C0258 - cecAP FAQs
Introduction
This section provides a list of frequently asked questions ("FAQs") we have received from people completing their cecAP, and the related answers.
Q1) What Life Cycle Analysis ("LCA") data and calculations do we need to provide during the CEC Assessment?
Evidence independent of who conducted the LCA analysis and calculations
The evidences you should have at hand for a CEC Assessment, independent of who conducted the LCA Calculations for energy consumption and CO2 footprint, are:
- Measurement records from weight and dimensional measurements of the components (a layer in a card construction is considered a component) you have provided in the cecLQRF
- Documents provided by suppliers or 3rd party laboratories serving as evidence for recycling, renewable, or recovered-from-waste content of each component
- Records of energy consumption for the time period reported
- Records of reject rates for the time period reported
- Evidence related to other CEC requirements beside the metrics
Case 1 — Additional evidence required if LCA Support service is provided by TruCert
If you decided to take the LCA Support service from TruCert, the input data for your LCA calculations, and the results, are contained in the cecLQRF file you received from TruCert.
The related calculations are documented in the cecLQRF file and in TruCert's LCA systems.
While you should retain the cecLQRF file as a record, you may assume that both the cecLQRF and TruCert's LCA system are accessible to the CEC Assessor.
Case 2 — Additional evidence required if LCA Support service is provided by another entity
You may decide to conduct the LCA calculations yourself, or use an external LCA consultant.
In this case, you are responsible for demonstrating during the CEC Assessment that all assumptions and calculations have been conducted in line with the CEC Requirements.
Therefore, you must make accessible the assumptions and methods underlying the data you report in the cecAP. This typically includes:
- All inputs and assumptions forming the basis of the LCA calculations
- The calculation methods used
- The product system modelled in the LCA calculation system
- The Life Cycle Inventory
- The results of the calculations
- Access to the system used to model the product and calculate the data, including someone who is able to operate the system
See the CEC requirements for more details.
Q2) Do I have to show the CSI letter during the CEC Assessment?
It is part of the CEC Assessment to check if, where applicable, a CSI letter has been granted for the product subject to the CEC Assessment.
If you have not already received the CSI letter at the time of the CEC Assessment, the CEC Assessment will still proceed. The missing CSI letter will be noted as a NC and a corrective action will be imposed requiring you to obtain a CSI letter and provide it to the CEC Assessor. The CEC Certificate will not be issued until you have provided a copy of the required CSI letter.
Once the CEC Assessor confirms that the CSI letter has been issued for your product, the CEC Certificate can be issued.
So, you do not have to wait until you have received the CSI letter before starting the CEC Certification process, but you need the CSI letter before the CEC Certificate can be issued. Hence, it might be a good idea to start both processes in parallel, as both processes take some time.
Q3) What evidence do I have to show to satisfy the requirement for CQM conformity
By default, the product subject to CEC Certification must conform to the applicable CQM requirements.
To demonstrate this during the CEC Assessment, you must provide a qualification report with at least the following information:
- List of all applicable requirements
- Conformity verdict per requirement (conform, or not conform)
- Reference to the test results, or the test results themselves
Non conformities of the product with specific CQM requirements must be covered by a CSI letter.
If you have a product that does not fulfill this, but you believe that the product deserves certification, please contact the CEC scheme at contact@cecocert.com.
Q4) What is the Halogen Content of the plastic material I use?
Usually, your supplier of PVC can tell you the Halogen Content of the plastic material they supply you.
If your supplier does not provide you this information, then use the following assumptions:
- For clear PVC films: 49%
- For white or coloured PVC films: 53%
- For plastic films made from PET, PETG, PLA, ABS, PC: 0%
Q5) What evidence do I have to provide if I claim that production waste is recycled?
If you claim that your production waste is recycled, you will have to provide evidence supporting this.
Evidence for recycling of production waste shall include:
- Records showing the total amount of production waste produced by your facility, for and per each material you claim is recycled
- Records showing that these wastes have been forwarded to a recycling provided
- A declaration by the recycling provide with the following details:
- Weight of waste received for recycling, and the type(s) of material received
- Description of the recycling process, including some photographic evidence illustrating the recycling process as conducted by the recycling provider; not generic photos found on the Internet are not accepted
- Description of the resulting product, for example resin for injection moulding, waste water or gutter pipes, films for card production
- Photographic evidence of the resulting product as produced by the recycling provider; generic photos found on the Internet are not accepted
A simple confirmation that certain amounts of material have been "picked up for recycling" is not accepted.
See CEC Requirement RF305.
Q6) When will the CEC Assessment be scheduled?
The CEC Assessment of your claim will be scheduled when the following two conditions are met:
- You have e-mailed the related cecAP, properly completed, to contact@cecocert.com
- You have paid the CEC Assessment fee in full, in accordance with the T&Cs stipulated in the cecAOF
We do no longer arrange CEC Assessment dates before these conditions are fulfilled.
Please note that typical payment issues resulting in underpayment include, but are unfortunately not limited to:
- The auditee did not pay the full bank charges; for example, by selecting the 'share bank charges' option when making the payment
- The auditee does not instruct their bank to transfer the full amount in the invoiced currency, but instead some lesser amount in their local currency calculated by themselves
- The auditee deducts withholding tax payments related to the CEC Assessment fee.
Please keep in mind that underpayment will result in delaying the CEC Assessment until the full amount has been received in our accounts.
Q7) What is the agenda for the CEC Assessment?
The agenda of the CEC Assessment is shown on the Coversheet worksheet of the cecAP, in Section 2. Search for "Assessment Schedule" if you cannot find it.