Guidelines On Environmental Labeling Requirements
Contents
1. Pitney Bowes tate G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 20 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied The labels must cover at least 5 of the battery or packaging surface The minimum dimensions of the label should be 0 5 cm X 0 5 cm Where the size of the battery or accumulator is such that the symbol would be smaller than 0 5 x 0 5 cm the battery or accumulator need not be marked but a symbol measuring 1 x 1 cm shall be printed on the packaging Japan Japan s rechargeable battery law requires that nickel cadmium rechargeable cells nickel metal hydride rechargeable cells small sealed lead acid cells and secondary lithium ion batteries be labeled with a three chasing arrow symbol and the appropriate chemical symbol be labeled with the chemical symbol Recycling Disposal Information In the US each battery containing lead or cadmium must be labeled with the three chasing arrows symbol Ni Cd batteries must be labeled with the phrase BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY Lead acid batteries must be labeled RETURN or RECYCLE Sealed lead acid batteries must be labeled with the phrase BATTERY MUST BE RECYCLED Crossed out Wheelie Bin The European Union requires that batteries containing heavy metals be labeled as follows 1 The c2. 32 bas gee n esign Guideline Pitney Bowes Tra G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 33 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied e G3725 Packaging Engineering Guidelines e G3720 Packaging Design and Compliance Guide e G3805 Pitney Bowes Design for Environment DfE Guideline E Allowed black ink for packaging label Added quick November 22 2005 reference table for ROHS labeling Re wrote WEEE section Corrected Quick Reference Table for Labeling of January 6 2006 Packaging and Product section VB 1 to say Label required on box only 33
3. Use of the SPI code according to standard Japanese Material Coding System use guidelines is permitted but not required PET Bottle Stee Can Aluminum Can The guidelines for complying with the Japanese material labeling requirements indicate the following major points 1 The obligation to place the material identification marks on paper and plastic began on April 1 2001 Penalties will not be applied before March 31 2003 but businesses are expected to comply soon in order to promote the selective collection of packaging waste 2 The vertical size of the marks shall be 6mm or more for printing and 8mm or more for embossing 3 Ifthe labeling would require printing on a package that would not otherwise undergo a printing process the package is exempt from the requirements Packages that are too small less than 50 square cm or whose shape would make affixing the label impossible are also exempt However if any of these packaging components are part of a packaging system e g outer film with no labeling around other printed components small cap on bottle with labels the exemptions do not apply Either each component must be labeled or Outer film e For packaging that is either too small or of an odd shape as mentioned above the Lid identification mark shall be placed on i Cup Soup bag Japanese Material Coding of multiple comnonents on same label bas gee n esign Guideline Pitney Bowes ela G3
4. are the most comprehensive and are comparable to those of other countries There are also guidelines for the use of Environmental Labeling in the UK and Canada Claims compliant with FTC guidelines will generally satisfy other guidelines Environmental labeling that fails to meet these guidelines is considered deceptive For the full text of other guidelines refer to Principles amp Guidelines for Environmental Labeling and Marketing by Consumer amp Corporate Affairs Canada 1993 and the UK Department of Environment s Green Claims Code of Practice revised June 2000 13 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 14 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied General Environmental Claims With regard to brand names product claims logos and advertisement the Federal Trade Commission FTC states It is deceptive to misrepresent directly or by implication that a product package or service offers a general environmental benefit Unqualified general claims of environmental benefit are difficult to interpret and depending on their context may convey a wide range of meanings to consumers In many cases such claims may convey that the product package or service has specific and far reaching environmental benefits As explained in the Commission s Ad
5. Austria Czech Republic Poland Guidelines for use The 1994 Directive in describing the system to be developed states that p ackaging shall bear the appropriate marking either on the packaging itself or on the label It shall be clearly visible and easily legible The marking shall be appropriately durable and lasting including when the packaging is opened The Directive also states that mJaterials may be identified by a numbering system and or abbreviation The identification marks shall appear in the centre of or below the graphical marking indicating the reusable or recoverable nature of the packaging These details regarding the application of the system are not included in the Decision establishing the system itself which contains only the numbers and abbreviations but not logos The abbreviations must appear in all capital letters except for the abbreviations for steel and aluminum EPI recommendations e Use EU material coding where possible 11 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 12 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied e Use the codes without the round Mobius loop three chasing arrows or other logo to avoid conflicts with Czech law and any appearance of an environmental claim It may be advantageous however to use th
6. a white diamond and the letters ROHS Its standard dimensions are 0 75 wide x 0 50 high It may be resized as necessary but must maintain the same proportions and must remain legible The standard colors are Pantone 354 and black When single color labeling is necessary the green may be replaced by black PB Labeling Specification AW18147 specifies the base stock is 5 mil velvet Lexan with 3M 467 adhesive 25 bes gue n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 26 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Quick Reference Table for Labeling of Packaging and Product Part or sub assembly that has Label required on box only always been compliant i e no changes were instigated for ROHS by the supplier Bought out or off the shelf standard ROHS Label required on box Lead electronic parts sub assemblies i e Free solder information on PCB to hub or modem and if the supplier JEDEC JESD97 may also be has had to make a change due to identified Bought out standard mechanical Supplier or Pitney Bowes ROHS parts i e screws which have hada Label required on box only change to make them compliant i e plating Bought out Pitney Bowes specific Supplier or Pitney Bowes ROHS mechanical parts i e formed sheet Label required
7. are subject to recycling fees SPI Resin Codes MATERIAL ABBREVIATION Polyethylene Terephthalate 1 PETE High Density Polyethylene HDPE Polyvinyl Chloride Low Density Polyethylene Polypropylene Polystyrene Other The symbol should be molded or embossed into the base of the container The recommended size is between one half inch and one inch depending on the size of the container measurements are for the symbol alone not including letters The SPI code is only a resin identification code to aid in plastics sorting It is not a recycling or environmental symbol and may not be placed prominently on the container or label The use of the SPI code is subject to FTC guidelines see Section IIIB 3 For FTC rulings on deceptive use of the SPI code refer to the FTC Guidelines Note Mexico follows a coding system very similar to the SPI coding discussed above There are significant differences however between the SPI system and the Mexican coding system These differences are as follows Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 7 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied e In Mexico there are no size exception allowances such as the small package size exemption e g under 8 oz or maximum size cutoffs e g excluding over 5 gallons e Mexico appl
8. label must be placed as close to the shipping label as possible WEEE Labeling Products that are subject to the WEEE Directive and are placed on the market after Aug 13 2005 must be labeled in accordance with CENELEC standard EN 50419 2005 If a product subject to this labeling requirement cannot be labeled due to its size or function and does not have a fixed power cord and instruction manual which can be labeled instead then the product 23 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 24 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied packaging must bear the required labeling For details of the symbol see Section VB 1 WEEE Labeling Placement of the label should be consistent with the placement of the ROHS label if applicable If the label is used on the product packaging it should be placed as close to multiple part tags as possible If no Multi Part tag is present the label must be placed as close to the shipping label as possible Mercury Containing Assemblies Mercury labeling laws for products containing mercury require the labeling of either the packaging or the owner s manual indicating that the product contains mercury and that it must be removed and properly disposed of prior to disposing of the product Mercury warnings and information labeling
9. must be clearly visible at the time of purchase If the product is packaged such that statements on the product are hidden you must place this language on the packaging For more detail see Section VB 1 lsotiazolines may apply to PB supplies Sweden requires that products containing more than 15 ppm of the mixture of two isotiazolines must be labeled as being sensitizing to the skin Isotiazolines are found in paints and glues For chemical supplies this may necessitate labeling the packaging Packaging made from Expanded Resins e g EPS corners Electronics packaging made from expanded resins is subject to materials coding requirements See Section IIIA 3 for details VA 2 Recommended Labeling TBD 24 bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 25 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied VB Product Laws Labeling on Products VB 1 Required Labeling RoHS Labeling When part designs are changed to comply with the requirements of the ROHS Directive PB requires the use of a label to distinguish new ROHS compliant versions of parts and products from their non ROHS compliant counterparts Parts and products that have not been changed should not be labeled The label should be used on Parts see below Finished products see
10. 810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 6 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied another packaging component in addition to its own mark e Marks for two or more packaging components may be placed on either component if they are to be discarded at the same time 4 Wrapping paper paper or plastic used in department stores is subject to marking requirements if the company name is printed on it A sheet 1 300 cm or less is exempted However it is preferable to add the mark even on a small piece if the cutting shape is known when the paper is ordered Turkey All packaging must be marked with the appropriate EU material code and the Mobius loop Companies who recover their own waste must label packaging with a Ministry assigned code The regulation requires that all companies who are part of a recovery system must label packaging with the relevant symbol of the organization e g Green Dot SPI Coding The use of Society of the Plastics Industry SPI codes is required in 39 states of ly the US and is used although not required in many other Latin American countries 1 on all plastic containers 8 oz and greater 200 ml in metric countries Mexico Ci encourages but does not require use of a coding system based on the SPI code PETE In Taiwan the SPI code is required on containers that
11. AN 06 Revision F Page 15 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied The Green Dot symbol is voluntary in Austria Belgium The Czech Republic Estonia Hungary lreland Latvia Luxembourg Norway Poland Slovakia Slovenia Sweden and Turkey It is permitted in other EU countries The Green Dot does not make an environmental or recycling claim it is an indication that the manufacturer has paid membership fees to a PRO EUROPE organization Use of the Green Dot trademark including voluntary use requires a valid membership agreement with a Green Dot licensing or recovery organization See detailed information on Green Dot in Section IIIA 2 Mandatory Take back Symbols The Czech Republic Packaging that does not carry any particular hazardous characteristics and is treated as standard household waste may be marked to inform the consumer on the proper method of disposal Industrial standard CSN 770053 covers this type of marking and gives specific symbols or phrases to be used on the packaging itself The Tidyman symbol right may be used This symbol has the following meaning in the Czech Republic Empty packaging should be disposed using municipal waste management programme in line with the locally applicable municipal decree Note The revised Tidyman standard CSN 77 0053 makes the use of the Tidyman symbol voluntary
12. Design Guideline Pitney Bowes Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 1 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied ty Pitney Bowes in Guideline on Environmental Labeling Requirements I INTRODUCTION Electronics products batteries and packaging are all subject to a variety of often conflicting domestic and international labeling requirements Each type of requirement may affect the labeling and artwork considerations for each of these areas For example a battery law may require battery information to appear on the battery the product the package and or the owner s manual This guide is intended to aid PB personnel its OEMs and suppliers in seeing through the maze of overlapping requirements and in selecting and using labeling in conformant with applicable laws regulations and guidelines The Overview table illustrates how each type of regulation may affect the product at different different levels e g component whole product battery package The document is cross linked to facilitate use by different PB staff OEMs and suppliers To find all of the labeling that must be included in the artwork for the packaging one may read down the column for packaging labeling On the other hand a manager overseeing membership in a collection program for batteries may wish to en
13. ROPRIETARY and CONFIDENTIAL information and is not to be copied batteries sold separately name logo This means that if a battery or a product containing a battery is sold under the Pitney Bowes brand name the battery must be marked with the Pitney Bowes name and or logo Mercury China requires all batteries to be labeled low mercury content or mercury free as appropriate The definition of low mercury content is that the mercury weight is less than 0 025 of the battery weight the definition of mercury free is that the mercury weight is less than 0 0001 of the battery weight Of course these claims must be true and verifiable batteries not conforming to one of these definitions may not legally be sold in China Four Arrow Symbol RA Taiwan requires the use of a four arrow symbol right on all batteries that are subject to recycling fees manganese zinc tubular alkaline manganese tubular one time LS lithium button lithium button alkaline manganese silver oxide mercuric oxide zinc air nickel cadmium nickel hydrogen tubular two time lithium IVB 2 Batteries that contain heavy metals The US the European Union and Japan require labeling of heavy metals containing batteries as to chemical composition and disposal requirements These labeling and information requirements vary from jurisdiction to jurisdiction Chemical Composition Labeling US Federal law requires labeling of regulated
14. batteries i e batteries containing lead or cadmium Each battery must be labeled with the battery s chemical symbol i e Ni Cd or Pb Europe For batteries containing heavy metals which are to be marketed in Europe the chemical symbol must be printed beneath the crossed out wheelie bin see Crossed out Wheelie Bin below It shall cover an area of at least one quarter the size of the crossed out wheelie bin symbol Romania Requires labeling with crossed out wheelie bin and chemical symbol as in the EU also requires the concentration of the heavy metals to be printed under the wheelie bin symbol It must cover at least one fourth of the size of the symbol provided under Annex no 3 Taiwan Taiwan requires the Chinese character symbols to appear on aluminum manganese button silver oxide mercuric oxide and nickel cadmium batteries and their packaging f these batteries are incorporated into a product label is required on PEES ZK battery packaging and electronic product or user manual Aluminum manganese button silver oxide and mercuric oxide batteries and or FR E FA their packaging must bear this Chinese character panel at right Tubular a gh o F batteries must bear the symbol on both the cell and the packaging Also nickel cadmium batteries and their packaging must be labeled with this Chinese character panel at right Sia Sh i gt E FA Fa h E Ae 19 mm bm esign Guideline
15. below Finished product packaging see Section VA 1 Packaging for mechanical and electrical parts see Section VA 1 Labeling of Parts e Custom Electrical parts must be labeled using PB label AW18147 The label should be placed near or included onto the part number label The labeling requirements may be adjusted following consultations between Pitney Bowes and its supplier s vendors to address issues such as available space etc e Custom Mechanical parts Labeling is not required Procurement will determine if any specific parts are to be labeled by vendor e Standard Electrical parts are any parts with a wire Negotiations will be conducted between the supplier and PB to mutually agree upon the size color and lettering convention If the supplier has a current alternate labeling scheme for ROHS identification Pitney Bowes will accept parts labeled according to that scheme e Standard Mechanical parts Labeling not required e Service parts for OEM equipment Labeling scheme to be determined by Commodity engineers in consultation with OEM suppliers Labeling of Finished Products Finished products must be labeled according to PB Labeling Specification AW18147 if they contain parts that have been modified to comply with the RoHS Directive Finished products may be labeled as ROHS Compliant only if all of their parts are ROHS compliant changed or unchanged Details for Use from AW18147 The label is a green rectangle containing
16. bove the symbol in fact their use is discouraged in many countries The orientation must be as in the illustration above with the darker arrow pointing upwards to the right and the lighter arrow pointing downward to the left The standard colors are Pantone 343 C dark green and Pantone 366 C light green Alternatively the logo may appear in one color on a white background or in white on a color background as long as the color corresponds to the dark green and the white bes gue n esign Guideline Pitney Bowes Tra G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 8 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied corresponds to the light green The recommended size is 10 mm but 6 mm is acceptable for extremely small packages The logo may be printed checked stamped or embossed The artwork files and a detailed set of guidelines for the implementation of the mark is included in the membership contract and license for all PRO EUROPE organizations or at hitp www green dot org uk select gt Joining gt Standards of Use IIIA 3 Recycling Disposal Information Estonia PVC containers must be marked with No incineration South Korea South Korea passed a new material coding requirement in December 2002 Ministry of Environment Notification No 2002 195 Although this labeling requirement i
17. copied Romania Manufacturers and Importers must inform buyers of the need to collect and recycle by labeling the case with the following texts Discarding of used rechargeable and or non rechargeable batteries is strictly forbidden Discharge of electrolyte from used rechargeable batteries is strictly forbidden Take back symbols If your batteries are part of the RBRC Rechargeable Battery Recycling Corporation system in which the fees are paid by the manufacturer place the RBRC logo right on the battery IVC Batteries Labeling on Products IVC 1 Pre Installed Batteries Taiwanese Labeling If aluminum manganese button silver oxide mercuric oxide and Ni Cd batteries are incorporated into a product the Taiwanese label is required on the electronic product see previous section IVC 2 Non removable Batteries Recycling Disposal Information If a battery containing lead or cadmium is incorporated into a product and is non removable the following language must appear on the product CONTAINS NICKEL CADMIUM BATTERY BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY or CONTAINS SEALED LEAD BATTERY BATTERY MUST BE RECYCLED IVD Batteries Other Required Labeling and Information IVD 1 Pre Installed Batteries Recycling Disposal Information If a product contains a battery the user manual must contain information on any environmentally hazardous substance contained in the battery and information on the safe
18. duct and its packaging must be labeled to indicate ROHS Compliance Parts packaging should be labeled with the RoHS green diamond label defined in PB Label Specification AW18029 Colors are Pantone 354 green and black single color labeling in black is permitted if necessary The label must be 1 5 x 2 in size The label is only for use on packaging that contains only ROHS Compliant parts As an alternative marking with a rubber stamp using black ink is permitted Placement of the label is as follows e Physical Item Individual Packaging The box and or bag that hold the individual part should be marked The label must be on the outside of the packaging container A label inside the container is unacceptable The label should be placed as close to the part number identification as possible on the outside of packaging e Master Carton If multiple items are packaged in a single box the box must be marked compliant if and only if all components are compliant The label should be placed as close to multiple part tags as possible If no Multi Part tag is present the label must be placed as close to the shipping label as possible Finished Product packaging should be labeled as follows e Physical Unit Individual Packaging The symbol should be located as close to the Multi Part serial number label as possible e Master Carton The label should be placed as close to multiple part tags as possible If no Multi Part tag is present the
19. e guidance from the Federal Trade Commission on the use of recyclable claims is based on the availability of recycling facilities for the package or product The most significant change made was that the old guidance allowed the use of the phrase Check to see if recycling facilities exist in your area as a Safe Harbor Recyclable Disclosure for packaging that is recyclable in a significant percentage but not a substantial majority of communities the so called second tier The new guide removes this Safe Harbor The Commission also concludes that the alternatives suggested by some reviewers such as recyclable where facilities exist would be inadequate to change consumer perception Example 4 of the Recyclable guide where this issue is presented has been revised to suggest the following types of disclosures Recycling programs for this bottle product or packaging may not exist in your area or This bottle product or packaging may not be recyclable in your area Because the new safe harbors are tied to the marketed product as opposed to recycling programs generally they reduce the possibility that consumers may infer that because a recycling program exists in their area that any product represented as recyclable can in fact be recycled in their local program lIIB 4 Take back Symbols Green Dot 0 14 mm bm esign Guideline Pitney Bowes tate G3810 Standards Engineering Issued NOV 02 Revised J
20. e the CONAI fees paid on the invoice when he sells the goods to a customer distributor retailer etc The information can either appear as a separate item on the invoice a separate column on the invoice or the fee can simply be included in the price of the product with a statement below the total indicating the amount of fees Note that if any repacking takes place this includes overlabeling and repalletizing you must include the corresponding fees from the invoice received from your supplier on your outgoing invoice For other members of the distribution chain format details vary complete instructions can be found in the current CONAI membership materials 16 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 17 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied IV BATTERY LABELING REQUIREMENTS IN DETAIL IVA Batteries Labeling on Packaging IVA 1 All Batteries KCA Logo All batteries or products containing batteries sold in the Netherlands must be marked with the KCA logo an image of a crossed out garbage container in a frame For batteries that do not contain heavy metals it may be printed on either the battery or the packaging For details on the label and its use see the full KCA Logo section in Section IVB 1 Crossed Out Wheelie Bin for small batteries Ge
21. e three chasing arrows symbol with plastic codes when this can be done in a manner that is consistent with SPI and FTC Guidelines enabling you to meet both requirements with one symbol e For composites not assigned a number use the appropriate abbreviation according to the predominant material and omit a numerical code e For material types not listed at all do not label unless required by a national law in that case use the applicable code from that country s system EU Material Coding System Material Abbreviation Number Polyethylene Terephthalate High Density Polyethylene Polyvinyl Chloride Low Density Polyethylene Polypropylene Polystyrene Corrugated fibreboard Non corrugated fibreboard Paper Steel Aluminum Wood Cork Cotton Jute Glass clear Glass green Glass brown Paper and cardboard miscellaneous metals Paper and cardboard plastic 12 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 13 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Paper and cardboard aluminum 82 Paper and cardboard tinplate 83 Paper cardboard plastic aluminum 84 Paper and cardboard plastic aluminum tinplate 85 Plastic aluminum 90 Plastic tinplate 91 Plastic miscellaneous metals 92 Glass plastic 95 Glass aluminum 96 Glass tinplate 97 Glass miscellaneous
22. ent hexane If marking plates or labels are used they must not show curling after the above tests 27 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 28 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Placement of Mark If possible the product itself must be marked If due to size or product function the marking cannot be applied to the product the marking shall be placed 1 ona fixed power cord as a flag label 2 inthe operating instructions 3 product packaging Crossed out Wheelie Bin Under Article 10 of the WEEE Directive producers are required to mark electronic products with the symbol shown to the right PB Labeling Specification AW17917 provides the artwork and addresses the use of this label It specifies the standard size of the label as 7 5 mm wide x 10 mm high The symbol may be scaled but proportions must be maintained For adhesive labels ial the base stock material is LAM 2mil clear Mylar with 3M 467MP adhesive or equivalent Location The location of the wheeled bin shall be in close proximity to either the serial or FCC plate If the labels are on different sides of the product place near the label furthest from the front of the machine e g back of machine instead of side Approval Pitney Bowes PD amp U will approve the location of the
23. er with the product forms a unit for sale that reaches the end consumer household hospital or point of use Sales packaging can be made up of the following packaging types Packaging in direct contact with the product e g bottles that are in direct contact with the product Outer sales unit packaging e g folding carton used to hold a bottle Cushioning inserts e g liners that protect the primary packaging Outer packaging that covers the packaging in direct contact with the product or the sales unit packaging e g plastic film that holds two bottles of shampoo together that are sold as a unit Note that for larger products sales packaging also includes packaging components typically thought of as transport packaging since these remain with the product until it reaches the end user For example printer in shipping carton machinery on pallet Unit of Sale A single product as packaged for sale WEEE EU Directive on The Directive on Waste Electrical and Electronic Equipment 2002 96 EC applies to electrical and electronic equipment which the holder discards intends to discard or is required to discard Also refers to general category of waste electrical and electronic equipment Vil Additional Resources The following documents address packaging design for environment battery requirements and related issues in more detail e G3805 Design for the Environment Guide e Battery Design and Compliance Guide
24. evision F Page 5 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Marking must be placed such that it will not be damaged or removed when the pack is opened or during use However if it is not possible to mark the pack itself for technical reasons then the marking can be placed inside the pack or if the properties of the product do not permit this on a separate leaflet handed over together with the packaged product South Korea Material coding is required South Korean system uses material specific logos with a separate disposal message see Section IIIA 3 Recycling Disposal Symbols The use of the SPI coding system is not required Japan ae npe Paper Containers Packaging Plastic Containers Packaging Material identification marks are now mandatory on paper Except Except PET Bottles for and plastic containers and packaging in addition to steel oe aoe iain sie f f Paper drink packs with Soy sauce and aluminum containers and PET bottles Note that this no aluminum coating labeling is required only on packaging of products sold to consumers households The Ministry of International Trade and Industry has issued new guidelines for the LE material marking to be placed on the packaging of SET t products sold in Japan The SPI code is allowed on PET bottles but should be conspicuous unlike under the FTC guidelines
25. formation VC 1 Required Information WEEE Labeling Products that are subject to the WEEE Directive and are placed on the market after Aug 13 2005 must be labeled in accordance with CENELEC standard EN 50419 2005 If a product subject to this labeling requirement cannot be labeled due to its size or function the fixed power cord must be labeled and the label must also be printed in the instruction manual For details of the symbol see Section VB 1 WEEE Labeling 29 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 30 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Recycling Disposal Information EU The EU WEEE Directive requires Member States to inform consumers of end of life product recovery systems available to them However upon national implementation Member States may pass this responsibility on to the product manufacturers importers PB should include in all product owner s manuals disposal collection scheme and recycling information for each market country along with contact information for up to date PB take back information Under the WEEE Directive producers must also provide information to treatment facilities to identify the different electrical and electronic equipment components and materials and the location of dangerous substances and preparations in
26. formation on the location of the component to assist in removal Mercury thermometers are subject to additional labeling requirements if a PB product incorporates a mercury thermometer refer to Electronics Regulatory Matrix lsotiazolines may apply to PB supplies Sweden requires that products containing more than 15 ppm of the mixture of two isotiazolines must be labeled as being sensitizing to the skin Ilsotiazolines are found in products such as paints and glues Coding of Major Components China s Cleaner Production Law requires producers to mark major components with standardized codes to identify the raw material composition i e ISO 11469 2000 coding Video Displays Effective January 1 2005 California requires CRTs and other video display devices with a diagonal measurement greater than 4 inches to be marked visibly with manufacturer s name or logo VB 2 Recommended Labeling Mexican SPI coding Mexican regulation NMX E 232 SCFI 1999 strongly encourages producers to label all products made of resins 1 6 with the SPI codes The symbols must be visible The recommended minimum size of symbol is of 12 7 mm Proposed Requirements The draft EUP Directive would require certain product groups to meet environmental design standards in order to use the CE mark The CE symbol which is currently used on electronic equipment in Europe is required to be no smaller than 5mm squared VC Product Labeling Laws Other Required In
27. iented strand board and wafer board Non manufactured Wood Packing NMWP Raw form of wood which is derived directly from the tree and has undergone only primary alterations i e debarking sawing shaping etc Packaging system a unique configuration of packaging components around a product For example a product in a shipping carton may be packed in groups of 24 on a pallet The packaging components inside the carton the carton itself the pallet and shrink wrap all constitute a packaging system The same product may be packed with together with other products as a set for sale in a different market This is an example of another packaging system for the same product Recyclable As applied to a product or package this term means that the entire product package excluding minor incidental components can be recycled Any non recyclable incidental components of a unit labeled recyclable must not impede or prevent recycling Note that this term when used without further qualification is often considered deceptive Recycled content The fraction of a product that is made from materials that would have otherwise entered the waste stream Claims regarding recycled content should specify the percentage of pre and post consumer content according to the following definitions Industrial Scrap Materials and by products reused in the original manufacturing process Also known as home scrap This material is generally not considered to be rec
28. ies the coding system to all products made of plastic of resin types 1 6 not just plastic containers as in the U S e Mexico allows placement of the code anywhere that is legible while the U S restricts the code to the bottom of the container e Mexico s coding system follows the 1 through 6 designations for certain resin types but does not use the designation 7 Other that the U S system allows IIIA 2 Take Back Symbols Green Dot The Green Dot is required in France Germany Portugal and Spain The Green Dot is the symbol of Packaging Recovery Organisation Europe s p r l or PRO EUROPE The Green Dot does not make an environmental or recycling claim it is 5 an indication that the manufacturer has paid membership fees to a PRO EUROPE organization Use of the Green Dot trademark in any of the countries listed in this section requires a valid membership agreement with a Green Dot licensing or recovery organization Status of Green Dot by Country Mandatory Voluntary as part of Recovery Scheme as part of Recovery Scheme Requires Licensing Only France Austria Canada Germany Belgium UK Portugal Czech Republic Spain Estonia Turkey Greece Hungary Ireland Latvia Lithuania Luxembourg Norway Poland Slovakia Slovenia Sweden The Green Dot must be easy to locate and identify and may bear no additional text graphics or similar modifications Note the words Der Gr ne Punkt are not required to appear a
29. ing ATTENTION CONTAINS NICKEL CADMIUM BATTERY MUST BE DISPOSED OF PROPERLY For products and devices that contain batteries which are not required to be removable see PB Battery Guideline the product must be labeled and the owner s manual must contain a notice informing the user of the dangerous contents of the batteries and explaining how to dispose of the battery device responsibly If removing the battery poses a safety risk to the owner the manual should instruct the owner to have the battery removed only by a professional If the product is covered by one of the battery or electronics take back systems the manual should instruct the owner to bring the entire product to a collection point at the end of its useful life and should provide the necessary contact information including a telephone number 22 mm bm esign Guideline Pitney Bowes tate G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 23 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied V PRODUCT LABELING LAWS REQUIREMENTS IN DETAIL VA Product Labeling Laws Labeling on Packaging VA 1 Required Labeling RoHS Labeling If a product may be supplied in two versions i e a version containing parts modified to be compliant with the RoHS Directive and an older version with non ROoHS compliant parts the new version of the pro
30. is requirement can be satisfied by use of the SPI code see below Exempted from this requirement are dangerous goods drugs sterile medical skin packs gift packs unprinted films bags films with area less than 0 125 m or rigid packaging with a volume lt 100ml Croatia A 1996 decree requires marking of plastic packaging and composite packaging with both a number and an abbreviation The markings specified differ from both the voluntary EU identification system and the U S SPI coding system The identifying number codes are the same as the SPI codes but the abbreviations are as follows 01 PET 02 PE HD 03 PVC 04 PE LD 05 PP 06 PS 07 0ther Czech Republic Since 1999 material marking has been required on packaging Symbology closely follows the EU material coding system Industrial standard CSN 770052 2 recommends the use of a triangle plus numeric code in it or a triangle plus an abbreviation below it or a triangle plus both numeric code and abbreviation The producer may decide to use a different form of simple easy to understand marking but is advised to follow the industrial standard to avoid any possible problems with government authorities The Trade Inspection and Environment Inspection do check marking and consumer disposal information They are entitled to impose a fine of up to CZK 500 000 in each individual case of improper material marking and up to CZK 500 000 in each case where the information on package disposal is
31. label Supplier will be responsible for assuring consistency of the location User Instructions User Instructions must also provide the user with information on the meaning of the WEEE marking and the role of the Producers and Users in the management of WEEE Mercury Containing Assemblies Note that electronic relays and other electronic devices that contain mercury are subject to labeling and take back requirements and landfill bans in Connecticut Maine Minnesota Vermont and Rhode Island Labeling must inform the purchaser that the product contains mercury and that the mercury must be removed and properly disposed of prior to disposing of the product The label must be clearly visible at the time of purchase this may require labeling the packaging The label must be located on a surface of the product that is visible during installation and removal Product labels must be durable enough to remain legible for the life of the product 28 bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 29 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied For mercury containing components contained in other products where the component could feasibly be removed from the product by the purchaser both the component and product must be labeled The label must provide in
32. ll ambiente dopo l uso Do not litter or the Tidyman symbol on all containers for liquid products In order to harmonize labeling requirements with those of the EU the Italian government has repealed the requirement to label containers that contain liquid with the Tidyman symbol or the statement Non disperdere nell ambiente dopo l uso This labeling requirement was officially repealed as of February 22 2003 Taiwan Taiwan requires the use of a four arrow symbol right on all containers either on the a container itself the inner or outer wrapping or on the packaging label that are subject to recycling under the Waste Act At present this requirement does not re apply to PB products In addition to the four arrow symbol plastic containers should also have a material symbol SPI codes are suitable IIIA 4 Marking of Wooden Packaging Restrictions exist on wood packaging material including coniferous and non coniferous wood in manufactured and non manufactured form transported internationally in several countries e g US EU and Member States Australia China Brazil Argentina In general these restrictions apply to wood packing in the form of packing cases crates drums pallets box pallets or other load boards dunnage spacers and bearers including those which have not kept their natural round surface These restrictions do not cover wood shavings and sawdust The internationally agreed wood treatment ma
33. ment to mark accessories however in circumstances where accessories can be purchased or supplied separately from the product they could be deemed as products in their own right Therefore stand alone accessories that operate external to the products being marked should also be marked e g external power supplies external modems scanners CRT s scales keyboards Individual items meeting the following criteria will likely require individual WEEE marking e tis separately packaged this package will frequently be supplied together with other packages e t carries Pitney Bowes or alternate manufacturer name logo PCN code and or serial number e It requires a CE or UL mark Marking The CENELEC standard EN 50419 2005 requires the manufacture mark product visibly legibly and indelibly with e Identification of the producer such as name logo registration e Crossed out wheeled bin details below e The date of manufacture put on the market or a bar under the wheeled bin symbol the bar to be used in conjunction with the wheeled bin is the symbol established by EN 50419 2005 to indicate that the product was placed on the market after Aug 13 2005 EN 50419 2005 specifies that minimum marking durability requirements must be met The mark must remain legible after 1 rubbing by hand for 15 seconds with a piece of cloth soaked with water and 2 for 15 seconds with a piece of cloth soaked with aliphatic solv
34. metals 98 for composites the material abbreviation is C plus the abbreviation for the predominant material e g C PAP for composite that is predominantly paper Specifications The directive states merely p Jackaging shall bear the appropriate marking either on the packaging itself or on the label It shall be clearly visible and easily legible The marking shall be appropriately durable and lasting including when the packaging is opened The abbreviations must appear in capital letters lIIB 2 Recycled Content Claims regarding the use of recycled content should be made with caution General and unqualified claims such as made from recycled materials or made using recycled materials should be avoided because 1 they do not indicate whether the product or the package has been made using recycled materials 2 they do not give the percentage of recycled materials used and 3 they do not specify whether pre or post consumer materials have been used Such claims are considered to be deceptive Please refer to Section V Glossary for definitions of pre and post consumer recycled content Claims regarding recycled content should differentiate between product and packaging and must specify percentages of post consumer and pre consumer content IIIB 3 Federal Trade Commission Guidelines for Environmental Claims The US Federal Trade Commission guidelines available at http www ftc gov bcp grnrule quides980427 htm
35. nd contains PROPRIETARY and CONFIDENTIAL information and is not to be copied The mark should at minimum include the e symbol e ISO two letter country code followed by a unique number assigned by the NPPO to the producer of the wood packaging material who is responsible for ensuring appropriate wood is used and properly marked e IPPC abbreviation according to Annex for the approved measure used e g HT MB IIB Voluntary Labeling and Environmental Claims lIIB 1 Material Coding EU Material Coding Background and application The Packaging Directive called for the development of an EU material coding system Although the 1994 Directive foresees a mandatory marking system the system created is explicitly voluntary However it provides for the possibility that material coding could be made mandatory by a future decision Although material coding in Europe is voluntary at the EU level several of the new member states have laws requiring material coding of packaging using the EU coding system see Section IIIA 1 on Mandatory material coding t should be noted that they may be required to adapt their laws to make the material coding voluntary but in the meantime the marking requirements are in effect In Estonia and Germany material coding is voluntary but if applied it must be consistent with the EU coding system It may also be used to satisfy material identification requirements that do not specify a particular system e g
36. nent that consisting of multiple material constituents e g paperboard plastic aluminum which have been laminated bonded or otherwise joined EuP Proposed EU Directive on The draft EU Directive on Energy Using Equipment would apply to equipment which is dependent on electric currents or electromagnetic fields in order to work properly refer to EU draft legislation for complete definition EU European Union An economic and political entity whose member states are Austria Belgium Cyprus the Czech Republic Denmark Estonia Finland France Germany Greece Hungary Ireland Italy Latvia Lithuania Luxembourg Malta the Netherlands Poland Portugal the Slovak Republic Slovenia Spain Sweden and the UK Note that EU Directives are also applied to varying degrees in Iceland Liechtenstein and Norway who are members of the European Economic Area IPP Integrated Product Policy A method of product design that assesses product and package together as a whole to determine the most effective efficient and environmentally responsible product and package system Isotiazolines a type of chemical compound often used in preservatives paints glues cosmetics shampoo cutting fluids putties and jointing material which is sensitizing to the skin Manufactured Wood Wood based products which have been processed using wood glue heat and compression including but not limited to plywood veneer fiber board particle board or
37. nerally this labeling is required on the battery itself and should cover 3 of the area of the largest side of the battery or accumulator for cylindrical shaped batteries 3 of half the surface area of the battery However for small batteries this formula would result in an illegible symbol In such cases the symbol measuring 1 x 1 cm must appear on the sales packaging Be sure to indicate clearly that the symbol refers to the battery not the packaging or the product Take back symbols T e CORT i O If PB products include batteries that are recovered in Belgium by the Bebat system the transport packaging must bear the Bebat label For batteries sold separately the label must appear on the consumer packaging IVA 2 Batteries that Contain Heavy Metals Crossed out Wheelie Bin for small batteries Generally this labeling is required on the battery itself and should cover 3 of the area of the largest side of the battery or accumulator for cylindrical shaped batteries 3 of half the surface area of the battery Where the size of the battery or accumulator is such that the symbol would be smaller than 0 5 x 0 5 cm the crossed out wheelie bin symbol measuring 1 x 1 cm shall be printed on the packaging The chemical symbol must be printed beneath the symbol It shall cover an area of at least one quarter the size of the crossed out wheelie bin symbol However be sure to indicate clearly that the symbol refers to the battery
38. ngs of each element of the mark x Country Code the two letter ISO country abbreviation y Mill Identification product manufacturer name brand or assigned mill number z Approved International symbol for compliant non manufactured wood packing These labels should be marked legibly visibly and on two opposite sides of the wood article The mark should not be made in the colors orange or red which are colors used to label packaging containing dangerous goods On March 18 2002 the Interim Commission on Phytosanitary Measures ICPM mandated by the IPPC The International Plant Protection Convention to which 117 countries are party adopted an international wood packaging mark similar to that shown above but which included a no bug symbol As of June 2002 the IPPC suspended the use of the international wood packing no bug symbol due to difficulties in protecting the symbol In May 2003 a new certification mark was published and incorporated into the International Standard for Phytosanitary Measures Guidelines for regulating wood packaging in international trade ISPM No 15 The mark is available for use by IPPC Contracting Parties and members of FAO through the National Plant Protection Organizations NPPOs See symbol below 10 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 11 of 33 This document data record is the property of Pitney Bowes Inc a
39. not attached to product Czech Standard SN 77 0052 2 has been revised making material coding mandatory for plastics metals and composites Material coding is voluntary for paper glass wood and textiles Exemptions to identification marking Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 4 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied packages made from shrink foil or extruded plastic foil unless printed on and labeled packages whose nominal volume is 50 ml or less inner fixing elements interlayer and inserts unless marked by printing embossing and or stamping dosing and charging devices applicators closures caps lids stopgaps labels stickers tags packaging components whose weight is 5 grams or less Latvia Latvia requires material marking based on the EU material coding system see Section IIIB 1 Additionally indication of the percentage of recycled content if used is mandatory on metal and plastic packaging as of 2 April 2002 and on packaging made of glass paper paperboard wood textiles and composite materials as of 1 January 2004 Lithuania The packaging law requires material coding but the specific procedure will be determined by a subsequent regulation Poland Polish regulations require producers to mark alumin
40. not the packaging or the product Chemical Composition Labeling Taiwan requires the Chinese character symbols to appear on several types of batteries and their packaging If these batteries are incorporated into a product label is required on battery packaging and electronic product or user manual For button cells the nE labels may be placed on the battery or the packaging na Jk AE FA Fa d E Y 17 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 18 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Aluminum manganese button silver oxide and mercuric oxide batteries and or their packaging must bear this Chinese character panel at right Tubular batteries must bear the symbol on both the cell and the packaging Also nickel cadmium batteries and their packaging must be labeled with this Chinese character panel at right Sie 0 The labels must cover at least 5 of the battery or packaging surface The fie gt ee H minimum dimensions of the label should be 0 5 cm X 0 5 cm FEAE IVB Batteries Labeling on Batteries IVB 1 All Batteries KCA Logo All batteries or products containing batteries sold in the Netherlands must be marked with the small chemical waste or KCA logo an image of a crossed out garbage container in a frame This label is req
41. on all non hazardous packaging previously this standard was mandatory Finland Members of PYR the Finnish packaging recovery scheme may print the new PYR logo on their packaging to indicate that they fulfill their producer responsibility QO obligations via PYR Portugal ECOPONTO ECOPONTO ECOPONTO a AZUL J VERDE Sociedade Ponto Verde recommends labeling consumer packaging with its new ECOPONTO icons Yellow for plastic amp metal Blue for paper board Green for glass The use of these icons is voluntary Sweden REPA recommends that companies mark plastic paperboard amp metal consumer packaging with sorting symbols and instructions Companies must be registered with REPA and pay the packaging fees for the specific packaging to be authorized to use the copyrighted pictograms 15 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 16 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied IIIC Other Packaging Related Information Requirements lIC 1 Invoicing Italy CONAI the third party packaging organization requires that packaging fees paid appear on the invoice for the packaging and that the subsequent packer filler and importer invoices mention the fees paid For PB products imported to Italy this means that the importer must includ
42. on box only metal which have had a change to make them compliant i e plating Any Pitney Bowes specific part i e Supplier or Pitney Bowes RoHS a motor sensor cable etc which Label required on part and box if has had a change due to ROHS and feasible thus also required a drawing revision Item as in G but physical size or Supplier or Pitney Bowes ROHS material unable to carry individual Label required on box only labeling PRODUCT OEM placed on the ROHS Label required on PRODUCT Market after July 2006 which is and box RoHS compliant Pitney Bowes Product placed on the Pitney Bowes RoHS Label required Market after July 2006 which is on PRODUCT and box RoHS compliant Custom Pitney Bowes spares item Pitney Bowes RoHS Label required or assembly i e PSU high level on part and box assembly that already currently is labeled K Custom Pitney Bowes spares item Pitney Bowes RoHS Label required not individually labeled on box 26 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 27 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied WEEE Labeling Affected Products Electrical and Electronic Equipment subject to the WEEE Directive and placed on the market after Aug 13 2005 must be marked in accordance with CENELEC standard EN 50419 200 There is no require
43. opied part of the arrow s end is 120 The color of the mark should be distinct from other colors used on the packaging so as to make the mark clearly visible Note EPI interprets this as applying only to printed packaging not embossed symbols The label should be located on the front or side flank of the component unless impossible in which case the mark could be located on the bottom of the package If there are multiple components each component should bear a material label However if it is impossible to label each component or if there is no printing engraving on a component then only the major component should be labeled to indicate its material type as well as the material types of the other non labeled components referred to as inclusive labeling Inclusive labeling is prohibited from use on food packaging that under the Food Sanitation Act must indicate ingredients on the packaging Previous material coding regulations were repealed as of December 31 2002 Producers and or importers that wish to use this separate disposal label on other packaging materials on a voluntary basis must apply for its use through KORECO Producers and or importers may also voluntarily label other packaging elements i e packaging elements not required to bear the Separate Disposal label with material identification empty space ratio and number of layers Italy Italy no longer requires the use of the phrase non disperdere ne
44. quare centimeters packaging components whose volume is less than 30 grams or 30 milliliters packaging material on which it is impossible to print engrave or label due to elements or structural properties Shopping bags and wrappings filled at point of sale by sellers are exempt from the mandatory recycling and thus the labeling requirement Please note that for buffers that have no printing engraving or for which labeling is impossible the buffer should not be labeled and the label should not be placed on the box in lieu of the buffer The Korean text below the triangle reads separate disposal Material type abbreviations PET HDPE LDPE PP PS PVC OTHER metal Fe Al paper paper pack or glass should be indicated inside the triangle Material types other than plastic resins should be written in Korean The symbol excluding the separate disposal text below must be larger than 8mm in width and length The height of the separate disposal Korean text should be one fourth of the width of the symbol The extension of each side of the symbol is a regular triangle whose inside angle is 60 and outside angle at the bended PET we oS bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 9 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be c
45. removal of these batteries The manual must also include information on recycling disposal facilities and or a telephone number under which more information is available Lithium Batteries and Battery packs GRS the battery recovery organization in Germany requires members to inform end user in instructions for use of lithium batteries and powerpacks that only discharged batteries should be deposited in collection boxes and instruct them to take precautions against short circuiting in the case of partially discharged batteries an additional indication that short circuiting can be 21 Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 22 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied prevented by insulating the poles with adhesive tape is recommended Not required if constructional measures have been taken to ensure that the returned batteries cannot be short circuited Symbols and Labeling as on Battery The owner s manual must also contain the KCA Logo crossed out wheelie bin chemical symbols as applicable and other labeling that would normally appear on the battery IVD 2 Non removable Batteries Recycling Disposal Information If the battery is permanently installed in the equipment or product then the user manual must contain a statement such as the follow
46. rk right must be placed on wood that has been treated The letters in parentheses are used here to indicate the meanings of each element of the mark Design Guideline Standard G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 10 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied a Trademark the identifying symbol logo or name of the accredited agency optional b Mill Identification product manufacturer name brand or assigned mill number the unique number assigned by the national plant protection organization to the producer of wood packing who is responsible for ensuring the appropriate wood is used and properly labeled c Heat Treated mark the abbreviation indicating treatment i e heat treatment HT methyl bromide fumigation MB de barking DB chemical pressure impregnation CPI d Country Code the two letter ISO country abbreviation For pallets manufactured of 100 manufactured wood a Manufactured Wood Certification Stamp must be used Manufactured wood includes oriented strandboard plywood strawboard masonite particle board paper overlaid veneer laminated veneer lumber or any combination of these To the right is an example of Manufactured Wood Certification Stamp to be used on manufactured wood pallets The letters in parentheses are used here to indicate the meani
47. rossed out wheelie bin right shall cover 3 of the area of the largest side of the battery or accumulator up to a maximum size of 5 x 5 cm For cylindrical shaped batteries the symbol shall cover 3 of half the surface area of the battery or accumulator and shall have a maximum size of 5 x 5 cm However for small batteries this formula would result in an illegible symbol In such cases the symbol measuring 1 x 1 cm must appear on the sales packaging Be sure to indicate clearly that the symbol refers to the battery not the packaging or the product The chemical symbol must be printed beneath the crossed out wheelie bin and shall cover an area of at least one quarter the size of the crossed out wheelie bin symbol The symbols shall be printed visibly legibly and indelibly KCA Logo For batteries containing more than 0 025 of their weight in cadmium or 0 4 of their weight in lead the logo must be affixed indelibly to the battery and used in association with the chemical symbol For built in batteries it may be printed on the packaging or the user s manual For details on the label and its use see the full KCA Logo section in Section IVB 1 20 bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 21 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be
48. s effective January 2003 there is a grace period until December 31 2003 for companies to comply Material coding is mandatory on all packaging of certain product types using the symbol below Product types covered are the following foods and beverages agricultural produce dairy and fishery products detergents cosmetics excluding glass containers shampoos and conditioners for pets drugs butane gas pesticides Packaging for the above products are required to bear the separate disposal label only if it is composed of a paper pack limited to paper packs that are coated and pasted with synthetic resins or aluminum foil metal container glass container or plastic resin Electronic equipment buffers for all electronic equipment i e consumer and commercial goods must also be labeled A buffer is defined as any packing materials that are made from foam like single synthetic resins which are made of beads containing hydrocarbons such as butane hexane pentane etc puffed by applying heat or by other means Examples of buffer materials are expanded polystyrene EPS polystyrene paper PSP expanded polyethylene EPE and expanded polypropylene EPP Sealed air is NOT considered a buffer and need not be labeled There are exemptions to the separate disposal labeling requirement which include the following packaging components that bear no labeling engraving or printing packaging materials whose surface is less than 50 s
49. stalled Batteries gt KCA Logo gt PB Name amp Logo gt Mercury gt Four Arrow Symbol Batteries that Contain Heavy Metals gt Taiwanese Labeling Non removable Batteries gt Recycling Disposal Info gt Chemical Composition gt Recycling Disposal Info gt Wheelie bin gt KCA Logo gt Take back symbols Required Labeling gt RoHS Labeling gt WEEE Labeling gt Mercury Containing Assemblies gt Isotiazolines gt Coding of Major Components gt Video Displays Requires labeling on All Batteries Other Information Owner s Manual Pre Installed Batteries gt Recycling Disposal Info gt Symbols and Labeling as on Battery Non removable Batteries gt Recycling Disposal Info Required Information gt WEEE Labeling gt Recycling Disposal Info Recommended Information gt EU Recycling Disposal Info gt Video Displays bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 3 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied gt Wheelie bin Recommended Labeling gt Mexican SPI coding gt Wheelie bin PACKAGING LAWS REQUIREMENTS IN DETAIL IIA Mandatory Labeling of Packaging ll1A 1 Material Coding Austria Material coding is mandatory on plastic packaging in Austria Th
50. sure that the collection program s logo appears in all the right places To navigate the document start with the Overview and click on a heading or a bulleted item to view the requirements in detail At the end of the document you will find a Glossary and a list of other PB Documents that relate to product and packaging design batteries and other relevant topics Pitney Bowes Standards Engineering Design Guideline Standard G3810 Issued NOV 02 Revised JAN 06 Revision F Page 2 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied ll OVERVIEW TABLE OF LABELING REQUIREMENTS Click on any item to link to section headings Type of Requirement lll Packaging Labeling Requirements Mandatory Labeling gt Material Coding gt Take back symbols gt Recycling Disposal Symbols gt Wood packaging Voluntary Labeling gt Material Coding gt Recycled content gt Claims language gt Take back symbols All Batteries gt KCA Logo gt Take back symbols Batteries that Contain Heavy Metals gt Wheelie Bins gt Chemical Composition IV Battery Labeling Requirements V Product Electronics Labeling Requirements Required Labeling gt ROHS Labeling gt WEEE Labeling gt Mercury Containing Assemblies gt Isotiazolines gt Packaging made from Expanded Resins Pre In
51. the electrical and electronic equipment to enable facilities to appropriately recycle and dispose of the parts indicated in Annex II Norway Regulations regarding Scrapped Electrical and Electronics Products requires that manufacturers or importers state in sales material information regarding waste disposal and that the electronic equipment sold may be delivered to the distributor and that the products are covered by a return and recycling scheme Sweden The Producer Responsibility for Electrical and Electronic Products Ordinance requires that manufacturers importers inform households and others about the take back obligation and return system Video Displays Effective January 1 2005 California requires manufacturers of CRTs and other video display devices with a diagonal measurement greater than 4 inches to inform consumer where amp how to return recycle dispose via toll free web site product labeling user manual or pkg By April 1 2004 manufacturers must inform retailer that product is subject to waste electronic fee VC 2 Recommended Information TBD 30 bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 31 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied VI GLOSSARY Composite a packaging material or packaging compo
52. uired for all batteries but the guidelines for its use vary according to battery type e For batteries that do not contain heavy metals it may be printed on either the battery or the packaging e For batteries containing more than 0 025 of their weight in cadmium or 0 4 of their weight in lead the logo must be affixed indelibly to the battery and used in association with the chemical symbol see Section IVB 2 e For built in batteries it may be printed on the packaging or the user s manual When used on packaging The KCA logo must be clearly visible on the packaging of all battery types Although the logo can be applied by using stickers printing the logo on the blister card is preferred The KCA logo must be applied in inerasable print on the back of the blister near to the Dutch text The NL symbol is optional and may appear below or next to the garbage can The minimum dimensions are 10 mm w x 14 mm h for the vertically oriented version or 10 mm w x 14 mm h for the horizontal format PB Name and logo France requires that all batteries be labeled with the battery producer s name logo the battery manufacturer AND installer s for batteries incorporated into products or distributor s for 18 bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 19 of 33 This document data record is the property of Pitney Bowes Inc and contains P
53. um and plastic packaging according to material content and recyclability The following exemptions apply 1 aluminum foil covered by plastics and laminates with aluminum foil paper or cardboard paper 2 two or more different materials but such packaging shall not be considered to be made of one type of the material with a closing made of another material 3 aluminum of a mass less than 5 grams SPI and other US or EU coding see Section IIIB 1 may be used Romania Romania requires material coding using a system similar to the EU coding system Details TBD Slovakia Slovakia requires material coding following the EU coding system see Section IIIB 1 and the use of the Tidyman symbol right Effective January 1 2006 only packaging or packaged products which are marked material coding disposal mark may be placed on the market Multi trip packaging must be clearly and legibly marked with the words Navratny obal returnable packaging Exemptions from marking Packs with a surface of less than 100 cm packs with a capacity that does not exceed 50 ml inner fixings components and inner layers if these are not printed or embossed plastic film that is not printed or that bears no label packaging ancillaries such as labels or hang tags and packaging components whose weight does not exceed 5 g Marking details mm bm esign Guideline Pitney Bowes tate G3810 Standards Engineering Issued NOV 02 Revised JAN 06 R
54. vertising Substantiation Statement every express and material implied claim that the general assertion conveys to reasonable consumers about an objective quality feature or attribute of a product or service must be substantiated Unless this substantiation duty can be met broad environmental claims should either be avoided or qualified as necessary to prevent deception about the specific nature of the environmental benefit being asserted Recyclability Unqualified claims of recyclability for a product or package may be made if the entire product or package excluding minor incidental components is recyclable For products or packages that are made of both recyclable and non recyclable components the recyclable claim should be adequately qualified to avoid consumer deception about which portions or components of the product or package are recyclable Claims of recyclability should be qualified to the extent necessary to avoid consumer deception about any limited availability of recycling programs and collection sites If an incidental component significantly limits the ability to recycle a product or package a claim of recyclability would be deceptive A product or package that is made from recyclable material but because of its shape size or some other attribute is not accepted in recycling programs for such material should not be marketed as recyclable Background The FTC has amended its guidance for the use of recyclability claims Th
55. ycled or recovered material and it is important to differentiate Industrial Scrap from Pre Consumer Recycled Material 31 bas gee n esign Guideline Pitney Bowes ela G3810 Standards Engineering Issued NOV 02 Revised JAN 06 Revision F Page 32 of 33 This document data record is the property of Pitney Bowes Inc and contains PROPRIETARY and CONFIDENTIAL information and is not to be copied Pre Consumer Material Materials and by products from manufacturing processes that would be destined for disposal had they not been diverted from the waste stream for reuse or recycling However pre consumer material does not include materials and by products generated by and commonly reused in an original manufacturing process see Industrial Scrap Post Consumer Material Materials generated by consumer business or institutional sources that have served their intended use or completed their lifecycle and would be destined for disposal had they not been diverted from the waste stream for reuse or recycling Rigid Packaging Container A package that retains its original volume after it has been emptied of its contents and in the absence of any external constraints Note that some jurisdictions have more specific definitions of rigid containers RoHS EU Directive on The Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment 2002 95 EC Sales Packaging Packaging which togeth
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