1. Marking of plastic parts
CB Forum 11 March 2014
EU Ecolabel TVs:
Marking of plastic parts

2. Text of EU Ecolabel criteria for televisions
Commission Decision 2002/255/EC: Plastic parts shall have a permanent marking identifying the material, in conformity with ISO 11469: Excluded from this criterion are extruded plastic materials and the light-guide of flat panel displays.
Commission decision 2009/300/EC: Plastic parts shall be of one polymer or be of compatible polymers for recycling and have the relevant ISO11469 marking if greater than 25 g in mass.

3. Dutch Applicant (extension of license)
Marking the optical components of a display would inevitably damage the optical performance of these components: no rim or overlap is possible on the optical components on which the ISO marking could be placed and where it would not influence the optical path.
This situation is not caused by a recent architectural change of the display setup, but has been there since the introduction of LCD Flat displays.
According to the applicant, the ISO marking is also absent in display products from their competitors.
Request to find a solution as soon as possible.
Level playing field!

4. Polish Competent Body
Confirms: “marking the plastic optical components according to ISO requirements is not possible without creating technical problems that will impair the appropriate functioning of the television”.
This technical problem is related to technology/material limitations: not manufacturer specific.
Other ecolabels recognize this technical problem and still provide a similar exemption:
EPEAT criteria based on IEEE Standard for Environmental Assessment of Televisions;
Japan Environment Association’s Eco Mark, Personal Computers Criteria, Version 2.9
Television Criteria, Version 1.0; TCO Development 3DTV “2011” draft criteria.

5. Possible solution of Polish CB supported by Dutch CB and Dutch Applicant
Criterion 5. Heavy Metals and Flame Retardants: no mention of exemption, but Application Form (page 14) presents the following exemption: “Note: only plastic parts of weight greater than 25 grams be considered within the boundaries of this criterion”.
Suggestion to introduce a similar exemption in page 12/13 of the same Application Form: “Note: Excluded from marking according to ISO require-ments are extruded plastic materials and the plastic optical components of the display panel” or “Excluded from this criterion are extruded plastic materials and the light-guide of flat panel displays” (like in 2002/255/EC).

6. Thank you for your attention and cooperation!
Ineke Vlot