Material Hazardous Substance Management

Since 2016, Simplo has voluntarily adopted the FMD mechanism. The FMD helps consumers understand the ingredients of materials and substances used in products. The FMD mechanism uses the green product management platform to investigate the ingredients covered by raw materials, and conduct data analysis and risk assessment. In addition, suppliers must sign the Statement of Conformity (SoC) to ensure compliance with latest regulations. When regulations are revised, the database must could identify high-risk raw materials to ensure that products comply with human health and environmental safety.
 

List of Hazardous Materials

In order to fulfill corporate sustainability responsibilities, reduce the impact on the environment and ecology, and comply with international regulatory requirements, Simplo Technology regularly checks international directives and relevant regulatory requirements, prohibits or controls their use and content in product materials, and stipulates hazardous substances Management standards. The company establishes a list of hazardous substances and announces the information on the green product management platform (Supplier Relationship Management, SRM) for suppliers and colleagues to follow. Management standards:

  • Level 1: The use of these substances and their purposes classified at this level must be banned immediately when over its allowed concentration.
  • Level 2: The use of these substances and their purposes classified at this level are phase-out in a specific period. On or after the date set in each table the substances in the respective table will be classified at level 1 and must not be contained in all materials.
  • Level 3: In order to monitor the use of hazardous substances in products, when these substances are intentionally used in modules, parts, sub-materials, materials, and the concentration is over its limit, the information of substances classified at this level should be disclosed.
  • Exemption: The substance applications classified as “Exemption” are those used for modules, parts, sub-materials, and materials but not regulated by the law or excluded from “the controlled substances” due to the unavailability of adequate alternative parts and materials on the market that satisfies the intended application.。Environment hazardous substances banned and restricted control list.

 

Hazardous Substance Verification

  • Simplo Technology collects hazardous substance test reports, material safety data sheets (MSDS), full substance declarations, material declarations, third-party test reports or supplier compliance statements from suppliers. This information can meet the content of IEC 62474 and can also be traced back to the upstream supplier.
  • Simplo Technology clearly stipulates in the purchase contract or order that suppliers of new materials must meet supplier specifications. Suppliers must ensure that all products sold to the company, the raw materials, solvents, consumables, packaging and processes used, etc. They do not contain or use harmful substances prohibited by the laws of the country where the product is located.
  • New materials must be inspected and tested by the technology research and development department and must be confirmed in accordance with “ Hazardous Substance Management Standards” to confirm that the new materials to be used meet the specifications or do not contain banned substances. If the supplier's materials are found to violate the hazardous substance management regulations, they will be handled according to the nonconforming product control procedures.

 

Materials and Parts Approval Process

 

 

 
 

 

 
 
Approval information Frequency
Level 3 Hazardous Substances Questionnaire New material approval/document revision (every year)
REACH Substances of Very High Concern (SVHC) Questionnaire New material approval/document revision (half a year)
Declaration of non-use of harmful substances New material approval/regulation revision (irregular)
RoHS test report New material recognition/report expiration (valid for 2 years)
Material Safety Data Sheet New material recognition/report expiration (valid for 2 years)

Full material disclosure (FMD)

Since 2016, Simplo Technology has been moving towards proactive material management and adopting the
Full Material Disclosure (FMD) action. FMD helps to build trust, promote industry standards, and address
consumer concerns about sustainability and health issues, which are part of corporate social responsibility and
sustainable development.

EU Chemical Policy (REACH)

REACH stands for Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH). As the name suggests, this directive requires chemical products entering the European market need to undergo registration, evaluation, authorization, and restriction based on their import status. Simplo Technology has established management and control procedures, conducted supply chain risk assessment, and participated in supplier conferences organized by customers to ensure that the flow of value chain information meets relevant requirements.
 

EU RoHS Directive

Simplo Technology's main manufacturing plant has implemented the IECQ QC080000 hazardous substance process management system since 2012 and obtained international certification. In addition to controlling raw material input according to RoHS processes, we occasionally conduct RoHS compliance testing on finished products. All products meet RoHS directive requirements, and to date, therehave been no RoHS violations or customer complaints.
 

Per- and polyuoroalkyl substances (PFAS)

In response to the US "PFAS Management Action Plan" and the EU REACH-related requirements, Simplo Technology has incorporated these regulations into the Hazardous Substance Management Regulations for material control. Regarding the PFAS-related information of our products, we also work with manufacturers to seek fluorine-free alternative materials or improve process technology, striving to achieve green products with consistent regulations and quality, and reduce risks to the environment and human health.
 

Product Safety

All products of Simplo Technology have been certified according to the mandatory or voluntary safety regulations of various countries and have undergone multiple safety tests and verifications before they are put on the market. The safety verifications include:
• International safety regulations (e.g. IEC 62133-2, IEC 62619, ISO 6469-1).
• European safety regulations such as EN 62133-2, 2014/35/EU LVD Directive, (EU) 2023/988 General Product Safety Regulation (GPSR), EN 62619.
• Important safety regulations of the U.S. and Canada (e.g. UL 2054, UL 62133-2, ANSI/CAN/UL 1973, ANSI/CAN/UL 9540(A)).
• China safety regulations (e.g. CNCA, GB, GBT, CQC, CCC).
• The safety regulations of Taiwan, Japan, Korea, India and the ASEAN countries.
• International transport regulations UN 38.3, etc.
Simplo Technology has a dedicated safety regulatory compliance department and a laboratory that has passed the ISO/IEC 17025 (CNS 17025) certification of the Taiwan Accreditation
Foundation (TAF). We plan to gradually increase our verification capabilities and expand our certification scope in the future to enhance product safety.
• Assessment of the impact of battery regulations
The EU Battery Regulation (EU) 2023/1542 was published in July 2023 to replace the original battery directive 2006/66/EC. Introducing new requirements for the sustainability and safety of batteries, including hazardous substances, QR codes, and design for removable batteries. The design of batteries in electronic products should be easy for end users to disassemble and replace, impacting Simplo's product verification process. Verification will shift from component-level (Recognized) to product-level (Listed), increasing the number of verification items and enhancing consumer safety.
 

Chemical Management Strategy

Simplo Technology ensures compliance with regulations and the spirit of REACH, regularly collects information on major international environmental regulations, stays abreast of the
latest trends, and continuously promotes hazardous raw material (chemical) substitution programs.