RoHS_WEEE

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(No Transcript)
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The RoHS and WEEE DirectivesImpact onBuyers
and ManufacturesDesign for RoHS and WEEE
Compliance
Version October 2005
3
The Facts
4
The Facts

• About 90 of EEE is (was) incinerated or land
  filled
• The waste consist average of about 40 reusable
  steel iron
• About 15 reusable plastic
• About 10 reusable copper and aluminum
• About 0.007 precious metals (gold, palladium,
  silver ..)
• EU EEE waste 2005 estimated at around 9.5 Million
  tonnes

5
Overview

• Brief background on environmental legislation (go
  to page 5)
• Overview International WEEE RoHS regulations
  (go to page 17)
• Brief overview of WEEE directive (go to page 19)
  
• Brief overview of RoHS directive (go to page 76)
  
• Essential requirements for WEEE compliance (go to
  page 34)
• Essential requirements for RoHS compliance (go to
  page 87)
• Cost saving opportunities (go to page 59)

6
What's behind?
The 6th Community Environment Action Program
(Decision 1600/2002/EC adopted in July 2002
covers a period of 10 years)

• Scope of the program
• Tackling climate change
• Sustainable use and management of natural
  resources and waste
• Environment, health and quality of live
  (chemical)
• Nature and Biodiversity

7
Whats coming next?

• Directive 2005/32/EC of the European Parliament
  and of the Council of 6 July 2005 establishing a
  framework for the setting of Ecodesign
  requirements for Energy-Using Products and
  amending Council Directive 92/42/EEC and
  Directives 96/57/EC and 2000/55/EC of the
  European Parliament and of the Council
  Published in the OJ L191 of 22. July 2005
  The directive is also commonly called
  Eco-Design DirectiveNational implementation
  before 11. August 2007

8
Existing EU Legislations - Waste Management

• Directive 2002/96/EC of the European Parliament
  and of the Council of 27 January 2003 on waste
  electrical and electronic equipment (WEEE)
• Directive 2000/53/EC of the European Parliament
  and of the Council of 18 September2000 on end-of
  life vehicles
• Directive 94/62/EC of the European Parliament and
  Council of 20 December 1994 on Packaging and
  Packaging Waste.

9
Existing EU Legislations - Hazardous Chemicals
The "Limitations Directive" for Dangerous
Substances and Preparations

• Council Directive 76/769/EEC of 27 July 1976 on
  the approximation of the laws, regulations and
  administrative provisions of the Member States
  relating to restrictions on the marketing and use
  of certain dangerous substances and preparations
  and its amendments
• Amended 26 times (last 2003/53/EC)
• 12 Adaptations to technical progress (last
  2004/98/EC)
• Some amendments concern substances and
  preparations used in EEE

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Existing EU Legislations - Hazardous Chemicals
The "Limitations Directive" for Dangerous
Substances and Preparations - EEE

• Directive 2003/11/EC of the European Parliament
  and of the Council of 6 February 2003 amending
  for the 24th time Council Directive 76/769/EEC
  relating to restrictions on the marketing and use
  of certain dangerous substances and preparations
  (pentabromodiphenyl ether, octabromodiphenyl
  ether)
• Council Directive of 18 June 1991 amending for
  the 10th time Directive 76/769/EEC on the
  approximation of the laws, regulations and
  administrative provisions of the Member States
  relating to restrictions on the marketing and use
  of certain dangerous substances and preparations
  (91/338/EEC) (Cadmium Directive)

11
Existing EU Legislations - Hazardous Chemicals
The Marking Directive" for Dangerous Substances

• Council Directive 67/548/EEC of 27 June 1967 on
  the approximation of laws, regulations and
  administrative provisions relating to the
  classification, packaging and labelling of
  dangerous substances
• 9 amendments (last 1999/33/EC)
• 28 adaptations to technical progress (last
  2001/59/EC)
• The WEEE directive refers to this directive for
  definition of dangerous substance or preparation

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Existing EU Legislations - Hazardous Chemicals
The Marking Directive" for Dangerous
Preparations

• Directive 1999/45/EC of the European Parliament
  and of the Council of 31 May 1999 concerning the
  approximation of the laws and regulations and
  administrative provisions of the Member States
  relating to the classification, packaging and
  labelling of dangerous preparations
• The WEEE directive refers to this directive for
  definition of dangerous substance or preparation

13
Future EU Legislations - Hazardous Chemicals
The New Approach REACH

• REACH Registration Evaluation Authorization
  of Chemicals
• Need to provide risk assessment of new chemical
  before placed on market
• Tool to restricted new chemicals

Go to page 4
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Why should I care?
Press Consumer Enforcement Authorities

• The press is becoming more and more aware and
  pick up hazardous chemicals in consumer products
  (See the Sony Case) (See Germany Stiftung
  Warentest)
• Consumer care about their health and exposure to
  chemicals
• European Enforcement Authorities start to
  coordinate (RAPEX)

15
Why should I care?
The Sony Case

• Published Wednesday 5th December 2001 1151 GMT
• Dutch customs officers yesterday impounded 1.3
  million PlayStations and 800,000 accessory packs
  worth over 180 million Euro (160.25 million)
  after environmental protection inspectors
  discovered they were a potential threat to the
  environment. The PSOne consoles and packs were
  bundled with cables which the inspectors found to
  contain up to 20 times as much cadmium as is
  deemed safe. The heavy metal isn't immediately
  toxic, but if sufficient quantities build up in
  the body over time, it can lead to kidney damage.
  For this reason, European Union environmental
  protection regulations place strict limits on the
  amount of cadmium a product may contain - it
  should account for no more than 0.01 per cent of
  the product's composition. When products are
  thrown away, the metal may leak out and into the
  environment, potentially entering the food chain.
  Sony said in a statement that it will replace the
  impounded cables with cadmium-free components.
  That will allow it to begin limited shipments of
  PSOnes by the middle of December. However, the
  company said it will not replace
  cadmium-containing cables that have already been
  sold to consumers. Nor will it cease to ship such
  parts to countries with less stringent
  environmental protection laws.Sony would not say
  how much this will cost the company, in terms up
  either up-front expenditure or lost pre-Christmas
  sales.

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Why should I care?

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Why should I care?
http//europa.eu.int/comm/dgs/health_consumer/dyna
/rapex/create_rapex.cfm?rx_id30
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Global WEEE Regulations
USA
State of California
Australia

• Countries with take back regulation in place or
  as draft

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Global Regulations restriction on hazardous
substances
USA
State of California
Australia

• Countries with regulations on hazardous substances

Go to page 4
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Product Life Cycle
RoHS Directive
WEEE Directive
21
WEEE Resource Stream
End-of life management
WEEE regulated area
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Scope of WEEE Directive

• Applies to electrical and electronic equipment
  listed in annex IA and designed for use with
  voltage rating not exceeding 1000 VAC or 1500
  VDC
• Is directed to producers of electrical and
  electronic equipment
• Is addressed to member states and local
  authorities thereof

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What is a Producer?

• Producer means any person who, irrespective of
  the selling technique used, including by means of
  distance communication 1) manufactures and
  sells electrical and electronic equipment under
  his own brand,
• 2) resells under his own brand equipment
  produced by other suppliers, a reseller not
  being regarded as the producer if the brand of
  the producer appears on the equipment, as
  provided for above
• 3) imports or exports electrical and electronic
  equipment on a professional basis into a Member
  State.

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Product Categories of EEE Waste

• Category 1 Large Household Appliances
• Category 2 Small Household Appliances
• Category 3 IT and Telecommunications Equipment
• Category 4 Consumer Equipment
• Category 5 Lighting Equipment
• Category 6 Electrical and Electronic Tools
• Category 7 Toys, Leisure and Sports Equipment
• Category 8 Medical Devices (not implanted and
  infected devices)
• Category 9 Monitoring and Control Instruments
• Category 10 Automatic Dispenser

Mainly B2C
Mainly B2B
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The key provisions of the WEEE Directive

• Product Design (Article 4)
• Separate Collection (Article 5)
• Treatment of WEEE (Article 6)
• Recovery and recycling (Article 7)
• Financing WEEE from private household (Article 8)
• Financing WEEE from others (Article 9)
• Information for user (Article 10)
• Information for treatment facilities (Article 11)
• Information and reporting to authorities (Article
  12)

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WEEE Implementation Germany
Manufacturer

National Register
Collection points by local authorities
Coordination Body
Pays to recycler
Collection Point Shops(voluntarily)
RetailerImporter
Recycler
27
Recovery and Recycling Targets (Article 7)
to be achieved by 31. December 2006
1) For gas discharge lamps 80
Responsibility of the producers or third parties
acting on their behalf (e.g. recycler)
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Waste Management Hierarchy
Best

Worst

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Example for a category 1 appliance

• Dishwasher Weight 100 kg (Category 1)Recovery
  Target 80 by weight Reuse / Recycling
  Target 75 by weight
• Conclusion Recovery of material and
  components minimum 80 kg Back into resource
  stream minimum 75 kg
• Energy recovery by incineration max. 5 kg
• Disposal as Landfill max. 20 kg

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Information and Reporting (Article 12)

• Producers shall register in a National register
• Producers report at least on annual basis the
  quantities and categories of EEE put on the
  market
• Producers report at least on annual basis the
  quantities and categories of EEE collected,
  reused, recovered, recycled and exported by
  weight or numbers
• Responsibility Producer

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Annex II of WEEE Directive

• Hazardous Materials to be removed from the
  equipment before further treatment according to
  Annex II of WEEE directive

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Annex II of WEEE Directive

• The following materials, substances, components
  must be removed from the product by the treatment
  facilities (information is to be provided by
  manufacturer)- PCB (polychlorinated biphenyls)
  containing capacitors- Mercury containing
  components- Plastic containing brominated flame
  retardants- Components which contain asbestos
  and asbestos waste- Printed circuit boards of
  mobile phones
• - Printed circuit board of devices where the
  surface is greater than 10 square centimeter-
  Toner cartridges, liquid and pasty as well as
  colour toner- batteries- Cathode ray tubes
  (CRT)- Gas discharge lamps- External electric
  cables- Chlorofluorocarbons (CFC),
  hydrochlorofluoro- carbons (HCFC) or
  hydrofluorocarbons (HFC), hydrocarbons (HC)-
  liquid crystal displays (together with their
  casing where appropriate) of a surface greater
  than 100 square centimetres and all those
  back-lighted with gas discharge lamps-
  Electrolyte capacitors containing substances of
  concern (height gt 25 mm, diameter gt 25 mm or
  proportionately similar volume)

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• Waste Stream during Recycling

Raw material producers
Raw material producers
Reuse
Manual Dismantling and Sorting
Ferrous
Metal
Non Ferrous
Recycling
Aluminum
Smelter
ABS
Grinder
Plastic
PC
Recyclable Materials
PE
Landfill
Energy recovery
Hazardous Parts
Shredder
Automatic Separation
Special Treatment
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WEEE Schedule
13. February 2003 Entry into force 13. August
2004 National law into force 14. August 2005 EEE
must comply with directive 31. December 2006
Producer must meet recovery and recycling
target 31. December 2006 Members states must
achieve separate collection target

Go to page 4
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Essential requirements for WEEE compliance

• Essential requirements for importers/buyers
• Essential requirements for manufactures

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Importers (Buyers)

• What have importer and buyers to do in EU?
• What are B2C products?
• What are B2B products?
• What should importers/buyers ask their suppliers
  with regard to WEEE?

37
Importers (Buyers)

• Register in national register (B2B and B2C) e.g.
  Germany
• For B2C provide insolvency guarantee for
  registration
• Make sure imported products are marked acc. EN
  50419
• Have the information available as outlined in
  article 11 (treatment information)
• Report on monthly basis goods placed on the
  market to compliance scheme
• Be aware of the national implementation which may
  differ from EU WEEE text (e.g. Germany Gesetz
  über das Inverkehrbringen, die Rücknahme und die
  umweltverträgliche Entsorgung von Elektro- und
  Elektronikgeräten (Elektro- und
  Elektronikgerätegesetz ElektroG)

http//www.stiftung-ear.de/
38
Importers (Buyers)

• Ask your supplier to but WEEE label on product
• Ask your supplier to provide declaration,
  testreport or certificate for WEEE compliance
  (Nemko provides WEEE assessment services)
• Ask your supplier to provided WEEE documentation
• Ask your supplier to mark all plastic material
  according to ISO 11469

39
Importers (Buyers)

• Ask your supplier to identify all hazardous
  materials in the product especially plastic
  containing brominated flame retardants
  (better-ask your supplier not to use at all any
  plastic containing those substances)
• Make sure the products you buy facilitate
  recycling (e.g. ease of dismantling) and reuse
  (have some green design requirements in place)
• Use high recyclability of the products as sales
  point

40
What I need to do for my Product (Design)?

• Product design
• Labeling of product
• Information to user
• Marking of parts and components
• Documentation

Jump to RoHS
41
Requirements for manufacturer
Article 4 Product Design

• Manufacturer shall design and produce electrical
  and electronic equipment which take into account
  and facilitate dismantling and recovery, in
  particular the reuse and recycling of WEEE, their
  components and materials.

42
Marking of Products
Article 10 Information for User
WEEE Marking

• The products must be labeled with

Registered trademark
Marking the product according to EN
504192005Marking must include
Knoxville
- A unique identification of producer (e.g.
brand name, trade mark or other means
- Date or year of manufacture/placed on the
market in coded or un-coded text or
050813
marking as above with the crossed-outwheeled
bin and additional bar
Date placed on the market
43
Marking of Products
A complete Marking
ABC Co., Ltd.
Model XYZ-1
Rated input 100-240V 1A, 47-63Hz
Rated output 12V 5A
Made in China

Knoxville
Model XYZ-1
Rated input 100-240V 1A, 47-63Hz
Rated output 12V 5A
Made in China
44
Marking of Products
Article 10 Information for User
WEEE Marking

• The WEEE Marking .

Shall indicate that product is placed on the
market after August 13. 2005 Shall facilitate
separate collection (minimizing disposal of WEEE
as unsorted municipal waste) information to user
about meaning must be provided in user manual
Does not indicate that waste collection and
treatment is financed Does not indicate
compliance with WEEE directive
Registered trademark
Knoxville
45
Treatment Information
Article 11 Information for Treatment Facilities

• In order to facilitate the reuse and the correct
  and environmentally sound treatment of WEEE,
  information for each type of new EEE put on the
  market has to be provided.This information shall
  identify, as far as it is needed by reuse
  centers, treatment and recycling facilities in
  order to comply with the provisions of this
  Directive, the different EEE components and
  materials, as well as the location of dangerous
  substances and preparations in EEE. (for
  dangerous substance and preparations refer to the
  directives 1999/45/EC and 67/548/EC)

46
Treatment Information
Article 11 Information for Treatment Facilities

• All treatment information can either be provided
  in the form of markings on the parts of the
  product
• Or in the form of documentation (e.g. Recycling
  description) The form chosen depends on the
  complexity of the product

47
Marking of Parts
Plastic and Rubber parts

• ISO 1629 provides coding for marking of rubbers
  e.g. NR (for natural rubber)
• ISO 11469 provides coding for plastic materials
  e.g. gtPA66ABS (GF25MD15)FR(52)lt ( plastic
  blend with 25 glass fiber reinforced and 15
  mineral powder as filling material and red
  phosphorous as flame retardant)

48
Marking of Parts
Marking Plastic enclosure example
49
Marking of Parts
Marking of Printed Circuit Boards

• For marking of printed circuit boards and printed
  circuit board assemblies two standards are
  available
• IPC-1066/JESD97 January 2005 (USA) Marking,
  Symbols and Labels for Identification of
  Lead-Free and Other Reportable Materials in
  Lead-Free Assemblies Components and Devices
• Jeita ETR-7021 Draft 2004.08 (Japan)Guidance
  for the Lead-Free Marking of Materials,
  Components and Mounted Boards used in Electronic
  and Electric Equipment

50
Marking of Parts
Marking of Printed Circuit Boards

• IPC-1066/JESD97
• Indicating PC board lead free incl.
  Components indicating category of solder
  used e.g. e1 SnAgCu solder

e1
51
Marking of Parts
Marking of Printed Circuit Boards

• Examples

52
Marking of Parts
Marking of Material and Components

• Marking standards for Materials and Components
• IPC-1066/JESD97 January 2005 (USA) Marking,
  Symbols and Labels for Identification of
  Lead-Free and Other Reportable Materials in
  Lead-Free Assemblies Components and Devices
• JEITA ET7001 The marking for the presence and
  non presence of the specified chemical substances
  in materials, components and printed circuit
  boards used in electrical and electronic
  equipment

53
Marking of Parts
Marking of Material and Components

• Marking standards for Materials and Components
• JEITA ET7001 If a hazardous substances is
  present in a material or component then the part
  shall be marked with the substance included e.g.
  below marking on LCD module Indicates
  that the parts contains lead (Pb) and mercury
  (Hg)

54

Example of complete Information according to
Article 11 (AGFA)

55

Example of complete Information according to
Article 11 (AGFA)

56
Examples of Treatment Information

57
Examples of Treatment Information

58

Examples of Treatment Information

59
WEEE Schedule
13. February 2003 Entry into force 13. August
2004 National law into force 14. August 2005 EEE
must comply with directive 31. December 2006
Producer must meet recovery and recycling
target 31. December 2006 Members states must
achieve separate collection target

60
Design for WEEE RoHS Compliance and Cost
Savings

61

Contents

• Typical Material Content of Electrical and
  Electronic products
• Design Support Recycling
• Design for Disassembly

62
Austrian Take Back System by ERA

• Producer have to declare on quarterly or monthly
  basis and pay the recycling contribution based on
  the fixed fee.

63
Belgium Product Take Back Scheme

• Manufacturer have to declare monthly or three
  monthly about imported good in addition an annual
  declaration must be submitted
• Recycling contribution is to be paid 30 days
  after the products has been declared (usually at
  the the time VAT becomes payable)

64
Example Recupel Belgium, El-Retour Sweden and ERA
Austria
What recycling cost can manufacturer and importer
expect from WEEE?
65
Example Recupel Belgium, El-Retour Sweden and ERA
Austria
What recycling cost can manufacturer and importer
expect from WEEE?
66
Typical Material Content of WEEE
Example CRT Monitor total weight 12.8 kg
67
Typical Material Content of WEEE
Example LCD Monitor total weight 5.1 kg
68
Typical Material Content of WEEE
Example Vacuum Cleaner total weight 7.5 Kg
69
Average Market Prices for Recycled Materials
Prices in US as of 19.4.2005 ) Mixed scrap
iron/steel Price LME for virgin material Price
recycled material www.metalworld.com Plastic
www.plasticsnews.com
70
How to increase the End-of Life-Value of your
Product?

• Reduce disassembly time (e.g. reduces cost for
  disassembly and assembly)
• Eliminate toxic substances(e.g. hazardous
  chemicals are removed e.g. brominated flame
  retardants)
• Reduce material variety (e.g. no mixed plastic
  materials)

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Disassembly

• Standard Disassembly times

• Reduce the number of joints
• Use snap fit fasteners screws glue solder
• Use only one type of screw head
• Minimize the number of screws
• Make the screws easily accessible
• Eliminate the need to access the product form
  different sides

72
Toxic Substances
Hazardous substances

• Eliminated brominated flame retardants (BFR)
• Antimony as FR
• Arsenic in semiconductors and FR
• Bismuth in solder
• Beryllium in Cu Be alloys up to 2

73
Material Variety
Incompatible Materials

• Avoid Composite Material (e.g. Plastic glass
  fiber reinforced, or plastic blends)
• Avoid Painting and coating
• Avoid stickers and adhesive on plastic
• Avoid material with toxic substances
• Use plastic screws for plastic and metal screws
  for metal

74
ESSENTIAL REQUIREMENTS

• WEEE Labelling
• Documentation
• Component and parts labelling e.g. plastic
• Design for Dismantling
• Design for Recycling
• Life Cycle Design ?

75
Nemko Services

• WEEE Compliance Assessment
• Calculation of recovery and recycling rate
• Product design
• WEEE Certification
• RoHS testing of components and materials
• RoHS verification of products
• RoHS certification
• RoHS consulting
• Eco Design support and consulting

76
Nemko Contacts

• ??/HongKong ??/Shenzhen
• ??(Add.) ??????????8? ??(Add.) ???????32?15-17?
  
• ??????1?3-5? Rm.3215-17, International Trade
• Unit 3-5,1/F., Festigood Centre, No.8 Lok
  Centre Building, Shenzhen, China
• Yip Road, On Lok Tsuen, Fanling, Hong Kong
  ??(P.C.) 518001
• ??(Tel.) 852 2675 0288 ??(Tel.) 86 755
  8221 0006
• ??(Fax) 852 2675 0550 ??(Fax) 86 755 8221
  3363
• ??(E-mail) martha.pang_at_nemko.com ??(E-mail)
  yong.beom.choi_at_nemko.com
• ??/Shanghai ??/Guangzhou
• ??(Add.) ???????????????? ??(Add.) ???????498?
• ????139???????1406? ????????11G
• Rm.1406, HuaNeng Union Tower, 139 Yincheng
  Rm.11G, Boli Plaza Trade Centre, Guangfa
• Rd.(East), LuJiaZui Finance Trade
  Zone, Huayuan, No.498 Huanshi East Road,
• PuDong New Area, Shanghai City, China Dongshan
  District, Guangzhou, China
• ??(P.C.) 200120 ??(P.C.) 510175
• ??(Tel.) 86 6886 4637 ??(Tel.) 86 20 8760
  6422
• ??(Fax) 86 5840 2421 ??(Fax) 86 20 8760
  6095
• ??(E-mail) shirlin.wang_at_nemko.com ??(E-mail)
  steven.yang_at_nemko.com

77
ROHS Directive
Go to page 78

• RoHS directive
• Typical application of restricted substances
• Testing and testing methods
• Hazardous substance standardization
• How to approach RoHS compliance

Go to page 92
Go to page 107
Go to page 113
Go to page 122
78
ROHS Directive

• Directive 2002/95/EC of the European Parliament
  and of the council of January 2003 on the
  restriction of the use of certain hazardous
  substances in electrical and electronic equipment

79
Scope of RoHS Directive

• From 1. July 2006 new electrical and electronic
  equipment put on the European market shall not
  contain (Article 4)
• Lead (Pb)
• Mercury (Hg)
• Cadmium (Cd)
• Hexavalent chromium (CrVI)
• Polyprominated biphenyls (PBB)
• Polybrominated diphenyl ether (PBDE)

80
Scope of RoHS Directive

• Large Household Appliances
• Small Household Appliances
• IT and Telecommunications Equipment
• Consumer Equipment
• Lighting Equipment
• Electrical and Electronic Tools
• Toys, Leisure and Sports Equipment
• Medical Devices (not implanted and infected
  devices) (after 2008)
• Monitoring and Control Instruments (after 2008)
• Automatic Dispenser

81
Maximum Concentration Value (MCV) - Limits

• Commission Decision (2005/618/EC) of 18 August
  2005

For the purposes of Article 5(1)(a), a maximum
concentration value of 0,1 by weight in
homogeneous materials for lead, mercury,
hexavalent chromium, polybrominated biphenyls
(PBB) and polybrominated diphenyl ethers (PBDE)
and of 0,01 by weight in homogeneous materials
for cadmium shall be tolerated.
82
Definition of Homogenous Material

Homogeneous material means a material that
cannot be mechanically disjointed into different
materials.
The term homogeneous is understood as "of
uniform composition throughout", so examples of
"homogeneous materials" would be individual types
of plastics, ceramics, glass, metals, alloys,
paper, board, resins and coatings. The term
mechanically disjointed means that the
materials can be, in principle, separated by
mechanical actions such as unscrewing, cutting,
crushing, grinding and abrasive processes.
83
Definition Homogenous Material Capacitor

Lead / Tin SolderCoating
Metal film (2) consisting two layers
Sn/Pb solder joint
Plastic Enclosure

Cu Lead wire with Sn/Pb coating
84
Exemptions

• ANNEX to RoHS Directive - Applications of lead,
  mercury, cadmium and hexavalent chromium, which
  are exempted from the requirements of Article
  41. Mercury in compact fluorescent lamps not
  exceeding 5 mg per lamp.2. Mercury in straight
  fluorescent lamps for general purposes not
  exceeding halophosphate 10 mg triphosphate
  with normal lifetime 5 mg triphosphate with
  long lifetime 8 mg.
• 3. Mercury in straight fluorescent lamps for
  special purposes.4. Mercury in other lamps not
  specifically mentioned in this Annex.5. Lead in
  glass of cathode ray tubes, electronic components
  and fluorescent tubes.6. Lead as an alloying
  element in steel containing up to 0,35 lead by
  weight, aluminum containing up to 0,4
  lead by weight and as a copper alloy containing
  up to 4 lead by weight. (Copper wire)
• 7. Lead in high melting temperature type solders
  (i.e. tin-lead solder alloys containing more than
  85 lead), lead in solders for servers,
  storage and storage array systems (exemption
  granted until 2010), lead in solders for
  network infrastructure equipment for switching,
  signaling, transmission as well as network
  management for telecommunication, lead in
  electronic ceramic parts (e.g. piezoelectronic
  devices).

85
Exemptions

• ANNEX to RoHS Directive (II)8. Cadmium plating
  except for applications banned under Directive
  91/338/EEC (1) amending Directive 76/769/EEC
  relating to restrictions on the marketing and use
  of certain dangerous substances and
  preparations.9. Hexavalent chromium as an
  anti-corrosion of the carbon steel cooling system
  in absorption refrigerators.10. Within the
  procedure referred to in Article 7(2), the
  Commission shall evaluate the applications for
  Deca BDE, mercury in straight
  fluorescent lamps for special purposes

86
Exemptions

• Proposed exemptions to Amendment ANNEX to RoHS
  Directive July 2004 (III) Lead used in
  compliant-pin VHDM (Very High Density Medium)
  connector system Lead as a coating material
  for a thermal conduction module c-ring Lead
  and cadmium in optical and filter glass Lead
  in optical transceivers for industrial
  applications Lead in solders consisting of
  more than two elements for the connection between
  the pins and the package of microprocessors with
  a lead content of more than 85 in proportion to
  the tin-lead content (exemption until 2010)
  Lead in high melting temperature type solders
  (i.e. tin-lead solder alloys containing more than
  85 lead) and any lower melting temperature
  solder required to be used with high melting
  temperature solder to complete a viable
  electrical connection
• Lead in high melting temperature type solders
  (i.e. tin-lead solder alloys containing more than
  85 lead) and any lower melting temperature
  solder required to be used with high melting
  temperature solder to complete a viable
  electrical connection Lead in solders to
  complete a viable electrical connection internal
  to certain Integrated Circuit Packages (Flip
  Chips) (exemption until 2010) Article 4(1)
  substances in safety equipment for fire and
  rescue services. Lead in lead-bronze
  bearing-shells and bushes

87
Exemptions

• 22 Exemption applications submitted by the
  industryLatest update for submitted exemptions
  can be found
• http//www.europa.eu.int/comm/environment/waste/we
  ee_index.htm

Go to page 76
88
Essential requirements for RoHS compliance

• Essential requirements for importers/buyers
• Essential requirements for manufacturers

Go to page 4
89
Importers (Buyers)

• Ensure the products does not contain any of the
  restricted substances
• Have a technical documentation - showing
  compliance - available for the authorities (this
  documentation is provided by the manufacturer or
  third party certification bodies like Nemko)
• Be aware that products should effectively be
  manufactured RoHS compliant latest in January
  2006

90
Importers (Buyers)

• Provide your supplier with clear specification
  (e.g. RoHS compliant parts to be used only)
• Ask your supplier to provide evidence in form of
  third party certificate, test report or
  assessment report ( A signed declaration from the
  supplier can be acceptable as well if trusted
  supplier)
• Have some products of the production lot
  inspected before shipment (e.g. screening with
  X-Ray) this action is strongly suggested during
  the period January 2006 to August 2007.

91
Importers (Buyers)

• Have a environmental statement ready for your
  customer (e.g. list of not used hazardous
  substances)
• Consider also to ban other hazardous substances
  from your product (e.g. brominated flame
  retardants)

92
Manufacturer

• Ensure to use RoHS compliant parts only (e.g.
  lead free solder)
• Establish technical documentation file (TCF)
  consisting declarations, test reports,
  certificates, incoming inspection results,
  supplier audits etc. of parts used in the
  product
• Apply for 3rd party RoHS certification
• Make sure to use only RoHS compliant parts
  starting January 2006

93
Application of hazardous substances


Application of banned and restricted substances
in electrical and electronic components
94
Banned Substances
Lead and its Compounds

Application and Use
95
Banned Substances

Lead and its Compounds
Lead Free Soldering
96
Banned Substances
Cadmium and its Compounds
Application and Use

97
Banned Substances

Cadmium and its Compounds

Application and Use
98
Banned Substances
Hexavalent Chromium (CrVI, Cr6)

Application and Use
99
Banned Substances
Mercury and its Compounds

Application and Use
100
Banned Substances
Brominated Flame Retardants (BFR)

• Brominated Flame Retardants (BFR)are used
  where fire safety is required, typically all
  printed circuit boards and plastic enclosures,
  rated with V-1 or V-0 according to UL94 do
  contain flame retardants. Flame retardants are
  also used in wires and cables

101
Banned Substances
PBB and its Compounds

Application and Use

• Flame retardant mainly for ABS

• Production of PBB ceased in the USA in 1976 and
  in Europe in 2001. No information about other
  countries available. PBB is not expected to be
  used anymore in products manufactured after 2001

102
Banned Substances
PBDE and its Compounds

Application and Use

• Flame retardant in ABS, PC etc.
• Flame retardant in printed circuit board

• Pentabromodiphenyl ether (PeBDE) and
  octabromodiphenyl ether (Octa-BDE) are banned
  under the directive 2003/11/EC.
• Decabromodiphenyl ether (Deca-BDE) is exempted by
  Commission Decision 2005/717/EC from 15. October
  2005 at least until 2010

103
Banned Substances
PBDE and its Compounds

Application and Use

• Flame retardant in ABS, PC, etc.
• Flame retardant in printed circuit board

TPBE Tribromophenoy ethane, TBBPA
TetrabromobisphenolA, - RDP Resorcinol bis
diphenyl phosphate, - BPADP Bisphenol A
diphosphate TPP Triphenyl phosphate, - TBBE
Tetrabromobenzoate ester
104
Banned Substances
PBDE and its Compounds

Market Share of Flame Retardants

HBCD Hexabromocyclododecaneused in automotive
sector and building material
Go to page 76
Source BSEF 2001
105
Banned Substances
Flame Retardants

How to check if flame retardants are in and
which type?

• If you have the plastic material from a resin
  manufacturer (e.g. BASF, GE, etc) you can get the
  information from them.
• If you have your material from a compounder then
  it maybe more difficult to find out, just ask the
  supplier for this information or ask for a test
  report.
• There are two ways to incorporate FR, if FRs are
  mixed together with the resin then they are
  called additive FRs (usually by compounding) if
  they are inserted into the chemical structure
  then they are called reactive FRs.

106
Banned Substances
Flame Retardants

• More information about flame retardants

107
RoHS Testing
Graphite Furnace AAS ??????????
EDX ?????X????????
Flame Furnace AAS ?????????
ICP-AES ????????????
ICP-MS ??????????
108
RoHS Testing

• IEC Draft Standard IEC 62321 (111/24/CD)
• Title
• Procedures for the Determination of Level of
  Regulated Substances in Electrotechnical Products
• Latest Draft Version published 24.06.2005

109
RoHS Testing (Excerpt from IEC Draft Standard)


110
RoHS Testing

• Screening

• Non destructive testing with EDX (energy
  dispersive X-ray fluorescence spectrometer or
  similarLimitations on detecting substances in
  the range of several ppmVery fast result -
  typical 30 seconds

111
RoHS Testing

• Chemical Analysis

• Destructive Testing

112
RoHS Testing

• Destructive Testing

ICP-AES Inductively Coupled Plasma Atomic
Emission SpectrometryAAS Atomics Absorption
SpectrometerHRGCMS High Resolution Gas
Chromatography/Mass Spectrometer 1) as per
commission decision 2005/618/EC from
19.8.2005 2) JIG 101 limits by Electronic
Industry Alliance (US), EICTA (Europe) and JGSSI
(Japan) Concentration values x (ppm or wt) by
weight in homogenous material. Homogenous
material means a unit that can not be
mechanically disjointed in single materials.
113
RoHS Testing and Certification
Equipment testing and certification
Bill of material
Non Critical Parts
Critical Parts

RoHS certificates available
Material declaration available
No
Yes
Self declaration
3rd party
Select samples for test
Use EDX for verification
Yes
Substance detected ?
After 1 year re-issue certificate with FI or new
assessment
Use AAS ICP - HRGCMS
No
Below limits
Reject
Prepare RoHS assessment report Issue RoHS
certificate valid one year
Yes
Go to page 76
114

Are there standardization approaches or
guidelines for hazardous materials and
substances?
115
Hazardous Substances Global Standards and
Regulations

• European Directive on restriction of hazardous
  substances in electrical and electronic Equipment
  (2002/95/EC) effective 1. July 2006
• Joint Industry Guide JIG 101 (EIA, EICTA, JGPSSI)
  Material Declaration Guide with restricted and
  banned substances
• Guidance Document on the Appliance of Substances
  under Special Attention in Electric Electronic
  Products (CEFIC - EECA - EICTA EUROMETAUX)
• California proposition 65
• California Electronic Waste Recycling Act of 2003
  (SB 20) effective 1. January 2007
• Japan Chemical Control Act
• Japan Green Procurement Survey Standardization
  Initiative (JGPSSI)
• Draft - Management Methods for the Prevention and
  Control of Pollutants from Production of
  Electronic Information Products 2003 (China)

116
Hazardous Substances Global Standards and
Regulations

• Joint Industry Guide JIG 101 (EIA, EICTA, JGPSSI)
  Material Composition Declaration Guide with
  restricted, banned and reportable substances

Reference http//www.eia.org
117
Joint Industry Guide JIG 101 Material
Composition Declaration Guide with restricted,
banned and reportable substances
Level A substances materials are subjected to
current legislation that a) Prohibit their use
and or marketingb) Restricts their use and or
marketingc) Requires reporting or results in
other regulatory effects

Level B substances materials that the industry
has determined relevant for disclosure because
they meet one or more of the following
criteria a) Precious materials/substances that
provide economic value for end-of-life
management purposes (E)b) Materials/substances
that are of significant environmental, health, or
safety interest (E,H)c) Materials/substances
that would trigger hazardous waste management
requirements (E,H,R)d) Materials/substances
that could have a negative impact on end-of-life
management. (R)
118
Joint Industry Guide JIG 101 Material
Composition Declaration Guide with restricted,
banned and reportable substances
Level A materials and substances (Banned
substances)

• Lead (Pb)
• Cadmium (Cd)
• Mercury (Hg)
• Hexavalent Chromium (Cr VI)
• Polybrominated biphenyl (PBB)
• Polybrominated biphenyl ether (PBDE)
• Asbestos
• Azo colorants
• Ozone depleting substances (CFC, HCFC, HBFC)
• Polychlorinated Biphenyls (PCB)
• Polychlorinated Naphthalene's
• Short chain Chlorinated Paraffins
• Tributyl Tin (TBT) and Triphenyl Tin (TPT)
• Tributyl Tin Oxide (TBTO)

119
Joint Industry Guide JIG 101 Material
Composition Declaration Guide with restricted,
banned and reportable substances
Level B materials and substances (Restricted and
reportable substances)

• Antimony (E,H)
• Arsenic (E,H)
• Beryllium (R)
• Bismuth (R)
• Copper (E)
• Gold (E)
• Magnesium (E)
• Nickel (E,H)
• Palladium (E)
• Selenium (E,H)
• Silver (E)
• Phthalates (E,H)
• Vinyl Chloride Polymer (PVC) (E,H)
• Brominated flame retardants) (E,R)

120
Standards for hazardous materials and substances
declaration

• Summary Forms of Declaration Compliance
  Declaration RoHS compliance declaration
  simplest form- no information about
  material or substance content
• Extended Compliance Declaration Based on list
  of regulated and or substances of concern,
  economic value substances e.g. Joint
  Industry Guide
• 100 Material Declaration 100 declaration of
  all materials and substances used. E.g.
  based on ZVEI umbrella specification

121
Standards for hazardous materials and substances
declaration
Material / Component / Product Content
Raw Material Suppliers
Assembly/Component Manufacturer
Part Manufacturer
Manufacturer

Material Declaration
Part Declaration
Component Declaration
Choose most suitable form of declaration
Product Declaration
122
Standards for hazardous materials and substances
declaration

Material / Component / Product Content
Simple Components e.g. screws, contact points,
RoHS Compliance Declaration
Complex Components e.g. Switch, relays, etc.
Extended Compliance Declaration
Assemblies Critical Components e.g. Populated
printed circuit boards, Product, semiconductors
etc.
Full Material Declaration
Go to page 76
123
Challenge to Manfacturer on how manage hazardous
substances and materials

• Manufacturer faces multiple questions and
  challenges
• - What other substances beside lead (Pb),
  cadmium (Cd), mercury (Hg), hexavalent
  chromium (CrVI), PBB and PBDE? - How to
  evaluate compliance of parts and components-
  Always testing needed?- When is testing needed?
  - How to get information about substances?- How
  to trace materials and substances inside the
  product?- What kind of information needed from
  suppliers?- How to judge/evaluate
  information/report provided by suppliers?- How
  to control cost for compliance with RoHSWEEE?

124
Compliance Enforcement by Authorities

• Authorities

Presumption of Compliancewhen placed on market
Self declaration by producer on request by
authorities
Technical Documentation consisting of supplier
declaration material declaration or Description
of Quality Assurance System
Assessment of declarationby authorities
Authorities assess provided documentation and may
ask for additional documents (e.g. reports, etc.)
Verification through testing by authorities in
case of concerns
If authorities have concern testing based on IEC
standard will be performed
Authorities
125
Compliance Approach by Manufacturer
Place Product on the Market
Compliance Approach based on technical
documentation consisting of Material
declarations provided by - Raw material
supplier- Component supplier- Assembly supplier
Test reports and certificates provided by -
Raw material supplier- Component supplier-
Assembly supplier
Compliance Approach based on Quality Assurance
System consisting ofProcess descriptionSupplie
rs auditIncoming inspection process
Producer Declaration of conformity
Assembly Supplier DoC
Component Supplier DoC Component material
Declaration
Raw Material Supplier DoC Material declaration

126
How to manage suppliers and parts?
127
How to manage suppliers and parts?

• Establish supplier management program
• Ask all suppliers to provide RoHS statement (e.g.
  declaration, testreport or certificate)
• Establish procedures for incoming inspection of
  critical parts (test can be performed with e.g.
  X-ray screening)

128
How to manage suppliers and parts?

• Phase 1 Classify parts
• Phase 2 Conduct supplier survey
• Phase 3 Evaluate supplier feedback
• Phase 4 Reclassify parts if needed
• Phase 5 Classify supplier based on experience of
  feedback
• Phase 6 Define compliance criteria and
  purchasing specification for parts based on
  feedback and classification of parts
• Phase 7 Prepare supplier audits (supplier self
  audit or third party audit)
• Phase 8 Re-classify suppliers
• Phase 9 Establish final purchasing and
  inspection specification and requirements
• Phase 10 Apply procedures and monitor

129
How to manage suppliers and parts?

• Classify materials, components, parts and
  assemblies Classification Level A RoHS
  substances very likely to be containedClassifica
  tion Level B RoHS substances likely to be
  contained Classification Level C RoHS
  substances not likely to contained

• ExamplesClassification Level A Power Cord
  Lead (Pb) very likely to be contained
  Classification Level B Power Cord Cadmium
  (Cd) likely to be containedClassification Level
  C Zinc plated screws all substances unlikely
  to be contained

130
How to manage suppliers and parts

• Required evidence for parts from supplier -
  Supplier Survey Classification Level
  A Extended Declaration Test report
  Classification Level B RoHS Declaration
  Testreport Classification Level C Extended
  Declaration - Full Material Declaration All
  suppliers have to provide self audit report

• Examples Classification Level A Power
  Cords, UL94V-0/1 rated plasticClassification
  Level B Bare Printed Circuit BoardClassificati
  on Level C Screws, springs,

131
How to manage suppliers and parts

• Classify Suppliers based on Survey
  Classification Level A Preferred Supplier -
  very trustworthy ISO 14001 Classification
  Level B Acceptable Supplier - somewhat
  trustworthy - Classification Level C New
  SupplierClassification Level D Not trustworthy
  but only supplier

• Requirements for SuppliersLevel A suppliers
  Suppliers declaration sufficient Level B
  suppliers Suppliers declaration test report
  for every lot Level C supplier Suppliers
  declaration test report for every lotLevel D
  supplier Suppliers declaration test report for
  every lot 100 inspection

132
Nemko Services

• RoHS testing of components and materials
• RoHS verification of products
• RoHS certification
• RoHS consulting
• Eco Design support and consulting

133
Nemko Contacts

• ??/HongKong ??/Shenzhen
• ??(Add.) ??????????8? ??(Add.) ???????32?15-17?
  
• ??????1?3-5? Rm.3215-17, International Trade
• Unit 3-5,1/F., Festigood Centre, No.8 Lok
  Centre Building, Shenzhen, China
• Yip Road, On Lok Tsuen, Fanling, Hong Kong
  ??(P.C.) 518001
• ??(Tel.) 852 2675 0288 ??(Tel.) 86 755
  8221 0006
• ??(Fax) 852 2675 0550 ??(Fax) 86 755 8221
  3363
• ??(E-mail) martha.pang_at_nemko.com ??(E-mail)
  yong.beom.choi_at_nemko.com
• ??/Shanghai ??/Guangzhou
• ??(Add.) ???????????????? ??(Add.) ???????498?
• ????139???????1406? ????????11G
• Rm.1406, HuaNeng Union Tower, 139 Yincheng
  Rm.11G, Boli Plaza Trade Centre, Guangfa
• Rd.(East), LuJiaZui Finance Trade
  Zone, Huayuan, No.498 Huanshi East Road,
• PuDong New Area, Shanghai City, China Dongshan
  District, Guangzhou, China
• ??(P.C.) 200120 ??(P.C.) 510175
• ??(Tel.) 86 6886 4637 ??(Tel.) 86 20 8760
  6422
• ??(Fax) 86 5840 2421 ??(Fax) 86 20 8760
  6095
• ??(E-mail) shirlin.wang_at_nemko.com ??(E-mail)
  steven.yang_at_nemko.com