Ballot Comments

NSF 426 Ballot Comments – Section 7
For Discussion at June 25-26 Joint Committee Meeting
Criteria Summary
7 Preferable materials use
7.1 Prerequisites
7.1.1 External enclosure
7.1.2 Disclosure of postconsumer recycled content
7.2 & 7.3 Optional Criteria
7.2.1 Postconsumer recycled content
7.2.2 Postconsumer recycled content of rare earth elements
7.3.1. Reduction of surplus parts by default
Ballot Comment Summary – from JC members and Public Review
Total comments: 28 comments (Note: some comments addressed multiple criteria.)
o 7.1.1: 8 comments
o 7.1.2: 4 comments
o 7.2.1: 7 comments
o 7.2.2: 5 comments (addressed in Section 9-10 document)
o 7.3.1: 5 comments
Some common themes
o Inclusion of metals in PCR criteria
o PCR plastic prerequisite
o Use of LCA to measure lower environmental impact
Proposed Discussion Topics for June 25-26 F2F
High Priority
1) 7.1.1/7.1.2/7.2.1: Should metals be included in these PCR criteria?
2) 7.1.1: Is a prerequisite for 20% PCR plastics in enclosures fair and reasonable?
3) 7.1.1: Will the use of LCA to measure “lower environmental impact” achieve the desired outcome?
4) 7.3.1 Value of criterion on reduction of surplus parts for servers
Assign to NSF, Individual or Small Group
5) Misc. comments on 7.1.1 & 7.2.1
Discussion Topic 1: Should metals be included in PCR criteria?
Discuss criteria 7.1.1, 7.1.2, and 7.2.1
7.1.2 Disclosure of postconsumer recycled content
There is no known way to track the PCR
content of metals used in commerce at this
time. It may be possible to establish a
tracking methodology (similar to conflict
mineral tracking) but at what environmental
benefit? Many metals are currently sold with
significant amounts of PCR, but once mixed in
at the smelter, it is impossible to tell what the
percents are.
We do not support a requirement for
reporting on postconsumer recycled content
of metals. While it may be possible to
determine the PCR content for significant
plastic parts, we do not currently have the
capability to document recycled content of
metals. Developing a system to collect and
document the recycled content of metals will
be difficult and will have no discernible
environmental benefit.
7.2.1 Postconsumer recycled content
Tim Mann/IBM
The vast majority of servers are made up of
metals that are already routinely collected
and recycled. Specifying increased recycled
content in servers will not result in any
increased recycling of these metals.
Most metal smelters include recycled metals
as part of their standard processes; the
amount of metal recycled per batch varies.
This requirement may be impossible to meet
due to smelter batch to batch process
decisions and variations.
This criterion should not include metal as the
infrastructure for recycling metal is
substantially in place world-wide; this
therefore becomes a point giveaway.
I believe that the number of optional points
available in 7.2.1, a total of 5, exceeds the
environmental benefit to be gained. I believe
that 3 optional points is more appropriate.
As with 7.1.2, there is currently no way to
track PCR content of metals.
Design Chain
Wayne Rifer/
Chris Cleet/ ITI
Remove the following two
lines from table 7.1:
• 25% PCR metal
• 25% PCR plastic
Supply chain availability is also a concern as
25% PCR plastic meeting NEBS flammability
rating of UL 94V-0 is not commonly
Discussion Topic 2: Is a prerequisite for 20% PCR plastics practical, fair and reasonable?
Discuss criterion 7.1.1
7.1.1 External enclosure
External enclosures for servers are largely
made of steel. It is impractical and of limited
environmental benefit to impose a PCR
material requirement on the small amount of
plastic contained in enclosures. Additionally,
any plastic material in the enclosure may
have strict performance and/or cosmetic
standards that may not be met with PCR
Chris Cleet/
Tim Earl/GBH
A minimum percentage of PCR for only one
class of materials is unfair. Many discussions
during the Joint Committee meetings
revolved around the assumption that all steel
and aluminum enclosures already have
"acceptable" levels of PCR. For steel, this was
based upon wide industry averages in the
United States only, with no regard given to
specific grades of material used in consumer
electronics. Plastic manufacturers are able to
trace their PCR usage within specific grades,
with third-party listing services
available. Because metal manufacturers
claim this is "too difficult" or maybe
"impossible", there is no proof requirement
for these metals. Plastics are put at a
competitive disadvantage partly because of
the very ability of plastic manufacturers to
trace PCR.
The result is that specific electronic grades of
steel and aluminum can be sourced anywhere
in the world and are considered "acceptable",
no proof required , even if made from 100%
virgin aluminum, shipped half way around the
world. Meanwhile, a 15% PCR plastic
material sourced from a local manufacturing
plant either could not be used or would need
to undergo an expensive and time consuming
It is not clear that 20% postconsumer resin is
feasible for use in casings; no studies show
that the color, safety and structural
requirements can be met with 20% PCR.
An LCA comparing two materials (for
example, biobased and PCR) will depend on
the specific environmental impacts being
considered. It is not clear how specific
environmental benefit will be addressed in
this criterion.
7.1.1 Metal receives an advantage here with
no recycled content necessary to be
considered preferable. This should be
The required threshold of 20% postconsumer content for plastic enclosures is
arbitrary. No life cycle analysis information or
data was presented to show that at this level,
there is a positive impact on the
environment. Additionally no LCA information
was provided that would demonstrate that
steel or aluminum enclosures are
environmentally preferred over plastics,
regardless of the plastics recycle content. No
evidence was presented to this
subcommittee that assures that the steel or
I suggest following the
structure of other
sustainability standards (such
as IEEE 1680.1) that set no
minimum PCR requirements,
but rather reward materials
that can show high levels of
aluminum used in these products contains
post-consumer materials at these levels. If a
20% post-consumer recycle content for
enclosures is determined to be a worthy
target with defined reductions in
environmental impacts, then all enclosure
materials – steel, aluminum, and plastics –
should be treated similarly to conform to
such a threshold.
The provision arbitrarily disadvantages the
use of plastics for enclosures. It should be
revised to provide optional credit for use of
PCR materials rather than as a prerequisite
and should include comparable PCR criteria
for metals. As the recycling content of metals
is not routinely tracked, it may be necessary
to establish criteria that are consistent with
standard industry practice, at least initially.
Provide optional credit for use
of PCR materials rather than
as a prerequisite. Include
comparable PCR criteria for
Discussion Topic 3: Will the use of LCA to measure “lower environmental impact” achieve the
desired outcome?
Discuss criterion 7.1.1 and LCA comment on 7.2.1
7.1.1 External enclosure
An LCA comparing two materials (for
example, biobased and PCR) will depend on
the specific environmental impacts being
considered. It is not clear how specific
environmental benefit will be addressed in
this criterion.
The criterion should reference the term
“external enclosure” as defined in 3.20
How to measure “lower environmental
How were these three choices
determined to be equivalent?
How is the LCA supposed to
demonstrate “lower
environmental impact”? Is
that across all impact
categories, or a majority?
11.2.1. does not indicate how
to judge what is “preferable”
from the inventory.
Also, 11.2.1 outlines an LCA
for the whole product, and
this criterion is for a particular
material. Maybe put in an
Annex what makes a good
LCA and then reference this in
both criteria.
The last bullet allowing for a material with
lower environmental impact seems like a
loophole to allow any material. Virgin
aluminum is one of the most energy intensive
materials that could be used. It would seem
that almost any other material will have a
lower environmental impact because of the
energy use of virgin aluminum. In addition
"lower environmental impact" is not defined
in 11.2.1 and is, in general, a vague term
which can mean different things to different
stakeholder groups. If one LCA has lower
energy use but another has lower EP which is
"lower environmental impact"?
The last bullet, "- A material
demonstrated to have lower
environmental impact than
those listed above based on
an LCA conducted in
accordance with criterion
11.2.1.", should be stricken.
7.2.1 Postconsumer recycled content
Brian Martin/
Although this is an optional criterion, use of
LCA calculations to demonstrate equivalent
or less impacts for alternatives to the
PCR/WEEE targets would be preferred.
Depending on the manufacturing location,
local supply chain logistics, and local material
availability, impacts for some materials with
lower PCR or WEEE content might be lower
overall than for the targeted PCR/WEEE
JC questions:
1) Keep metals in criteria 7.1.1, 7.1.2, 7.2.1 and/or remove from 1, 2 or all 3?
2) If metals removed from 7.1.1, should the criterion be:
a. Retained as is
b. Further modified
i. Exempt servers that use mostly metals in enclosure (Server manufacturer comment)
ii. Strike last bullet for LCA demonstration (William Hoffman proposal)
iii. Further define lower environmental impact and LCA (Elwood comment)
b. Deleted
3) For criterion 7.2.1 should an LCA option be added? (Brian Martin comment)
Discussion Topic 4: Value of criterion 7.3.1 for servers
This criterion (reduction of surplus parts) may
be more suited for a PC standard. This
criterion adds cost and no clear
environmental benefit for servers where
most installations are highly customized and
In many cases, servers are sold through third
party business partners, and it may not be
possible to exclude parts in those shipments.
Chris Cleet/
Tim Earl/
Ho/ Koi
Tim Mann/
Also, blanks and dummies have significant
function in the layout of a server to maintain
airflow and cooling. Developing a tracking
system for this will be very costly and provide
very limited environmental benefits.
The option to order the minimum number of
fans is problematic. Manufacturers are not
likely to over spec fans. If the intent is for
buyers to specify fewer fans for a
“downgraded” or “low end” server, then the
possibility exists that it will be upgraded later
and lack sufficient cooling, leading to failure
or a fire hazard. (We cannot rely on users
considering upgrading the fan if they upgrade
the server).
For Section 7.3.1, can you confirm that 1
point is given if the manufacturer provides
the declaration, or does the product
configuration need to be "zero" for all surplus
parts to get the 1 point? Additionally, what if
the customer requires surplus parts for
warranty purposes?
We do not support this criterion. While some
purchasers may welcome the elimination of
cables, mounting hardware, and cosmetic
dummies from their products, the majority of
customers expect and want these included
with product shipments. Eliminating these
from shipments as a default would likely
cause customer satisfaction issues, and is not
Revision options:
1) Retain as is
2) Consider revisions (none suggested)
3) Delete criterion (several commenters)
Misc. comments on 7.1.1 & 7.2.1
7.1.2 Disclosure of postconsumer recycled content
Chris Cleet/
Regarding the sentence “additives and
fillers used in material shall be included in
the denominator”, this would seem to
apply to additives and fillers contained in
the recycled plastic (which is not
reasonably feasible to measure).
Elwood/ EPA
The text says “entire weight of the
product, less exclusions, should be
included in the denominator”, but the
denominator in the formula says “total
material (of the type in the numerator) by
weight…”. These are very different. If you
follow the formula, it is weight of PCR in
plastic divided by all plastic, but if you
follow the text it is weight of PCR plastic
divided weight of entire product (exclusions). Need to clarify what counts
and what doesn’t. Maybe an annex with
more detail about how to calculate PCR?
It was discussed in the development of
this criteria that cables cannot be
manufactured using recycled plastic and
achieve a safety approval from UL
specifically and others by assumption. This
distorts the calculation as cables must be
used as part of the denominator but there
is no chance of them being part of the
Clarify that the criterion applies to all
materials. Fix the formula and
Actually, look to next criterion for better
details, though it has issues as well.
It is suggested that like the printed
circuit boards, cables should be added
to the parts that are excluded from the
Revision options:
Consider revisions
a. Exempt cables (Paul Parkinson comment)
b. Clarify to address Cleet and Elwood comments
7.2.1 Postconsumer recycled content
Tim Earl/
From the table: “Demonstrated
conformity with a material traceability
standard.” One example given. Either
define this in more detail or remove it.
Chris Cleet/
The two traceability standards listed apply
to plastics molders. It is not clear who
needs to demonstrate conformity and/or
how server manufacturers would or
should demonstrate conformity.
Revision options:
Consider revision
a. Clarify who needs to demonstrate conformity (Chris Cleet comment)
Examples of
standards are
provided in
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