Wishing you the very best in 2010. A cautionary note from 2009 and some points for the New Year you will want to follow.
Know your product
Most small businesses have not addressed the basic information requirements for conformance with generally accepted product stewardship and sustainability standards. While these businesses have avoided the effort and potential expense of gathering and managing these requirements, they need to understand the business implications of restricted markets or the inability to address their customer’s requirements in a timely manner.
Plan for the following in 2010
- 15 new substances of very high concern will be added next week to the REACH SVHC list (Annex XIV). Your obligation to provide Downstream User information begins the day of official listing. This will bring the current list to 30 substances.
- HCFC refrigerants ban in new products - specific Class 2 Montreal Protocol Ozone Depleting Substances are now coming up for restriction by EPA.
- While the UN Conference on Climate Change in Copenhagen was marginally successful, the issue of carbon impact has not gone away. Smart money is preparing as appropriate for their business. This may be as simple as improved energy efficiency, better design and review of specifications and purchasing contracts. Gathering or providing the right information will be the key to success. Considering the cost of energy, understanding the carbon impacts will be a financial benefit even if carbon labeling is not required for your products or services.
- Understand the implications of the Energy Independence and Security Act of 2007 for your business. In 2010 lamp labeling will be required and by 2012, incandescent bulbs will be banned in stages. Some European countries are ahead of the US on the incandescent lamp ban. With the shift to new light technology, it is important to fully understand the impact of the changes for your business.
If the European market is important to your business, have you factored in new eco design criteria in your CE Marking requirements. At present this applies to external power supplies and some energy using products.
EPA is concurring with the voluntary production ban of Deca brominated fire retardant.
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