Green Product Management

Restricted Chemical Substances Management

In reaction to progressively stricter international environmental protection restrictions on the use of chemical products and in an attempt to enhance controls in the use of various chemicals in the manufacturing of products, especially those deemed as hazardous, Acer is offering systematic management controls to ensure each supplier is able to meet requirements. Acer is strongly committed to the protection of human health and the conservation of the environment. Hence, Acer upholds a cautious attitude regarding the use of chemical substances in its products, As to uphold the spirit of the precautionary principle, we abide by all regulatory standards concerning particular chemical substances and demand our suppliers to follow the “Guidance of Restricted Substances in Products” established by Acer on application on the limited or gradually banned hazardous chemical substances.
 
Acer defines a "hazardous chemical substance" as one that is persistent, bio-accumulative, toxic, carcinogenic, or mutagenic, reproduces toxicity or causes environmental hormone disruption.

Precautionary Principle
We adopt the principle of early prevention, assessing all potential hazards and chemical substances that may impact the environment.

• Acer strictly forbids continued use of substances that have been confirmed by authorized appraisal agencies to cause irreversible damage to the ecosystem or human health.
• If current scientific technology is unable to confirm certain substances to cause irreversible effects, Acer proactively assesses whether it should continue using such substances.
• If there is a suitable and safe substitute substance available, Acer will opt to use the substitute. Before such a suitable and safe material is available, Acer will actively strive to research and develop suitable and safe substitutes.
• In the case of a dispute, Acer takes responsibility by proactively gathering and providing related proof

Response to the European Union RoHS Directive
Since the European Union’s (EU) promulgation of the RoHS Directive, Acer has established a Global Environmental Safety Team to focus on related concerns in 2005. The primary tasks of this organization are to stay abreast of related regulations and information in each EU nation, and to establish an Environmental Safety Team at Acer’s Taiwan headquarters. This team is responsible for providing guidance, inventorying raw materials used in manufacture, switching to alternative materials, and verifying their effectiveness for each product line and each supplier of principal components. From 1 July 2006 all of Acer’s products have been RoHS compliant.

For the currently on-going RoHS amendment, Acer supports the organo-Cl/Br-free RoHS version. Acer will keep watching the development of RoHS amendment to have early involvement of new materials and work on relevant strategies in time.

Our Response to REACH

REACH (which stands for Registration, Evaluation, Authorisation, and Restriction of Chemicals) is the name for the European Union’s recent chemicals policy, contained in Regulation (EC) 1907/2006 which entered into force on June 1, 2007 (REACH Regulation). REACH places greater responsibility on industry to manage the risks that chemicals may pose to human health and the environment. Under the regulation, certain chemical substances, either by themselves, in compositions or in articles may not be manufactured or placed on the market within the European Union unless they have been registered in accordance with the relevant provisions where this is required. The REACH Regulation is based on the principle that it is for manufacturers, importers and downstream users to ensure that they manufacture, place on the market or, respectively, use such substances that do not adversely affect human health or the environment. Its provisions are underpinned by the precautionary principle which is consistent with Acer’s concept for chemical substances management.

• Registration

Per paragraph 1 of article 7 of the regulation, any producer or importer of articles shall submit a registration to the European Chemicals Agency (“ECHA or Agency”) for any substance contained in those articles, if both the following conditions are met:

• the substance is present in those articles in quantities totaling over 1 ton per producer or importer per year;
• the substance is intended to be released under normal or reasonably foreseeable conditions of use.
  Through preliminary assessment and expert consultation it has been determined that our products do not release the substances under normal or reasonably foreseeable conditions of use. Therefore, Acer will not submit a registration to ECHA.

• Notifications

Per paragraph 2 of article 7 of the regulation, any producer or importer of articles shall notify the Agency, in accordance with paragraph 4 of this Article, if a substance meets the criteria in Article 57 and is identified in accordance with Article 59(1), if both the following conditions are met:

• the substance is present in those articles in quantities totaling over 1 ton per producer or importer per year;
  
• the substance is present in those articles above a concentration of 0,1 % weight by weight (w/w).

On October 28, 2008, ECHA listed 15 substances in the Candidate List of Substances of Very High Concern for authorization. On January 13, 2010, another 14 chemical substances were added to the list. On March 30, 2010, Acrylamide was added to the list. On June 18, 2010, another 8 chemical substances were added to the list. Current candidate list contains 38 substances in total. The list will be regularly updated, please check the ECHA website for the latest list. Substances that are included in the Candidate List have been identified as Substances of Very High Concern (SVHC). These substances may have very serious and often irreversible effects on human health and the environment. Substances on the Candidate List may subsequently become subject to authorization by decision of the European Commission.

Candidate List of Substances of Very High Concern for Authorization

ECHA recommended that seven chemical substances of very high concern should not be used without specific authorization on June 1, 2009. These listed substances may not be used after 42 to 48 months after the inclusion date. Acer will monitor further developments to provide necessary implementation measures with suppliers. Once substances are included in the “Authorization List,” Acer will view them as restricted substances from such moment on and request suppliers to analyze the availability of alternatives and consider their risks, and the technical and economic feasibility of their substitution.

The First Authorization List

Based on Acer’s proactive attitude for environmental protection, Acer manages hazardous substances beyond RoHS compliance and develops HSF management schemes following the precautionary principle. To fulfill such principle, we conducted a full inventory together with suppliers for the first list of SVHCs and found some PVC-made articles, such as power cords and external cables contained DEHP that exceeded 0.1%. Other SVHCs were not found in notebook PCs, desktop PCs, monitors, projectors, TVs,smart phones and servers. The preliminary result is summarized below:

Acer will keep working with the suppliers to seek out any SVHCs contained in our products, those containing more than 0.1% will be updated onto our website information accordingly.

• Obligations linked to the Candidate List of SVHC (for articles)

• From the date of inclusion:
  EU or EEA suppliers of articles which contain substances on the Candidate List in a concentration above 0.1% (w/w) have to provide sufficient information, available to them, to their customers or upon request, to a consumer within 45 days of the receipt of the request. This information must ensure safe use of the article and as a minimum contain the name of the substance.
• From 2011:
  EU and EEA producers or importers of articles have to notify ECHA if their article contains a substance on the Candidate List. This obligation applies if the substance is present above 0.1% (w/w) and its quantities in the produced/imported articles are above 1 ton in total per year per company.
  - For substances included in the Candidate List before December 1, 2010, the notifications have to be submitted not later than June 1, 2011.
  - For substances included in the Candidate List on or after December 1, 2010, the notifications have to be submitted no later than 6 months after the inclusion.
  
  Note: A notification is not required when
  1. the producer or importer of an article can exclude exposure of humans and the environment during the use and disposal of the article. In such cases, the producer or importer shall however supply appropriate instructions to the recipient of the article.
     
  2. The substance has already been registered for that use up the same supply chain or any other supply chain.

For more information about REACH, please visit http://echa.europa.eu/reach_en.asp

Hazardous Substance Free Plan (HSF Plan)

Acer's prevention principles behoove us to assess all potentially hazardous or chemical substance that may have a negative impact on the environment. Thus, Acer is committed to eliminating the use of hazardous chemical substances listed in OSPAR Plus. At the present stage, PVC and BFRs are priority hazardous chemical substances chosen for gradual elimination. Acer is scheduled to prohibit PVC and BFRs from use in all newly introduced personal and mobile computing products by 2011. For a detailed description of this plan, please see our HSF Plan.

In light of the precautionary principle and international trends for sustained development, Acer has officially banned the use of deca-BDE and PFOS in all its products, parts and components. In addition, Acer is planning to ban the use of all phthalates, beryllium (and its compounds) and antimony (and its compounds) for new Acer products by 2012. Please refer to Guidance Of Restricted Substances In Products for more details.

Chemical substances management

1. Banned substances: use of the listed substances is strictly prohibited, in any part of the products such as packaging.

2. Restricted substances: According to current company policy, the content of these substances shall not exceed the legal limit.

3. Restricted substances in future: The regulated substances in all future products shall confine within legal limits.

Based on Acer’s preventive principles, aside from currently banned or limited materials, there are still many chemical substances in use whose affects on the environment are still unknown. Along these lines, Acer will continue to adhere to international controls on use of hazardous chemical substances. These include agreements such as the fifteen-nation Oslo-Paris Commission (OSPAR), the Stockholm Convention on Persistent Organic Pollutants (POPs), the European Union Registration, Evaluation and Authorization of Chemicals (REACH), the United States Environmental Protection Agency’s Electronic Product Environmental Assessment Tool (EPEAT) and the Joint Industry Guide (JIG).

Moreover, Acer will continue to contact with major environmental groups that are concerned about the use of hazardous chemical substances in business. These include Greenpeace, the U.S. Silicon Valley Toxics Coalition (SVTC) as well as other such organizations and businesses that deal with the handling of discarded high-tech information products. These organizations offer the latest information on hazardous chemicals that can help Acer ascertain what substances should have restricted use in the future. The screening principles Acer will adhere to in restricting the use of chemical substances include:

• Substances shown to aversely affect the environment, user health or safety
• Substances possibly requiring hazardous waste management measures
• Substances for which the process of handling its discarded products has a severely negative affect on the environment
• Substances confirmed to have been used in an information technology product

Initial selection of substances for restricted use in the future will be based on the following evaluation points:

• Technical feasibility
• The affect the restricted use or banned substance has on product quality and safety
• Any negative affect substitute technology would have on the environment

Moreover, in coordination with suppliers, Acer will conduct tests on substitute materials and when it is determined that any substitute technology will neither affect product quality, safety, reliability nor harm user health or increase environmental burden, then a clear timetable will be established for the phasing out restricted use or banned substances. Acer is committed to working with all involved in progressively urging suppliers to implement the use of more environmentally-friendly substitute technologies in products so as to reach the objective of phasing out restricted use and banned substances.

In the present stage, Acer has already adopted a limited timetable for future limited use substances such as brominated flame retardants (BRFs), polyvinal chloride (PVC), phthalates, antimony and beryllium. In accordance with Greenpeace suggestions, we are also adopting screening principles and focal assessments in researching and testing substitute substances with suppliers. We are also setting clear timetables to phase out restricted use and banned substances. Substances currently under assessment for future restricted use include, arsenic, bismuth and selenium. As these substances adhere to the above-mentioned screening principles, we will follow up by including them on the list of items requiring further evaluation to determine the feasibility of restricting or banning their use.