japan issued notifications to the World Trade Organization Technical Barriers to Trade Committee restricting SCCPs in products. These are commonly used as flame retardants in plastics (because they’re flammable and we use them where they could potentially catch fire...right?), but also have other applications.

The Stockholm Convention on Persistent Organic Pollutants (POPs) is a global treaty to protect human health and the environment from POPs. POPs are chemicals that can remain intact in the environment for long period of time, can be widely distributed geographically, accumulate in the fatty tissues of humans and wildlife, and have harmful impacts on human health or the environment. At the eighth meeting of the Conference of Parties of the Stockholm Convention (COP-8) in 2017, SCCP was listed in Annex A of the Convention. For chemicals listed in Annex A of the Convention, Parties would have to take measures to prohibit the production, import, export and use of the chemicals.

Conference of Parties of the Stockholm Convention (COP-8) in 2017, SCCP was listed in Annex A of the Convention. For chemicals listed in Annex A of the Convention, Parties would have to take measures to prohibit the production, import, export and use of the chemicals.

Singapore’s restriction comes into force in June 2018, and Japan’s by October 1, 2018. Both are open for comment through most of January. Visit NotifyUS for more information (if you’re not a member, you should join – it’s free and provides updates on a subset of upcoming regulatory requirements around the world).

Unnecessary Testing

EN50581:2012 is the harmonized standard to use for EU RoHS due diligence (IEC 63000-2016 is the international implementation). Manufacturers who follow this standard do not have to test parts and materials used in their products to confirm compliance with RoHS restrictions if the level of risk that the parts could contain a restricted substance and the supplier has its design and supply chain under control is low enough. Test is a poor substitute to process control anyway; it only assesses compliance of the parts and the manufacturing lot being tested. It gives no insight into ongoing control.

So if you test, you should – in theory – test every lot. That’s crazy. You should get better suppliers or work with your existing suppliers to verify that they understand RoHS requirements (as well as all your other requirements) and have their business, manufacturing, procurement and supply chain processes under control.

Despite this, I still see primarily Asian manufacturers testing everything. Very often they are telling SGS, Intertek and the other test houses to test for flame retardants or VOCs (volatile organic compounds, many are on the REACH SVHC list) in metals. Metals will not contain flame retardants or VOCs for two reasons:

  1. They are unnecessary
  2. Temperatures metals are processed at will burn up these molecules if they are in there to begin with

Bottom line: understand what you are asking for and why. And save yourself some money.

The Results of Poor Control: Selling Illegal Products in the USA

Somehow Samsung (and the much smaller manufacturer Element Electronics) is selling televisions in the USA containing the restricted flame retardant decabromodiphenyl ether (DecaBDE). And they got caught, by an environmental NGO testing television enclosures to see what flame retardants are in use for that application. I’m shocked, shocked to find a major manufacturer using illegal substances in their products. What happened? How little diligence are these companies putting into their product lifecycle management? How can this sort of embarrassment be avoided? Read my article on LinkedIn and let me know what you think.


Visit DCA at or email me with any questions or comments on this post.

Mike Kirschner

Mike Kirschner

Mike Kirschner is a product environmental compliance and performance expert who provides advice and expertise to manufacturers in a variety of industries. His primary areas of focus include EU RoHS, the impact of EU's REACH regulation on article manufacturers, California’s Safer Consumer Products regulation, and performance standards like IEEE-1680.x for electronics. Mike helps manufacturers define, implement and troubleshoot internal management systems that result in compliant products, and assesses and monitors environmental regulations around the world on their behalf.

He contributed two chapters to the Governance, Risk, and Compliance Handbook, published by Wiley in 2008, and is featured in the critically acclaimed book, Exposed: The Toxic Chemistry of Everyday Products and What's at Stake for American Power. In 2009 he was appointed to the California EPA Department of Toxic Substance Control's Green Ribbon Science Panel. Prior to joining ENVIRON, Mike founded product lifecycle and environmental consultancy Design Chain Associates, LLC (DCA), where he serves as president. Before founding DCA in 2001, Mike spent 20 years in engineering and engineering management roles within the electronics industry with manufacturers including Intel and Compaq. He holds a BS in electrical engineering from Worcester Polytechnic Institute.

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