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Product Environmental Compliance: Overview and Data Requirements

Product Environmental Compliance: Overview and Data Requirements

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Product Environmental Compliance: Overview and Data Requirements

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  1. Product Environmental Compliance:Overview and Data Requirements James Kaminski Project Manager, Product Environmental Compliance Rockwell Automation

  2. Disclaimer • This presentation has been put together to provide a high-level overview of a few of the EU product environmental requirements that apply to Electrical and Electronic Equipment and should be considered “for reference only” • This presentation does not cover all aspects of the Directives, nor does it apply to all product types • Rockwell Automation is not responsible for any actions on the part of other parties resulting from information shared within this presentation

  3. Agenda Who is Rockwell Product Environmental Compliance Overview Summary

  4. Who We Are The world’s largest companydedicated to industrialautomation and information. We make our customers more productive and the worldmore sustainable.

  5. Rockwell Automation At A Glance Fiscal 2013 Sales$6+ billion Employees Over 21,000 World Headquarters Milwaukee, WI USA MarketOver 80 countries Emerging Markets 22% of total sales Trading SymbolROK Leading global provider of industrial power, control and information solutions.

  6. Rockwell Automation Products Operator Interface Controllers Components and Accessories Sensors Over 300,000 standard products Over 700,000 active components and subassemblies Drives Mechanical Power Transmission Motors PowerDistribution Motor Control Rockwell Automation sells a variety of control electronics to help our customers control their processes and operations.

  7. Agenda Who is Rockwell Product Environmental Compliance Overview Summary

  8. Product Compliance Functions Technical / performance data Origin of components and raw matl’s Disclosure of substances in components

  9. What is Product Environmental Compliance? • Manufacturers must comply with environmental regulations addressing aspects of products which could have an adverse impact on the environment and/or humans. Common areas of concern: • Hazardous materials • Energy use and efficiency • Carbon and water footprint • Packaging and documentation • End-of-life disposal / recycling • The list of domestic and international environmental regulations geared towards environmental stewardship keeps growing and includes RoHS, REACH, WEEE, Batteries, Packaging and Eco-Design Complying with standards and directives ensures continued access to global markets

  10. Common traits: Regulations are not harmonized between countries, states and regions All require significant data tracking, management, and reporting requirements Not static but evolving Rapid global implementation Electronics Industry is Now Regulated Green Passport DMF BPA Ozone Depleting Substances Halogens Mercury PVC CLP POPS Greenhouse Gases REACH ELV TSCA RoHS Kyoto Protocol Phthalates PFOS Product Stewardship Packaging Batteries EU Ecodesign WEEE China Energy Efficiency Not just a European issue anymore! Latin America and North America have the highest number of proposed laws, the majority dealing with hazardous substances and waste take-back initiatives

  11. EU RoHS2011/65/EURestriction of Hazardous Substances • RoHSapplies to all types of electrical and electronic equipment (EEE) sold in the EU unless specifically excluded in the text of the Directive • For example, EEE operating above 1000V AC / 1500V DC is excluded • RoHS restricts the use of 6 hazardous substances in EEE • The thresholds for the RoHS substances are applied at the “homogenous material level” For a full review of the EU RoHS requirements, refer to the published European Union Directive 2011/65/EU or go to:

  12. EU REACHRegistration, Evaluation, Authorization of CHemicals Candidates for Authorization List Authorization List (Annex 14) Restricted List (Annex 17) None of these lists is static – new substances are continually added. Maintaining compliance relies on a full understanding of what substances are in our products

  13. Conflict Minerals: Dodd-Frank Wall Street Reform & Consumer Protection Act - Section 1502 • “Conflict Minerals” are minerals mined in conditions of armed conflict and human rights abuses, specifically funding a deadly civil war in the Democratic Republic of the Congo (DRC) region • “Conflict minerals” play critical roles in modern electronics • Tungsten (wolframite) –RF filters, small motors • Tin(cassiterite) – solder • Tantalum (columbite) – capacitors • Gold– switches, relays, connectors • The US law regarding Conflict Minerals is not a ban but a supply chain reporting issue, with the goal of eliminating business to mines that support conflict activities • It is not the intent of the law to eliminate business to that region of the world Conflict Mining and the Electronics Industry - the new “Blood Diamond”?

  14. Product Environmental ComplianceData Collection Activities • Information is required on the substances used in components and materials that go into our final, salable products • Hazardous substances regulated by RoHS, REACH • Special requirements for substances and mixtures that we import into the EU • To prepare for future restrictions, we need to collect “full material disclosure” which gives us knowledge of what’s contained in our products • In addition to substance knowledge, we must collect “Certificates of Compliance” to support our claims for RoHS and REACH regulations • RoHS Certificates of Compliance are required under EU RoHS2 • We must validate the “trustworthiness” of certificates by surveying / auditing our suppliers to ensure the consistency of their environmental programs

  15. Challenges of Declaration Sourcing Customer / OEM We must provide all of the same data to our customers Over the years, new and subsequent regulations have required data collection deeper into the supply chain Factored Product Manufacturer Component Distributor Component Manufacturer Solder Manufacturer PCBA Manufacturer 1993 Country of Origin Conflict Minerals REACH / FMD RoHS Component Manufacturer Component Manufacturer Component Manufacturer 2002 RoHS data requirements become more complex as we shift from EU to China Chemistry Supplier Chemistry Supplier Chemistry Supplier Material Supplier Chemistry Supplier 2008 Metals Supplier Metals Supplier Metals Supplier Smelter Mine of Origin Smelter 2013 Mine of Origin

  16. Agenda Who is Rockwell Product Environmental Compliance Overview Summary

  17. Summary • Regardless of the reasons for substance regulations, the responsibility of manufacturers to understand and provide the content of their products is increasing • Manufacturers who sell product internationally must be willing to make the investment in Product Stewardship functions to meet their legal requirements • The only guarantee in the world of Product Environmental Compliance is that the regulations will continue to grow • Sustainability efforts • Pollution control • E-waste problems • Energy efficiency • Carbon & water footprint