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Complying with Laws, Regulations and Social Trends

Compliance with Environmental Laws and Regulations on Products

Complying with environmental laws and regulations in various countries with full collaboration of the supply chain

In recent years, various laws and regulations have been introduced at both the national and regional levels. Legal and regulatory restrictions have been rising year after year regarding chemical substances and product areas covered. Legislation covers such areas as reducing power consumption during product use, as well as environmental and health impacts.

As a global company with operations in more than 40 countries, the Brother Group believes that compliance with laws and regulations is the foundation of environmental risk management and product competitiveness. The Brother Group has developed activities in line with the Brother Group Environmental Action Plan 2018 (2016-2018), in order to ensure compliance with laws and regulations in all the countries and regions in which the Brother Group operates and to quickly prevent pollution and reduce environmental impacts with high ethical standards. In FY2016 (April 1, 2016-March 31, 2017), to fulfill the environmental targets of globally complying with regulations on chemical substances and energy-saving regulations on products, the Brother Group has been committed to continuously strengthening its framework for responding to developments of laws and regulations in respective regions and offering eco-conscious products before new regulations come into force. Ensuring compliance with laws and regulations across the group has made it possible to quickly cope with needs for products and enhance sales and services.

To deliver environmentally conscious products, environmentally conscious parts and materials must be used. When procuring parts and materials, suppliers are asked to deliver parts and materials in accordance with the Brother Group Green Procurement Standards. Also, the Brother Group conducts audits on suppliers every three years to check their management systems and operations. Suppliers are required to make necessary improvements and guarantee that the goods that they supply meet the standards.

Green procurement

Compliance with the RoHS Directive in different countries

RoHS, which is an EU directive introduced in July 2006, bans the use of hazardous substances in electrical and electronic equipment. In response to this directive, the Brother Group worked with suppliers to build Brother's unique environmental information system, which is used to investigate, avoid, and manage chemical substances contained in products. Later in 2007, China RoHS came into force, requiring the labeling with information on the contents of hazardous substances for electronic information products sold in China.
In 2008, the South Korea WEEE & RoHS came into force, requiring manufacturers to: restrict the use of hazardous substances contained in electrical and electronic products; set content standards for such substances; recycle products; and collect packaging materials. The Brother Group promptly complied with these new laws by utilizing the environmental information system.
FY2009 (April 1, 2009-March 31, 2010) saw new regulations come into force or conventional regulations tightened in different countries and regions, for example, enforcement of the Turkey RoHS, and the addition of restricted substances under the Canadian Environmental Protection Act (CEPA), which is intended to control hazardous substances. The Brother Group succeeded in promptly meeting all of these regulations.
In FY2010 (April 1, 2010-March 31, 2011), the Brother Group complied with the Serbian WEEE & RoHS and RoHS in the Ukraine.
In FY2011 (April 1, 2011-March 31, 2012), in emerging countries including China, Southeast Asia, and India, local sales facilities joined local manufacturers' associations and actively conducted information gathering and lobbying activities, thus strengthening communications with the authorities in respective countries. A framework is now in place in this region for the compliance with environmental laws and regulations.
In FY2012 (April 1, 2012-March 31, 2013), the Brother Group complied with the WEEE & RoHS in India and RoHS in Vietnam.
In the US, the Brother Group ensured compliance with the Toxic Substances Control Act (TSCA, which regulates commercially used chemicals), the California Proposition 65 (a law requiring warning labels for hazardous substances), and the Perchlorate Contamination Prevention Act.

Compliance with the REACH Regulation (EU)

REACH is the EU Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. It came into force in June 2007 for chemical substances that are manufactured or imported. Phased registration deadlines are set depending on the substance and its volume band. The Brother Group completed pre-registration of chemical substances covered by the regulation by FY2008 (April1, 2008-March 31, 2009).
In EU countries, manufacturers are required to (i) report SVHC (Substances of Very High Concern) content in products, (ii) disclose information regarding SVHCs when selling products and (iii) respond to inquiries from consumers within 45 days. The Brother Group improved the environmental information system to facilitate the investigation of SVHC content. In FY2009, the Brother Group set up a system for collecting data from suppliers to improve disclosure of information on SVHC content.
In FY2010, the Brother Group developed a system for calculating the SVHC content in products and reporting it to the appropriate agency as necessary. Meanwhile, safety data sheets (SDSs) have been translated into EU languages and have been published on the website.
In FY2012, the SDSs were revised to comply with the revised REACH Regulation.

Safety Data Sheets (SDS)

Compliance with energy-saving regulations in respective countries

The Ecodesign (ErP) Directive (formerly, the EuP Directive, which came into effect in 2005, and was revised in 2009) was set up as a framework that requires the eco-conscious design of energy-related products sold in the EU, to help prevent global warming. The Brother Group uses the data in the environmental information system to calculate life-cycle assessment (LCA) results and facilitate eco-conscious design, thereby ensuring quick compliance with the directive.
Energy-saving technologies for applicable products were developed, and relevant procedures for product environmental impact assessments were updated for "imaging equipment (Lot 4)," "standby and off-mode losses (Lot 6)," "external power supply (Lot 7)," and "networked standby losses of energy using products" (Lot 26) (these are categories into which Brother's products fall) to put in place a framework for compliance. A system is in place to ensure compliance.
Countries outside the EU have increasingly introduced laws and regulations requiring eco-conscious design and set energy conservation standards in respective product areas. The Brother Group has taken quick action to meet these laws and regulations.
In the U.S., energy conservation standards were established for each product area in accordance with the Energy Policy Act of 2005. The Brother Group met the standards for external power supply products. Meanwhile, the Brother Group ensured compliance with similar energy conservation standards in other countries including Australia and Canada. In South Korea, the Brother Group complied with energy conservation standards for printers, All-in-Ones, and AC adapters based on the Energy Use Rationalization Act.

Compliance with the WEEE Directive, etc.

The WEEE Directive requires the collection and 3Rs (Reduce, Reuse and Recycle) of used electrical and electronic equipment. Member countries, distributors, producers, and other entities are required to fulfill the requirements in the design, sorting, collection, and recycling phases. The Brother sales offices in Europe are members of a compliance organization or scheme in their country. Compliance organizations recover and recycle WEEE on behalf of companies to meet the requirements and targets set within the Directive. The Brother Group also works on collection and recycling on a voluntary basis in Australia and New Zealand.
In FY2009, the Brother Group ensured compliance with the Enforcement Ordinance of the Act on the Promotion of Saving and Recycling of Resources in South Korea. A collection and recycling system for Brother's products was developed in Japan in collaboration with partners, and commenced in FY2012. In the US, a collection and recycling system is operated by contractors in accordance with state and federal laws.
Recently, WEEE-based bills have been drafted and legislated in other countries, primarily in Southeast Asia. As in the case of the RoHS Directive, etc., the Brother Group continuously obtains the latest information through sales companies in respective countries, manufacturers' associations, information services, etc., to ensure legal compliance.

Disclosure of product information in accordance with The Eco Declaration (ECMA-370) (Europe and the U.S.)

The Brother Group discloses the environmental characteristics (including legal requirements) of printers, All-in-Ones, label printers, scanners, etc. for Europe and the U.S. in accordance with The Eco Declaration (ECMA-370) which is a standardized format and system for disclosing environmental characteristics of ICT and CE products including printers and All-in-Ones in Europe.

The Eco Declaration

Efforts to prevent illegal logging (EU and Australia)

The EU Timber Regulation and Australia's Illegal Logging Prohibition Act have entered into force, which prohibit placing timber products (including paper products) derived from illegally harvested timber on the market. The regulations also require investigations and assessments of suppliers to prevent mixing of illegally harvested timber. The Brother Group collected information from suppliers about inkjet and thermal paper as well as product package boxes, and confirmed the legality of timber used as a raw material.

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