ENVIRONMENTAL PRODUCT CONTENT SPECIFICATION FOR SUPPLIERS & OUTSOURCED MANUFACTURERS

Rev 02

1  Purpose

Echodyne is committed to complying with evolving global chemical regulation that may restrict use, require labeling or communication to customers, end users or regulatory authorities.

In order to meet the environmental compliance regulations for its products, Echodyne requires that its suppliers and outsource manufacturers meet those same compliance regulations and provide the environmental compliance information to support Echodyne’s regulatory filings, statements and declarations required by customers and international environmental regulations.

This document outlines the content of documentation required from suppliers and outsourced manufacturers to enable Echodyne to meet environmental requirements.

2  Scope

This document applies to goods procured from our suppliers, used as components of products to be delivered to customers, and used for manufacturing and packaging of products.

Environmental Regulation covered by this document include but may not be limited to:

  • ROHS – Restriction of the use of certain hazardous substances in electrical and electronic equipment, 2011/65/EU + (EU) 2015/863.
  • REACH, Registration, Evaluation, Authorisation and Restriction of Chemicals - (EC) 1907/2006, (SVHC communication and Annex 17 restrictions).
  • POP – Persistent Organic Pollutants, (EU) 2019/1021.
  • California Proposition 65 – California Safe Drinking Water and Toxic Enforcement Act.
  • US TSCA PBT - Toxic Substances Control Act - Persistent, Bioaccumulative, and Toxic (PBT) Chemicals under Section 6(h).
  • PFAS - Per- and polyfluoroalkyl substances (several US and EU regulations).
  • Halogen-free products.
  • Packaging – Packaging and Waste Directive EU 94/62/EC + (EU) 2018/852.
  • Conflict Minerals (several international regulations).
  • Anti-Slavery, Human Trafficking and Forced Labor (several international regulations).

3  Component Content Restrictions and Reporting

All materials, including sub-components, solder, plating, colorants, finishes and process residues must conform to the environmental regulations contained in this document.

Echodyne is committed to complying with evolving global chemical regulations that may restrict use, require labeling, restrict import/export, limit manufacture or distribution in commerce, and limit or ban their presence in products. The primary drivers of chemical regulations include U.S. Toxic Substances Control Act (TSCA), E.U. RoHS, REACH, POP, and similar laws.

Suppliers and outsourced manufacturers are expected to monitor applicable chemical regulations and comply with all applicable restrictions and limitations and provide statements providing confirmation of compliance and necessary substance information. When regulations change, the product needs to meet the latest restrictions within a short time after the change is implemented. Guidance on information required is included below but is subject to change and clarification when necessary. Suppliers may use standard formats and tools such as IPC 1752A or IEC 62474 standards or consultant company forma such as https://getenviropass.com/product-compliance-form/.

Information may be submitted as a CoC with the shipment, or through interaction with Echodyne engineering such as the component or compliance engineers. For clarifications and issues please contact [email protected]

3.1  ROHS

 A statement verifying compliance for EU ROHS is required listing any exemptions used (exemptions must be valid for category 3: Computing & communications equipment). EU RoHS specifies maximum levels for the following 10 restricted substances.

  • Cadmium (Cd): < 100 ppm
  • Lead (Pb): < 1000 ppm
  • Mercury (Hg): < 1000 ppm
  • Hexavalent Chromium: (Cr VI) < 1000 ppm
  • Polybrominated Biphenyls (PBB): < 1000 ppm
  • Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm
  • Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
  • Benzyl butyl phthalate (BBP): < 1000 ppm
  • Dibutyl phthalate (DBP): < 1000 ppm
  • Diisobutyl phthalate (DIBP): < 1000 ppm

Note 1: In exceptional cases this requirement may not apply if the component will not be part of electronic equipment, e.g. a tripod, carrying case.

Note 2: It is expected that Medium Chain Chlorinated Paraffins (MCCPs) and Tetrabromobisphenol A (TBBP-A) will be added to EU ROHS requirements in 2024.

3.2  REACH

For all components and accessories (EEE and non-EEE) it is required to confirm compliance with the REACH regulations, showing compliance with REACH Annex XVII: restrictions on the manufacture, placing on the market and use of certain dangerous substances, mixtures and articles and meet article 33 requirements for identifying SVHC from latest ECHA list. This should include a negative declaration (no SVHC above 0,1 % by weight) or details of SVHC above the threshold for the Part Number.

The list of substances restricted under article XVII of REACH is updated periodically and the latest restriction list should be confirmed at: https://echa.europa.eu/substances-restricted-under-reach

The REACH SVHC list is updated periodically and the latest SVHC list information should be confirmed at

http://echa.europa.eu/web/guest/candidate-list-table

Note: in exceptional cases annex XVII restrictions not applicable to Echodyne use case may be specified or ignored. Similarly, restrictions applying to human contact may depend on the type of component.

3.3  EU POP

A statement verifying compliance with EU POP regulation (EU) 2019/1021 and the absence of the restricted substances is required for all components. The list of substances can be verified at: List of substances subject to POPs Regulation - ECHA (europa.eu)

3.4  Packaging

For packaging or packaging components, a statement verifying compliance with EU packaging directive 94/62/EC and the absence of heavy metals (lead, cadmium, mercury, and hexavalent chromium) at greater than 100 ppm.

3.5  PFAS

For each component a declaration or statement of the PFAS content is required. PFAS regulations on PFAS contents in components and products are being developed and currently EU and US have slightly different lists, so both need to be evaluated. For the US, the weight of each PFAS is required.

The list of substances for USA EPA reporting can be verified at: https://www.epa.gov/toxics-release-inventory-tri-program/tri-listed-chemicals

Information on EU proposal for additional PFAs restrictions: https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas

3.6  PROP 65

For California Prop 65, it is required to list any substances that could come into contact with users or other people which are on the list for cancer causing and for reproductive harm. The list is regularly updated and the latest prop65 list should be confirmed at: https://oehha.ca.gov/proposition-65/proposition-65-list

3.7  TSCA PBT (Persistent, Bioaccumulative, and Toxic)

A statement of compliance for all components showing compliance with TSCA restrictions. Currently this limits use of 5 substances of which Phenol, Isopropylated Phosphate (3:1), PIP (3:1) is the most significant.

3.8  Halogen-free products

A statement or declaration that components are halogen-free is requested but not essential.

3.9  Conflict Minerals

Echodyne supports both customer due diligence and legal requirements on reporting and traceability of conflict minerals (tin, tungsten, tantalum, and gold) and other critical materials (cobalt and mica) used in products. All suppliers using these materials are expected to engage in due diligence with their supply chains to understand and report the sourcing of all products or materials supplied.

For suppliers of components or materials likely to include Tantalum, Tin, Tungsten or Gold, a declaration on conflict mineral compliance and, where appropriate, a list of smelters preferably using the standard template available at https://www.responsiblemineralsinitiative.org/reporting-templates/cmrt/.

In addition, declarations for the Extended Mineral Reporting are desired to cover Cobalt and Mica sources and smelters, preferably using the template https://www.responsiblemineralsinitiative.org/reporting-templates/emrt/.

3.10  Anti-Slavery, Human Trafficking and Forced Labor

Echodyne supports both customer due diligence and legal requirements on reporting anti-slavery, human trafficking and forced labor in the supply chain. All suppliers are expected to engage in due diligence with their supply chains to validate and report any risk in this area. A statement or declaration of compliance is this area should be provided to Echodyne. One way to do this is with a standard template such as one provided at: https://www.socialresponsibilityalliance.org/

3.11  Sustainability

Echodyne does not have specific templates and requirements on sustainability requirements for CSRD and ESG. Information or declarations related to this should be provided, if available.

4  Abbreviations

  • COC – Certificate of Conformity
  • CSRD – Corporate Sustainability and Reporting Directive
  • ECHA – European Chemical Agency
  • EEE – Electrical and electronic equipment.
  • ESG – Environmental, Social and Governance.
  • PBT - Persistent, Bioaccumulative, and Toxic.
  • PFAS – Per- and polyfluoroalkyl substances. PFAS are molecules containing at least one fully fluorinated methyl (CF3) or methylene (CF2) group without any hydrogen or halogen atom directly bonded to it.
  • POP- Persistent organic pollutants
  • REACH – Registration, evaluation, authorization and restriction of chemicals.
  • ROHS – Restriction of hazardous substances.
  • SVHC – Substances of Very High Concern or ECHA Candidate list.
  • TSCA – US Toxic Substance and Control Act.
  • WEEE – Waste electrical and electronic equipment.
Environmental Product Content Specs

For additional information regarding Echodyne's environmental initiatives and further explanation of this specification, please contact [email protected]