Quiet before the storm of environmental compliance By Harvey Stone Managing Director, Goodbye Chain Group    Compared to recent years, 2007 was quiet in regard to product environmental regulations. Aside from China's Restrictions on Hazardous Substances taking effect, there were few new governmental requirements or actions. There were no major RoHS or WEEE enforcements, and a bill to expand California's RoHS legislation was vetoed. Unfortunately, 2007 was also the "quiet before the storm."  As we enter 2008, it would be prudent to expect a tumultuous year - and a tumultuous next 10 years - for many reasons. First, we have crossed the "greening of industry" tipping point. One example: Several thousand scientists participated in a Nobel Prize-winning scientific consensus when they produced material for the Inter-Governmental Panel on Climate Change's Fourth Report. Hundreds of corporate executives are calling for mandatory caps on greenhouse gas emissions. Virtually every leading company is launching energy-related initiatives in regard to products, facilities and logistics. Second, it appears that we will finally see China RoHS's Phase 2 Catalogue. An initial public meeting to discuss it was set for this week. Products in the catalogue will be required to undergo pre-market testing. Third, we will see the first wave of implementing legislation from the European Union's Energy-Using Products Directive. For covered products, there will likely be requirements for energy reductions and for life-cycle analysis. Fourth, results of the E.U.'s review of the RoHS regulation will be published. It is likely that at least some medical devices and control and monitoring instruments will be included in the directive's scope. Certain exemptions may be removed, and additional substances may be added. Finally, the E.U.'s Registration, Evaluation and Authorization of Chemicals (REACH) will kick into high gear with a 2008 pre-registration period and subsequent registration deadlines over the next 10 years. In my estimation, REACH will be to "toxicity in products" what climate change is to "energy use in products." Why? Because REACH addresses tens of thousands of substances for which health and environmental testing is scarce; because it will require companies to obtain authorization to use the most detrimental 1,500 of those substances; and, most importantly, because it is an unequivocal statement: "No data. No market. No E.U. sales revenue." For companies that see the green handwriting on the wall, design innovation is the key. Gathering full-disclosure substance data is a must. Capturing new business from slower movers is the reward. Happy New Year to all and rest up for the wild ride ahead.   Post a comment on the TFI Weblog>>>