Compliance with environmental laws and regulations
Quick to comply with environmental laws and regulations in various countries in full collaboration with the supply chain
In recent years, various laws and regulations have been introduced at both the national and regional levels and legal and regulatory restrictions have been rising year after year. Legislation covers such areas as reducing power consumption during product use, as well as environmental and health impacts during processing of used products. As a global company with operations in many countries and regions, the Brother Group believes that compliance with laws and regulations is the foundation of environmental risk management and product competitiveness. The Brother Group is committed to strengthening the framework to quickly respond to developments and offering eco-conscious products before new regulations come into force. In procuring parts and materials, the Brother Group conducts audits on suppliers every three years to check their management systems and operation in connection with laws and regulations. Suppliers must make improvements if necessary.
Compliance with the Law on Promoting Green Purchasing
The Japanese Law on Promoting Green Purchasing came into force in April 2001, requiring the state and other entities to purchase products that comply. Businesses and citizens are also encouraged to purchase products that comply with the law and cause less environmental impact. In FY2008 (April 1, 2008-March 31, 2009), the Brother Group set a binding goal for all products subject to the Law to meet its requirements. As a result, all products released from FY2009 (April 1, 2009-March 31, 2010) complied with the law.
Compliance with the RoHS Directive in different countries
RoHS, which is an EU directive introduced in July 2006, bans the use of hazardous substances in electrical and electronic equipment. In response to this directive, the Brother Group worked with suppliers to build Brother's unique environmental information system, which is used to investigate, avoid, and manage chemical substances contained in products. Later, the China RoHS came into force in 2007, requiring the labeling of information on the contents of hazardous substances for electronic information products sold in China. In 2008, the South Korea WEEE/RoHS came into force, requiring manufacturers to restrict the use of hazardous substances contained in electrical and electronic products, setting content standards for such substances, product recycling, and collecting packaging materials. The Brother Group promptly complied with these new laws by utilizing the environmental information system.
FY2009 saw new regulations come into force or conventional regulations tightened in different countries and regions, for example, enforcement of the Turkey RoHS, the EU directive regarding restriction of the use of PFOS (perfluorooctane sulfonates, organic fluorine compounds), as well as the addition of restricted substances under the Canadian Environmental Protection Act (CEPA), which is intended to control hazardous substances. Note that the Brother Group succeeded in promptly meeting all of these regulations. In the US, the Brother Group ensured compliance with the Toxic Substances Control Act (TSCA, which regulates commercially used chemicals) and the California Proposition 65 (a law requiring the listing and labeling of hazardous substances).
Compliance with the REACH Regulation
REACH is an EU Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It came into force in June 2007 for all chemical substances that are manufactured or imported. Phased registration deadlines are set depending on the substance and its volume band.
The Brother Group completed pre-registration of chemical substances covered by the regulation by FY2008 and improved the environmental information system to facilitate the investigation of SVHC (Substances of Very High Concern) content that had been newly required to register. In EU countries, manufacturers are required to (i) disclose information regarding SVHCs when selling products to retailers and (ii) respond to inquiries from consumers within 45 days. In FY2009, the Brother Group set up a framework for collecting data from suppliers to improve disclosure of information on SVHC content. In FY2010 (April 1, 2010-March 31, 2011), the Brother Group developed a system for calculating the total mass of SVHC content in products and reporting it to the appropriate agency as necessary.
Current SDSs (safety data sheets on chemical substances) have been translated into EU languages and released on the Website.
Compliance with the ErP Directive (former EuP Directive)
The ErP Directive (which came into effect in 2005 as the EuP Directive and was revised in 2009) was set up as a framework for the eco-conscious design of energy-related products which are sold in the EU, to help prevent global warming. The Brother Group calculates LCA results and facilitates eco-conscious design, with the data in the environmental information system, thereby ensuring quick compliance with the directive.
Relevant procedures for product environmental impact assessments were updated for "standby and off-mode losses (Lot 6)" and "charger and external power supply (Lot 7)" (current categories in which Brother products fall) and a framework was put in place whereby the CE marking (indicating compliance with the safety regulations) could be affixed.
Compliance with the WEEE Directive, etc.
The WEEE Directive requires the collection and 3Rs of used electrical and electronic equipment. Member countries, distributors, producers, and other entities are required to fulfill the requirements in the design, sorting, collection, and recycling phases. The Brother Group in Europe meets the WEEE Directive with the assistance of collection and recycling organizations operational in respective countries. In Australia and New Zealand, the Brother Group works on collection and recycling on a voluntary basis.
In FY2009, the Brother Group ensured compliance with the Enforcement Ordinance of the Act on the Promotion of Saving and Recycling of Resources in South Korea. A collection and recycling system for Brother's products is being developed in Japan in collaboration with partners, and will commence in FY2011 (April 1, 2011-March 31, 2012). In the US, a collection and recycling system is operated by contractors in accordance with state and federal laws.
Green Procurement (parts and materials)
Over the years, the Brother Group has been steadfast developing green procurement activities in compliance with laws and regulations around the world. Since 2001, the Brother Group has been implementing green procurement activities with which we prioritize parts and materials that show environmental considerations for all products that we sell. In 2003, we dedicated efforts to completely eliminating the six prohibited substances named in the EU's RoHS Directive from parts and materials. Then, in November 2006, we updated our Green Procurement Standards to manage 24 substance groups specified by the electric and electronic industries of Japan, the US and EU in JIG. From FY2008, we began testing for the substances regulated by the EU's PFOS Directive and REACH Regulation.
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