Environmental factors affect business decisions more and more as politicians and consumers become increasingly aware of the effect our society has on the environment.  This is not restricted to the end-user, typically retail use of products such as recycling packaging, reducing gas consumption and so on, nor in the raw sources of materials, such as renewable resources, managing forests – but in the impact of interim production.

RFID tags are widely used in industry because of their flexibility and the high degree of utility and effectiveness they provide in tracking assets.  RFID tags are used in the most extreme environments such as in the sea, where salt water acts as a highly effective corrosive or in sub-zero temperatures of Arctic oil production fields.  The focus has been on developing RFID asset tags which are capable of handling anything that is thrown at them or where they are thrown into space!

The technology focus is now shifting to developing RFID asset tags which are biodegradable.

The idea stems in part from the tracking systems used in wildlife research and management.  A radio collar or tag attached to an elephant of shark is simply a glorified RFID asset tag!  The issue there has been to be able to remove the tag when the animal study has finished, without of course harming the animal.  The automated removal of collars and tags did not address the issue of the biodegradability of the tag as in many instances it was designed to be recovered in order to collect the stored information.  This altered when studies revealed tag recovery was not always possible or desirable and the issue became one of how to track an animal and allow the tag to degrade naturally, usually from within the body of the animal involved.

It has become a short lap in imagination to see the application of biodegradable asset tags to commercial use, however there are limited applications for biodegradable RFID asset tags outside of livestock management.  The focus has therefore moved to how RFID tags can naturally degrade in the environment once they have been used combined with developing re-use strategies for both the RFID tags and the integral components.

Presently, RFID asset tags are typically manufactured from a silicon chip, a polymer substrate and a metal, radio antennae which is held together by adhesives.  None of the typical components are environmentally friendly in terms of ability to decompose, while many of the materials could lend themselves to recycling and re-use if they could be effectively managed on a commercial scale currently not available.

Biodegradable RFID asset tags are still some way off but they are undergoing development at the time of writing (January 2010) and are likely to be introduced to market in the commercial short-term.  Several companies at home and overseas are working on cracking the issues with biodegradability, notable the larger manufacturers which is probably as well as it is clear that one key to effective minimization of environmental impact will be to ensure standardization on a massive scale.

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The US Product Safety Commission is responsible for the Consumer Product Safety Improvement Act which was amended in 2008 and came into force in 2009.  A new section, S.103 covers product labeling of consumer products, making it mandatory for products to carry a tracking tag no matter whether they are imported or made in America and no matter who makes them.  Hand-crafted products do not escape the new legislation so, we’ll take a look at the new law and how it affects you.

Overview of s.103

s.103 mandates that all products, irrespective of origination, must carry a tracking tag to sufficiently identify where they were made and carry basic information to include:

• source of the product;
• manufacture date; and
• information on the manufacturing process, such as batch identification or in the case of a hand-crafted business, the worker id.

There is a key phrase which has been appended to all these requirements and serves to ameliorate the impact of the new law – manufacturers are only required to add tracking labels, “…to the extent practicable.”  For instance, if you are making miniature figurines an inch or two high, you may not be able to add a tracking label and all the information required, especially if they are not shipped with individual packaging and are part of a batch of product, for instance candy or home-made chocolate.

Tracking labels cannot refer to safety information or standards, unless your product actually complies with that safety standard.

The new law came into force on August 14, 2009 though the safety standard provisions came into effect from October 13, 2008.

How the Law Impacts Home-based Businesses

Congress received a lot of representations from small and home-based businesses on how the new law would impact them and their businesses.  It is apparent that s.103 brings many small and home-based businesses under the aegis of labeling legislation for the first time, so what do you need to consider to get yourself into line with the new law?

Look at Your Existing Tracking System

Part of the attraction behind buying hand-crafted goods is that they are individual, if not unique.  Adding tracking labels detracts from this (even though they can be removed).  You may already be doing enough to satisfy s103 of the new law, so your first step is review your existing tracking system.

The law requires that your tracking tag should identify you as the manufacturer sufficiently so a consumer is able to find and contact you with any requests for more detailed product information or any information proscribed by the new law.

Product Specific Information

Ask yourself, if a customer came back to you with a piece you sold them a couple of years ago, would you be able to advise that customer on the materials you used to make that piece?  The new law imposes an obligation to be able to advise customers on safety issues and characteristics of the materials used in construction.  An effective way of doing this is to maintain good records and receipts which allows you to be able to identify when you used certain materials in your business.

Marking Your Packaging

If your products are sold through retailers, can someone see from the packaging information which would be sufficient to identify them as products subject to a safety recall notice?  If the packaging does not include this information, does your product carry it where it is visible through the packaging material?

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