EKSP-2285, Version 8.0

Kodak Health, Safety, and Environmental (HSE)
Supplier Requirements

For Articles, Chemicals, Electrical and Electronic Equipment, and Packaging

Table of Contents
1.

Purpose .............................................................................................................................. 2

2.

Scope ................................................................................................................................. 23.

Supplier Responsibilities ..................................................................................................... 2

4.

Ethical Requirements .......................................................................................................... 4

5.

Article Requirements ........................................................................................................... 5

6.

Chemical Requirements ...................................................................................................... 6

7.

Electrical and Electronic Equipment (EEE) Requirements................................................... 78.

Packaging Requirements .................................................................................................... 99.

Appendices ........................................................................................................................12
Appendix A – Declarable and Restricted Materials ................................................................................. 12
Appendix B – Traceability Requirements for Difficult-to-Identify Components ....................................... 19
Appendix C – Packaging References ..................................................................................................... 20
Appendix D – Instructions for Testing and Sampling Heavy Metals in Packaging .................................. 21
Appendix E – Definitions ......................................................................................................................... 22
Appendix F – Revision History ................................................................................................................ 25

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EKSP-2285, Version 8.0

1. Purpose
Eastman Kodak Company (Kodak) requires that products supplied to Kodak meet all
applicable regulatory compliance requirements during manufacture, global distribution,and sale. Additionally, Kodak has established internal standards that go beyond
compliance to reduce the environmental impact of our products. These requirements areincluded in this document.
Suppliers are required to conform to the requirements in EKSP-2285 Kodak Health,
Safety, and Environmental (HSE) Supplier Requirements for Articles, Chemicals,Electrical and Electronic Equipment, and Packaging (formally known as Kodak
Health, Safety, and Environmental (HSE) Specifications for Products, Parts andPackaging). If more recent regulatory compliance requirements are in force, Kodak
requires that the supplier meet these requirements. From time to time, otherdocumentation may also be used to communicate specific requirements as required by
Kodak businesses.
This document is revised periodically. The current version of EKSP-2285 can be found atwww.kodak.com/go/hsesupplier.

2. Scope
As Kodak is a global company, EKSP-2285 applies to all products supplied or licensed
to Kodak regardless of production or source location. Requirements apply to Kodak andnon-Kodak branded products and are based on the type of product. EKSP-2285
specifies HSE requirements for the following types of products:• Articles• Chemicals• Electrical and Electronic Equipment• Packaging

3. Supplier Responsibilities
3.1. Manufacturing/Export Approvals:
The supplier shall obtain and maintain any necessary approvals and authorizations from
regulatory agencies and other government organizations to manufacture in and export
from their country of manufacture.
3.2. Conformance Documentation:
The supplier is to complete either Kodak’s HSE Supplier Declaration Form (DF) or
respond to authorized third-party requests for conformance information.
Instructions for completing a DF can be obtained on Kodak’s website at:www.kodak.com/go/hsesupplier. If Kodak or an authorized third party acting on behalf ofPage 2 of 25

EKSP-2285, Version 8.0
Kodak makes a request for a DF, the supplier shall respond within 15 business days orsuch commercially reasonable shorter period as specific in the request.
3.3. Expectation Regarding Second and Third Tier Suppliers:
The supplier shall have a due diligence process for contacting their suppliers to ensure
accurate and complete information is provided to Kodak. Documentation and/or test
data, including documentation and data from the supplier’s supply chain, shall be kept
on file and made available upon request by Kodak.
3.4. Change Management:
The supplier shall promptly notify Kodak, by sending an email to ww-mcd@kodak.com
and copying their Kodak Procurement contact whenever product, process, material, or
regulatory changes result in changes to the DF that has been previously submitted.
3.5. Product Changes, Discontinuance, Recalls, or Non-Conformance:
The supplier is obligated to promptly communicate in writing to Kodak at wwmcd@kodak.com any changes, discontinuance, recalls, or non-conformance that could
impact the safety, health, or environmental performance of a Kodak product.
If potential safety, health, environmental, or regulatory issues are discovered by Kodak
or Kodak’s customers, which are determined to be the supplier’s responsibility, thesupplier will be notified in writing. The supplier shall address the concern in writing
within 15 business days from the date of all such notifications or such commerciallyreasonable shorter period as may be set forth in the notice.
3.6. Additional Information:
Suppliers shall promptly provide Kodak with documentation to verify compliance with
EKSP-2285 requirements or additional requirements identified in regulatory complianceguideline documents or other documents upon request. This includes, but is not limitedto:• Documentation to satisfy Kodak’s reporting requirements• Special applications, material composition or marking requirements (e.g., foodcontact applications)• Regional regulatory compliance and product labeling requirements
3.7. General Requirements for Articles, Chemicals, Electrical and Electronic
Equipment (EEE), and Packaging:
Note: The following requirements for Articles, Chemicals, Electrical and Electronic
Equipment (EEE), and Packaging are in addition to the requirements outlined in Section
5-8 for the individual product types.
3.7.1. Restricted Materials: Appendix A identifies restricted and declarable
substances/substance groups and the criteria suppliers shall use to evaluate each

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component of the supplied product, as well as reportable applications and thresholdlevels.
Unless Kodak has confirmed acceptability for use and provided written permission toa supplier, products shall not contain restricted substances above the prescribed
thresholds for the declarable applications listed in Appendix A.
3.7.2. Emissions from Products: Suppliers shall identify airborne emissions that may begenerated/emitted during normal conditions of use or foreseeable misuse (e.g.,volatile organic compounds, carbon black, ozone, styrene, objectionable odors, anddust). Certificates, test reports, and supporting documentation shall be provided uponrequest.
3.7.3. EU REACH Substances of Very High Concern (SVHCs): Suppliers are required todeclare all SVHCs present at greater than 0.1 % by weight in products supplied to
Kodak (Appendix A). Suppliers shall also review updates to the list of SVHCs andpromptly inform Kodak at ww-mcd@kodak.com if a newly added material is present
in the items provided to Kodak at greater than 0.1 % by weight.
Suppliers of equipment products and components for which Kodak uses anauthorized third-party to gather conformance information shall promptly respond torequests on an ongoing basis as the EU REACH SVHC list is updated.
3.7.4. Product Safety (PS): Products supplied to Kodak shall conform to all applicable
Product Safety (PS) standards appropriate for intended markets. Examples include
Flammability (UL-94), Toy Safety (ASTM F963, EN-71), or Food Contact.
Certificates, test reports, and supporting documentation shall be promptly provided
upon request.
3.7.5. Paper and Printed Materials: Paper and printed materials (including manuals andstuffer sheets) shall contain a minimum of 10 % recycled content OR be certified by
one of the following forest certification schemes:• Any national certification system that has been endorsed by PEFC (Programme
for the Endorsement of Forest Certification), e.g., Sustainable Forestry Initiative(United States) and PEFC Canada.
• The Forest Stewardship Council.
3.7.6. Packaging: Suppliers are required to meet all applicable Packaging Requirementsfor packaging components used in products supplied to Kodak.

4. Ethical Requirements
4.1. Conflict Minerals:
Kodak is committed to ethical and responsible conflict minerals sourcing in compliancewith the Dodd-Frank Act, EU Conflict Minerals Regulation 2017/821, OECD Due
Diligence Guidance, and industry best practices. To ensure compliance and prevent
sourcing from the Democratic Republic of Congo (DRC) and its surrounding countries
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EKSP-2285, Version 8.0(Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan,
Tanzania, Uganda, and Zambia) and conflict-affected and high-risk areas (CAHRAs),
when requested, suppliers to Kodak are expected to: have a conflict minerals policy, adue diligence management system, and annually return the requested Conflict Minerals
Reporting Template (CMRT) to kodakconflictminerals@kodak.com.
Kodak regards this program as a total supply chain initiative; therefore, we require our
suppliers, including distributors, to pass these expectations to their suppliers to ensure
conformance throughout the supply chain. Kodak will internally assess suppliers basedon the strength of their programs, aligning with the principles outlined in the OECD Due
Diligence Guidance. If a supplier fails to cooperate in implementing corrective measures
and/or does not meet compliance standards, Kodak reserves the right to takeappropriate actions, including discontinuing purchases from the supplier.
4.2. Animal and Plant Derived Materials:
4.2.1. Suppliers shall declare all animal and plant derived materials with documentation of
the source.
4.2.2. Products shall not be produced using materials from any plant or animal speciesclassified as endangered or threatened under the Convention on International Tradein Endangered Species of Wild Fauna and Flora (CITES I, II, III), the International
Union for Conservation of Nature (IUCN) Red List of Threatened Species™, and theEndangered Species Act (ESA).
4.2.3. Kodak requires that any materials sourced from farm-raised animals adhere to The
Five Freedoms.

4.3. Forced Labor and Supply Chain Due Diligence:
4.3.1. Suppliers shall comply with all applicable laws on human rights, labor and social
standards of the United Nations, the European Union, the United States of America,
the United Kingdom, and other countries worldwide in its global business operations.
Examples include but are not limited to the UK Modern Slavery Act, US Uyghur
Forced Labor Prevention Act (UFLPA), and Mexico’s Forced Labor Import Ban.
4.3.2. Suppliers shall comply with all applicable laws on supply chain due diligence andtransparency. Examples include but are not limited to the California Transparency inSupply Chains Act, US Uyghur Forced Labor Prevention Act (UFLPA), UK Modern
Slavery Act, the German Supply Chain Due Diligence Act and Australia’s Modern
Slavery Act.

5. Article Requirements
The supplier shall evaluate compliance with the Article Requirements as well as the General
Requirements for Articles, Chemicals, Electrical and Electronic Equipment (EEE), andPackaging.
5.1. Proposition 65:

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EKSP-2285, Version 8.0
Suppliers shall declare when labeling is required in the state of California, per the
California State Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).
Suppliers of consumer products shall provide Kodak with a product that does not
require a California Proposition 65 label, unless approved in writing in advance by
Kodak. The Proposition 65 list contains over 1,000 chemicals, including lead, mercury,phthalates, PCBs, and DEHP, and can be found at The Proposition 65 List - OEHHA(ca.gov).
5.2. EU Deforestation Regulation (EU) 2023/1115
Articles made from natural rubber and under the scope of the products listed in Annex I
of Regulation (EU) 2023/1115 shall be:• Deforestation-free• Produced in accordance with the relevant legislation of the country of
production.
• Covered by a due diligence statement.
Prior to supplying, suppliers shall provide Kodak with the information outlined in Article 9
of EU 2023/1115 to allow the necessary due diligence checks to be carried out.
5.3. Chemicals Released from Articles during Foreseeable Use:
Suppliers are required to meet all Chemical Requirements.

6. Chemical Requirements
The supplier shall evaluate compliance with the Chemical Requirements as well as theGeneral Requirements for Articles, Chemicals, Electrical and Electronic Equipment (EEE),
and Packaging.
6.1. Safety Data Sheets (SDS):
Suppliers are required to provide an SDS for chemicals, solutions, or mixtures to HSEat ww-sds@kodak.com and the Kodak purchasing representative at time of supply. The
SDS shall comply with applicable provisions of GHS (Globally Harmonized System ofClassification and Labeling of Chemicals), or the comparable regulation for the country
where the material is transported. The SDS shall be provided in English and in theofficial languages of all countries to which it is supplied. At least one EU SDS should be
provided (Germany is preferred.)
6.2. Global Inventory Status:
Suppliers are required to declare the status of chemicals (including those in solutions,mixtures or released from articles during foreseeable use) regarding chemicalregistration and premanufacture notification requirements in those countries that haveenacted such requirements. Countries and regions having chemical control regulations
include, but are not limited to, Australia (AICS), Canada (DSL/NDSL), China (IECSC),
European Union (EINECS), Japan (ENCS), Korea (ECL), New Zealand (NZIoC),
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EKSP-2285, Version 8.0
Philippines (PICCS), Province of Ontario, Switzerland, Taiwan, Turkey, and UnitedStates (TSCA).
6.3. REACH:
To assist Kodak in meeting requirements under European Union REACH Regulation(EC) No. 1907/2006, suppliers are required to promptly provide the following
information:• Identify whether the chemical is manufactured in the EU• Identify whether supplier has pre-registered or registered the chemical• Identify if the chemical is exempt from reporting (and if so, why)
Indicate if supplier’s Only Representative (OR) will agree to include Kodak volume/use
should Kodak have applicable reporting requirements for the chemical. To assist Kodak
in meeting REACH-like requirements in other countries such as Korea and Turkey,
suppliers are required to promptly provide additional information upon request.

7. Electrical and Electronic Equipment (EEE) Requirements
The supplier shall evaluate compliance with the EEE Requirements as well as the General
Requirements for Articles, Chemicals, Electrical and Electronic Equipment (EEE), andPackaging.
7.1. Traceability Requirements for Difficult-to-Identity Components:
Suppliers providing plastics, foam, wire harnesses, circuit boards and safety labels shallmeet the traceability requirements in accordance with Appendix B unless advised
otherwise. Meeting these traceability requirements will demonstrate to regulatory
inspectors that the material and/or part is identical to or equivalent to what is listed in
the agency's product safety inspection report.
7.2. Batteries:
Batteries shall comply with EU Battery Directive 2006/66/EC and EU Battery Regulation
2023/1542. When requested, suppliers shall provide Kodak with the following battery
information including, but not limited to:• The number and weight of embedded or non-embedded batteries shipped withthe product• Battery chemistry• IEC and ANSI Designations (e.g. R03 and 24)• Form factor (shape)• Voltage• Whether primary (non-rechargeable) or secondary (rechargeable)• Transportation classification• Safety Data Sheet (SDS)• Test reports and/or certifications (e.g., CE Mark, UL NRTL Mark, UN
Transportation Safety Test Certificate, Korea Product Safety Testing Certificate)
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7.3. Finished Commercial Electrical and Electronic Equipment (EEE) Requirements:
Finished EEE includes, but is not limited to, standalone printers, presses, platesetters,
plate processors, plate stackers, scanners, workstations, and external power supplies.
Regulatory compliance guideline documents or other documents may be used tocommunicate the intended countries of sale so that applicable regulatory compliancerequirements, marks, or statements are placed on the product and/or data plate and therequired documentation is delivered with the equipment. For example: serialized EU
Declaration of Conformity applicable for EEE in scope of the Machinery Directive.
7.3.1. Product Safety (PS): EEE shall comply with applicable US or EU Product Safety
standards when there are no country specific regulatory requirements. Otherwise,
EEE shall comply with all applicable Product Safety standards and workplace safety
requirements for the intended markets (e.g., UL, CSA, IEC/EN, ASTM standards and
EU Product Safety Directives). To ensure applicable PS standards are met, suppliers
shall disclose to Kodak if wireless or laser technology is used. Certificates, test
reports and supporting documentation shall be provided for all regions and/or
countries in which the supplier has approval to market upon request.
• Manuals or guides shall be provided which identify appropriate preventative andprotective measures to be employed to mitigate risk to customers and service
personnel during installation, use and service.
• Safety instructions and safety labels shall be provided in at least one of theofficial languages for the intended markets.
• Regulatory compliance guideline documents or other documents for specificproducts may contain additional requirements. Suppliers are expected to meet
all equipment regulatory requirements for the specified markets in which theequipment will be placed.
7.3.2. Electromagnetic Compatibility (EMC): EEE shall comply with applicable US FCC
or EU EMC Directive / standards when there are no country specific regulatory
requirements. Otherwise, EEE shall comply with all applicable Electromagnetic
Compatibility (EMC) requirements for the intended markets (e.g., FCC for US&C,
RCM Mark for AU&NZ, KC Mark for Korea, and CE mark / EU EMC Directive for EU).
To ensure applicable EMC standards are met, the supplier shall disclose to Kodak if
wireless or other ionizing / non-ionizing emitter technology is used. Certificates, test
reports and supporting documentation shall be provided upon request for all
countries in which the supplier has approval to market.
• Regulatory compliance guideline documents or other documents for specificproducts may contain additional requirements. Suppliers are expected to meet
all equipment regulatory requirements for the specified markets in which theequipment will be placed.
7.3.3. Sound Level: Products shall conform to the following sound pressure levels:• General office systems shall be less than 70 dB(A).
• Per Kodak Requirement, large professional operating systems shall be lessthan 80 dB(A) at workstations where operators will be continuously exposed.
Kodak bases full shift exposure levels on an 8-hour workday. Based upon the
OSHA Permissible Exposure Limit of 90 dBA as an 8-hr TWA or the Hearing

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Conservation Action Level of 85 dBA as an 8-hr TWA, each increase in 5 dBA
decreases allowable exposure time by one half (e.g. 8 hours to 4 hours).
7.3.4. Energy Efficiency: Products shall conform to all applicable energy efficiency
regulations including testing, labelling and registrations applicable to the equipment
type and the intended markets. (e.g., DOE for US, NRcan for Canada, EU Directive
2009/125/EC for EU, K-MEPS for Korea).

8. Packaging Requirements
The supplier shall evaluate compliance with the Packaging Requirements as well as theGeneral Requirements for Articles, Chemicals, Electrical and Electronic Equipment (EEE),
and Packaging.
8.1. Environmental Impact:
Packaging materials supplied to Kodak shall be designed and manufactured such that:• Their volume and weight are limited to the minimum adequate to maintain theappropriate and necessary level of safety and hygiene for concerned packed
products.
• They are re-usable or easily recyclable, or at least recoverable in the form ofenergy recovery.
• They contain, as much as possible, recycled materials
8.2. Marking of Packaging Materials:
All packaging shall bear the appropriate marking either on the packaging itself or on thelabel, as defined by the EU identification system for packaging material 97/129/EC.
Exceptions include metalized films and laminates, shrink wrap, foams and materials thathave dimensions or color that make marking impractical.
8.3. Plastic Packaging:
All Rigid Plastic Packaging Containers (RPPC) shall contain at least 25 % postconsumer recycled content.
All other plastic packaging should contain the highest percentage practical of recycledplastic content, aiming for a minimum of 30 % recycled content (pre- and/or postconsumer).
All plastic packaging shall be recyclable.
The use of plastic bags shall be limited to cases where they are essential to maintainthe appropriate and necessary level of safety and hygiene for concerned packed
products.
8.4. Paper Packaging:
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Paper-based packaging shall either be supplied by a Forest Stewardship Council (FSC)
certified source (or equivalent) or contain a minimum of 10 % recycled content.
Additionally, elemental chlorine shall not be used to bleach virgin or recovered content
fibers used in product packaging.
8.5. Wood Packaging:
Solid wood packaging materials that are used in international trade and may serve as apathway for plant pests shall be treated and marked when exported or imported and be
free of bark, according to UN Standard ISPM-15. For further information, refer toAppendix C.
Sawdust, wood wool, shavings and raw wood cut into thin pieces are not suitable
pathways for introduction of quarantine pests and are not regulated unless technicallyjustified.
8.6. Regional Requirements for Product Packaging:
Packaging shall comply with various state, country and regional requirements asoutlined below. Additional information on these requirements can be obtained fromreferences contained in Appendix C.
8.6.1. Regional Packaging Reporting: Suppliers shall provide the weight, volume,
material composition, including recycled content expressed in percent (%), of all thecomponents of the packaging supplied to Kodak upon request to facilitate calculationof Regional Packaging reporting obligations.
8.6.2. Dangerous Goods Packaging: Packaging used to transport Dangerous Goods
shall meet UN standards and suppliers shall provide a Dangerous Goods packaging
certificate upon request which declares that the materials have been packed andstowed in compliance with the applicable regulations (IMDG or IATA).
8.6.3. Requirements in the European Union (EU):8.6.3.1. European Directive on packaging and packaging waste
Suppliers shall provide Kodak with a Certificate of Conformity to "essential
requirements" fixed by Directive 94/62/EC, when requested.
8.6.3.2. Regulation (EU) 2023/1115 on products associated with deforestation
Packaging materials made with paper or wood shall be:• Deforestation-free• Produced in accordance with the relevant legislation of the country of
production.
• Covered by a due diligence statement.
Suppliers shall provide Kodak with the information outlined in Article 9 of EU
2023/1115 upon request to allow the necessary due diligence checks to be carriedout.

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EKSP-2285, Version 8.0
8.6.4. Requirements in South Korea:
8.6.4.1. Article 14 of the “Act on the Promotion of Saving and Recycling Resources”
requires that all foam packaging components used as cushioning materials forelectronic equipment in Korea be marked with a "separate discharge" mark. The
mark facilitates the separation of products and packaging for recycling. Exemptions
include: packaging and packaging component materials with a surface area of
50 cm2 or less; containers with components weighing 30 grams or less; andpackaging and packaging component materials whose nature and structure impede
printing, engraving or labeling on the material.
8.6.4.2. Per Ministry of Environment Notice No. 2019-244, the following packaging materials
are not allowed:•••

Poly Vinyl Chloride (PVC) laminations, shrink wraps and coatings
Colored Polyethylene Terephthalate (PET) bottles
PET bottle label adhesive that does not peel off from the bottle according toAnnex 1 of Packaging Material Recyclability Rating Evaluation Standard

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9. Appendices
Appendix A – Declarable and Restricted Materials
Substance/SubstanceGroup
Animal and plant derived
substances

Biocides / Biostats /Pesticides

Brominated flame retardants

Qualification/Threshold

Reference

Declare all substances that are intentionally added or
known to be present as an impurity.

•

Convention on International Trade inEndangered Species of Wild Fauna and Flora(CITES I, II, III)

Product Type
ArticlesChemicals
Packaging•

IUCN Red List of Threatened Species•

USA: Endangered Species Act (ESA)•

Kodak requirement•

USA: Federal Insecticide, Fungicide, andRodenticide Act (FIFRA)

Articles•Canada: Pest Control Products Act (S.C. 2002,
c. 28)

Packaging•

Biocidal Products Regulation (BPR, Regulation(EU) 528/2012)•

South Korea: Consumer Chemical Products
and Biocides Safety Act•

Blue Angel requirement

Use of polybrominated biphenyls (PBBs) andpolybrominated diphenyl ethers (PBDEs) atconcentrations above 0.1% by weight (1000 ppm), as
measured at the homogeneous level, is not permitted.

•

Kodak Requirement•

Use of brominated flame retardants other than PBBs
and PBDEs at concentrations above 0.1% by weight(1000 ppm), as measured at the product level, is not
permitted.

•

RoHS Directive 2011/65/EU and (EU) 2015/863 Chemicals
Packaging
USA: TSCA Section 6(h)Equipment
Canada - CEPA - Prohibition of Certain Toxic
Substances

Declare all substances that are intentionally added.

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Equipment

Chemicals
Equipment

ArticlesEKSP-2285, Version 8.0
Substance/SubstanceGroup

Qualification/Threshold

Reference

Carcinogens, Mutagens, andReproductive Toxicants(CMR)

Declare all substances that are intentionally added or
known to be present as an impurity.

••

Known human carcinogens:o

IARC 1;o

ACGIH A1;o

NTP “known to be human carcinogen”

Declare all materials that are known to cause
irreversible significant adverse effects in humans or
are strongly presumed to have the potential to causesuch effects by relevant routes of exposure (other than
CMRs)

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ArticlesChemicals

Suspected to be carcinogens:o

IARC 2A, IARC 2B;o

ACGIH A2;o

NTP “reasonably anticipated to be a
carcinogen”•

13 OSHA carcinogens•

Carcinogen, Mutagen, Reproductive Toxicant(CMR):
oChemicals of concern

Product TypeGHS category 1A, 1B & 2;•

CERHR classification "Serious concern" and"Concern" for adverse reproductive effects•

CA Proposition 65 list of reproductive /developmental toxicants and carcinogens•

SVHC Candidate List of EU REACH 1907/2006•

USA: TSCA Section 6 (15 U.S.C. §2605)

Articles•GHS criteria: Specific target organ toxicity(STOT) – repeated exposure Category 1 or 2

Chemicals•Blue Angel requirement

EKSP-2285, Version 8.0
Substance/SubstanceGroup
Conflict Minerals:
Tantalum

Qualification/Threshold

Reference

Declare all substances that are intentionally added or
known to be present as an impurity.

Tin

Product Type
Articles•Section 1502 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act•

EU Conflict Minerals Regulation 2017/821•

SVHC Candidate List of EU REACH 1907/2006

Articles•Substances classified as Category 1 orCategory 2 endocrine disruptors for humanhealth or for the environment under CLP
regulation

Chemicals•

List I and List III of the ED lists developed by the
Flemish, Danish, French, Dutch, and Swedish
authorities found at The ED Lists | Endocrine
Disruptor List•

USA: TSCA Section 6 (15 U.S.C. §2605)

Equipment

Tungsten
Gold
Endocrine Disrupters

EPA high-priority chemical
substances

Declare all substances that are intentionally added or
known to be present as an impurity.

Declare all substances that are intentionally added or
known to be present as an impurity.

ArticlesChemicals
Equipment

Fluorinated Greenhouse
Gases (PFC, SF6, HFC)

Shall not be intentionally added or used in
manufacturing.
When no alternative exists, only FluorinatedGreenhouse Gases with low Global Warning Potential
should be contained in products delivered by suppliers
to Kodak. Suppliers are required to provide Kodak with
the name of contained Fluorinated Greenhouse
Gases, their weights in each concerned product, andtheir Global Warning Potentials upon request.

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Kodak Requirement

Chemicals•(EU) No 517/2014

Equipment•

USA: EPA 40 CFR Part 82 Subpart G•

WA State Bill 1112, Hydrofluorocarbon
Greenhouse Gas Emissions.

EKSP-2285, Version 8.0
Substance/SubstanceGroup
Heavy Metals:
Cadmium/cadmium
compounds
Hexavalent chromium/hexavalent chromium
compounds (Cr+6)

Qualification/Threshold

Reference

Declare all substances that are intentionally added or
known to be present as an impurity.

•

Annex XVII of EU REACH1907/2006 (18, 23,
27, 47, 63)

In packaging: the total concentration of intentionallyadded cadmium, hexavalent chromium, lead, andmercury cannot exceed 100 ppm. Refer to Appendix D
for the test methodology.

•

China Administrative Measures on Electronic
Information Products Pollution Control•

EU Battery Directive 2006/66/EC and EU
Battery Regulation 2023/1542•

EU Packaging & Packaging Waste Directive
94/62/EC Article 11•

RoHS Directive 2011/65/EU and (EU) 2015/863•

Products Containing Mercury Regulations
SOR2014/254•

USA California Electronic Waste Recycling Act(California RoHS)•

Blue Angel requirement•

IEC 62474 - Material Declaration for Productsof and for the Electrotechnical Industry

In batteries: Cadmium/cadmium compounds arebanned from use for concentrations ≥0.001 % by
Mercury/mercury compounds weight. Lead/lead compounds require labeling if
concentrations ≥0.004 % by weight. Mercury/mercury
Nickel/ nickel compounds
compounds are banned from use for concentrations≥0.0005 % by weight.
Copper/ copper compounds
Lead/lead compounds

IEC 62474 Declarable
Substances

Declare all declarable groups and substances as
identified in IEC 62474, located at IEC 62474
The Declarable Substance List (DSL) and theReference Substance List (RSL) can be found along
the left-hand side of the IEC 62474 website.
The DSL is the list of declarable groups andsubstances.
The RSL provides an indicative list of substances,including CAS numbers, that are included within asubstance group.

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Product Type
ArticlesChemicals
Equipment
Packaging

ArticlesEquipment

EKSP-2285, Version 8.0
Substance/SubstanceGroup

Qualification/Threshold

Reference

Mineral oils - Mineral oil
aromatic hydrocarbons(MOAH) and mineral oil
saturated hydrocarbons(MOSH)

Shall not be ingredients used in printing inks for
packaging nor product documentation.

Nanomaterials

Declare particles that are considered nanomaterials aswell as provide any available data such as:• Specific surface area, shape, density

Product TypeChemicals•France: Anti-waste and Promotion of Circular
Economy, Law 2020-105•

Blue angel requirement•

USA: TSCA (40 CFR 704)•

Commission Recommendation of 10 June 2022 Chemicals
on the definition of nanomaterial 2022/C 229/01•

Montreal Protocol

Articles•List of Class I and Class II ODS can be foundhere: Ozone-Depleting Substances | US EPA

Chemicals

Packaging

Articles• Aggregation or agglomeration tendency• Surface modification• Physical-chemical properties (e.g., octanol-waterpartition coefficient, solubility, etc.)• Toxicity data
Ozone-Depleting Substances Shall not be intentionally added or used to(ODS)
manufacture products supplied to Kodak.

Equipment
Packaging

Per- and polyfluoroalkyl
substances (PFAS)

The following sub-categories of PFAS shall not be
intentionally added or known to be present as animpurity:
PFOS and its derivatives
PFOA and its derivatives
PFHxS and its derivatives
PFHxA and its derivatives
C9 - C14 PFCA
Declare all PFASs (including other subcategories notlisted above) that are intentionally added or known tobe present as an impurity.

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Kodak requirement

Articles•

EU Persistent Organic Pollutants (POPs)
Regulation EU 2019/1021

Chemicals•

USA: TSCA Reporting and Recordkeeping
Requirements for Perfluoroalkyl andPolyfluoroalkyl (PFAS) Substances

Packaging•

Canada - CEPA - Prohibition of Certain Toxic
Substances

Equipment

EKSP-2285, Version 8.0
Substance/SubstanceGroup

Qualification/Threshold

Reference

Persistent, Bioaccumulative,
and Toxic (PBT), very
Persistent and very
Bioaccumulative (vPvB),
Persistent, Mobile and Toxic(PMT), very Persistent andvery Mobile (vPvM), or
Persistent Organic Pollutant(POP) substances

Declare all substances that are intentionally added or
known to be present as an impurity.

Phthalates

Declare all substances that are intentionally added or
known to be present as an impurity. Shall not be
intentionally added in packaging.

Product Type•USEPA Sustainable Futures Guidance

Articles•

USA: TSCA section 6(h)Chemicals•

European Union REACH Directive/CLP
regulation

Equipment•

Annex XIII of EU REACH 1907/2006•

Annex I of EU POPs 2019/1021•

Stockholm Convention on Persistent Organic
Pollutants•

Kodak requirement

Articles•US Toxics in Packaging Clearinghouse (TPCH)

Chemicals

Packaging

Equipment
Packaging

Phenol, isopropylated
phosphate (3:1)

Shall not be intentionally added.

•

USA: TSCA section 6(h)Articles•Kodak Requirement

Equipment

PVC shall not be used for plastic packaging.

•Blue Angel requirement

Articles

PVC and PVDC shall not be used at concentrations>0.1 % by weight (1000 ppm) in articles.

•

Declare all PVC and PVDC that are intentionallyadded to equipment.

•

South Korea Ministry of Environment Notice No. Equipment
2019-244
Packaging
Kodak requirement

Declare all substances intentionally added or known tobe present as an impurity. Substances that fall under
Restriction 75 due to their classification as skincorrosive category 1, 1A, 1B or 1C, skin irritantcategory 2, serious eye damage category 1 or eye
irritant category 2 can be considered exempt from thisrequirement.

•

Annex XVII of EU REACH 1907/2006

Articles•Kodak requirement

Chemicals(PIP (3:1))
Polyvinyl chloride (PVC) andpolyvinylidene dichloride(PVDC)

REACH restricted
substances

Page 17 of 25

Equipment
Packaging

EKSP-2285, Version 8.0
Substance/SubstanceGroup

Qualification/Threshold

Reference

Product Type

Restriction of Hazardous
Substances (RoHS)

Equipment in scope of the RoHS Directive shalldeclare compliance on their EU DoC.

•RoHS Directive 2011/65/EU and (EU) 2015/863 Equipment•

Kodak requirement

Sensitizers

Declare all known respiratory or skin sensitizer
substances that are intentionally added or known to bepresent as an impurity.

•

Kodak requirement

Articles•Blue Angel requirement

Chemicals•

SVHC Candidate List in Annex XIV of EU
REACH 1907/2006

ArticlesSubstances of Very High
Concern (SVHCs)

Declare all SVHCs present at greater than 0.1 % byweightChemicals
Equipment
PackagingAnnex XVII of EU REACH 1907/2006 (78)

Synthetic polymer
microparticles

Declare all synthetic polymer microparticles as definedby Annex XVII of EU REACH 1907/2006•

Toxicity characteristic
substances

For articles and packaging: Declare all components
listed in 40 CFR 261.24, Table 1. Provide TCLP
(Toxicity Characteristic Leaching Procedure) test data
for any articles which contain a component from 40
CFR 261.24, Table 1•

USA: 40 CFR 261.24, Table 1

Articles•

USA: 40 CFR 261.33

Chemicals

ArticlesChemicals

PackagingFor chemicals: Declare all components listed in 40
CFR 261.33 and provide the weight %.
Volatile Organic Compounds(VOC)

Declare all substances that are intentionally added or
known to be present as an impurity.

•

Kodak requirement

Articles•

USA: EPA 40 CFR 59

Chemicals
Equipment
Packaging

Waste Electrical andElectronic Equipment(WEEE)

Equipment in scope of the WEEE Directive shall bemarked with the WEEE symbol.

Page 18 of 25•

EU Directive 2012/19/EU

Equipment

EKSP-2285, Version 8.0
Appendix B – Traceability Requirements for Difficult-to-Identify Components
Description

Plastic & Foam

Wire Harness

Circuit Boards

Safety Label

Requirements

Materials shall be identifiable to safety
agency inspectors.

Shall be identifiable as having
been produced under the UL
Recognized Wire Harness
Manufacturer’s Program and
CSA Certified Wire Harness
Program.

Shall be identifiable
as having been
produced under the
UL RecognizedComponent Printed
Wiring Program.

Shall be identifiable as having
been produced under the UL
and/or CSA Marking andLabeling System approvalprograms.

RequiredInformation fromsupplier with each
shipment••••

Wire Harness label on the
shipping container or on eachharness.

Mark parts according
to UL Printed Wiring
Program (e.g.
Manufacturer’s nameor trademark andboard type).

Manufacturer’s identity (e.g.,name or trademark) andmanufacturer’s label type (e.g.
Type 123).

••

Label on each harness
Label the smallest
deliverable package
Label the shipping box
for the harnesses
contained in the box

Mark parts according
to UL Printed Wiring
Programrequirements.

•

Harnesses will be produced
under the UL Recognized
Wiring Harness Manufacturer
program and be CSA
Certified.

Parts will be produced
under the UL
Recognized Printed
Wiring Board
program.

Safety labels will be approved to
UL and/or CSA "Marking andLabeling System" requirements.

••

Molder name
Kodak part number
Raw material manufacturer namePlastic manufacturer type designation(e.g.,"Cycoloy C6200")Month and year molded
UL Recognized Molder program
number, if applicable

In addition, for parts with metallic (EMI)coating, identify the applicator, the processused, and the metallic (EMI) coating materialused.
Acceptable
methods to provide
traceability to
Kodak

•
•

Related suppliersafetyexpectations

Parts will be produced under the UL
Recognized Fabricated Parts Program.

•

Molded on each part or"Stuffer sheet" containing the 6 items
above in the smallest shipping
container orLabel on every shipping container
stating the 6 items above.

•

Page 19 of 25•

For CSA approved labels,
place an identifier on eachlabel.
For UL approved labels,
place the identifier on eachlabel or smallest delivered
package.

EKSP-2285, Version 8.0
Appendix C – Packaging References
European Parliament and Council Directive 94/62/EC on Packaging and Packaging Waste(Amended by Directive (EU) 2018/852)
Further information can be obtained at: Summaries of EU legislation - EUR-Lex (europa.eu)
97/129/EC: Commission Decision of 28 January 1997 establishing the identification system for
packaging materials
Further information can be obtained at: Decision - 97/129 - EN - EUR-Lex (europa.eu)
Wood Packaging Materials
Approved treatment includes fumigation with methyl bromide or heat treatment (HT)—heated to acore temperature of 56 deg C (133 deg F) for 30 min. Kiln drying (KD) or chemical pressure
impregnation (CPI) may be considered heat treatment to the extent that these meet the heat
treatment specifications mentioned.
Treated solid wood packaging materials shall be marked with the International Plant Protection
Convention (IPPC) logo, the ISO two-letter country code followed by a unique number assigned by
the National Plant Protection Organization (NPPO) to the producer, and the IPPC approved
abbreviation for the phytosanitary treatment measure used (e.g., HT and MB).
Recycled, remanufactured or repaired wood packaging material should be re-certified and re-marked.
All components of such material should have been treated.
Further information may be obtained at: IPPC - International Plant Protection Convention
Korean Separate Discharge Mark
Further information can be found at: Korean Separate Discharge System

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EKSP-2285, Version 8.0
Appendix D – Instructions for Testing and Sampling Heavy Metals in Packaging
ChemicalTechniqueSpecification

Test Method*

Cadmium

Inductively coupled plasma

Less than 100 ppm total withPb, Hg, and Cr (VI)

6010

Lead

Inductively coupled plasma

Less than 100 ppm total withCd, Hg, and Cr (VI)

6010

Mercury

Cold Vapor Atomic Absorption Less than 100 ppm total with
Spectroscopy
Cd, Pb, and Cr (VI)7470, 7471

Chromium VI

Atomic Absorption
Spectroscopy

7190, 7195, 7196, 7197

Less than 100 ppm total with
Cd, Pb, and Hg* Test Method - The US EPA's SW 846 set of analytical methods for the determination ofchemical concentrations in wastes and other materials.

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EKSP-2285, Version 8.0
Appendix E – Definitions
Articles – Item/object which during production is given a special shape, surface or design
which determines its function to a greater degree than does its chemical composition andwhich have an end-use function in whole or in part dependent on their shape or design but
does not require alternating or direct electric current to operate. Examples of articles include
paper, bolts, cables, tape. Note: Batteries and components used to manufacture EEE shall beassessed and declared per the requirements for EEE specified in this document (seedefinition).
Chemicals – Products or raw materials made of organic or inorganic substances with adistinct molecular composition, which can be a solid, liquid, or gas. Chemicals may be
individual substances or mixtures. Examples of chemical products include surfactants,
pigments, solvents, polymers, etc. Chemicals can also include articles that act as containers
or carriers for chemicals such as alcohol cleaning wipes.
Conflict-affected and high-risk areas – Conflict-affected and high-risk areas are identified by
the presence of armed conflict, widespread violence, or other risks of harm to people. Armed
conflict may take a variety of forms, such as a conflict of international or non-international
character, which may involve two or more states, or may consist of wars of liberation, or
insurgencies, civil wars, etc. High-risk areas may include areas of political instability or
repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread
violence. Such areas are often characterized by widespread human rights abuses and violationsof national or international law.
Conflict Minerals – Conflict minerals (currently 3TG, also known as tantalum, tin, tungsten,gold, and their derivatives) as defined by US Securities and Exchange Commission Form SD
and Regulation (EU) 2017/821.
Due Diligence management system – Implementation of the five-step framework defined by
the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from ConflictAffected and High-Risk Areas (“OECD Guidance”)This includes establishing and maintaining
strong company management systems, establishing and maintaining a process to identify andassess risks in Kodak’s supply chain, responding to identified risks, audit smelters/refiners
sourcing activities, and publicly reporting on supply chain due diligence.
Electrical and Electronic Equipment (EEE) – All equipment that has at least one
intended function which is dependent on electric current or electromagnetic fields, or thatgenerates or transfers or measures such currents and fields. Finished EEE include
standalone printers, presses, plate setters, plate processors, scanners, work stations, andexternal power supplies. EEE also applies to components and parts that are formed to a
specific shape or design which are intended to be incorporated into an EEE and may or
may not have a power source. This includes, but is not limited to: sensors, hardware
components, printed circuit boards, batteries, cables, cords, mechanical andelectromechanical sub-assemblies and sub-components used to assemble equipment
products and/or systems.
Intentionally added – Deliberate use in the formulation of a product where its continued
presence is desired to provide a specific characteristic, appearance, or quality.

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EKSP-2285, Version 8.0
Known to be present – Supplier has knowledge that the material is present through existing
analytical information, second tier supplier declarations, or other methods.
Nanomaterials - Particles which are considered to be nanomaterials as described by U.S. EPA
TSCA (40 CFR 704) and/or meet the definition of nanomaterials according to the EU
Commission Recommendation on the definition of a nanomaterial (2022/C 229/01)
Recommendation on the definition of a nanomaterial (2022/C 229/01)’Nanomaterial’ means a natural, incidental or manufactured material consisting of solid
particles that are present, either on their own or as identifiable constituent particles inaggregates or agglomerates, and where 50 % or more of these particles in the numberbased size distribution fulfil at least one of the following conditions:(a), one or more external dimensions of the particle are in the size range 1 nm to 100 nm;(b), the particle has an elongated shape, such as a rod, fibre or tube, where two external
dimensions are smaller than 1 nm and the other dimension is larger than 100 nm;(c), the particle has a plate-like shape, where one external dimension is smaller than 1 nm
and the other dimensions are larger than 100 nm.
In the determination of the particle number-based size distribution, particles with at least
two orthogonal external dimensions larger than 100 μm need not be considered. However,a material with a specific surface area by volume of < 6 m2/cm3 shall not be considered ananomaterial.
US EPA Guidance on Nanomaterial Definition (40 CFR Part 704)
[Nanomaterials]... are solids at 25 °C and standard atmospheric pressure; that are
manufactured or processed in a form where any particles, including aggregates andagglomerates, are in the size range of 1-100 nanometers (nm) in at least one dimension;and that are manufactured or processed to exhibit one or more unique and novel
properties. This rule does not apply to chemical substances manufactured or processed informs that contain less than 1% by weight of any particles, including aggregates andagglomerates, in the size range of 1-100 nm. These parameters are for purposes ofidentifying chemical substances that are subject to the rule and do not establish adefinition of nanoscale material.
Packaging – Any material intended to be used for the containment, protection, handling,delivery and presentation of goods from raw materials to processed goods from the producer tothe user or consumer. Packaging may be classified as primary packaging, grouped or
secondary packaging, and transport or tertiary packaging. Examples of packaging include:
cartons, crates, pails, trays, bags, pallets, pallet collars, drums, load boards, skids, dunnage,interior or exterior blocking, bracing, cushioning, weatherproofing, exterior strapping, stretch
wrapping, coatings, closures, inks, adhesives, interleaving paper and labels.
Recycled Content – The concentration of materials that have been recovered or otherwise
diverted from the solid waste stream, either during the manufacturing process (pre-consumer) or
after the consumer use (post-consumer) and have been reused in the production of anotherproduct.
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EKSP-2285, Version 8.0
Reportable Application – Specific purpose of use that triggers the reporting requirement. Note:
This use is defined in the scope of the underlying law or industry standard. Examples include
batteries, textiles, wood, etc.
Rigid Plastic Packaging Container (RPPC) – Any plastic package having a relatively inflexible
finite shape or form that has a minimum capacity of eight fluid ounces (236.6 milliliters), or theequivalent volume, and a maximum capacity of five fluid gallons (18.9 liters), or the equivalent
volume, and is capable of maintaining its shape while holding other products. RPPCs include,
but are not limited to: bottles, cartons, pails, clamshells and other receptacles.
Threshold Level – Concentration level which defines the limit above which the presence of a
substance in a product shall be declared.

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EKSP-2285, Version 8.0
Appendix F – Revision History
Revision
8.0

SectionAll

ChangeDate

Major restructuring, formatting, 08/29/2024
and requirements update.

Page 25 of 25