UL RoHS 2007 Vincent Sylvester NA, Regional Business Manager RoHS Solutions (603) 370-7162 Vincent.Sylvester@us.ul.com Partners Working For A Green Planet!
Restricted Substances Regulations Stretch Across the Globe
RoHS Directive Restricted Substances and Limits
Insulated wires comprised of metal wire inside plastic insulating material Mechanically Disjointed Material • Mechanically Disjointed • Refers to materials that, in principle, can be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes • Semiconductor package containing six different homogeneous materials
“Green” Products –Restriction of 29 Total Substances Found in Annex A and B of Joint Industry Guide “JIG” (also called IPC 1065) developed by the EIA, JGPSSI and EICTA
Three Steps to RoHS Compliance • Understand It • Implement It • Prove It
RoHS Enforcement
Keys of “RoHS Enforcement Guidance Document” • Testing • Enforcement Process • Compliance Assurance System (CAS)
XRF Testing • EU will carry out X-Ray Fluorescence (XRF) analysis of products to detect infringements • XRF is a Screening Tool Capable of Detecting: • Pb, Cd, Hg • Cr (VI), Hexavalent Chrome • (for Cr total presence) • PBB’s and PBDE’s (Br compounds) • (for Br total presence only) • Note: Products must be submitted to China laboratories for testing
Enforcement Process • Market surveillance activities • Market intelligence • Random selection • Products known to contain materials of high concern • High volume products • Short life products • Consumer products unlikely to be recycled • Notification of concern from external parties • Notification of concern from other Member States
Requirements for a Compliance Assurance System (CAS) • Testing • Component Documentation • Procedure Documentation
Testing Requirements • Demonstrate that your finished products pass XRF screening • Demonstrate that your suppliers’ components pass XRF screening
Component Documentation Requirements • Provide all converted Bill of Materials for RoHS compliance • Provide Build to Print documentation for RoHS compliance for the following high risk parts and assemblies • Printed circuit boards • Cable assemblies • Metals • Metal Finishes • Plastics • Hardware
Levels of Preferred Component Documentation • Provide material declarations at homogeneous levels for all components • Where material declarations are not available, provide test verification that no restricted substances are present at the homogeneous level • Where material declarations or test results are not available, provide certificates of conformance or producers’ warranties for evidence of compliance Preferred Least Preferred
Procedure Documentation Requirements • Demonstrate that Management has provided RoHS compliance objectives, and resources to ensure progress toward RoHS compliant products and production • Provide evidence that RoHS compliance assurance is included in Management Review. • Provide training records for all employees for RoHS compliance
Procedure Documentation • Demonstrate the design process contains RoHS compliance • Demonstrate your internal data and records system reflects RoHS compliance data
Procedure Documentation • Supply Chain Management • Provide evidence that you have communicated RoHS requirements to your Suppliers • Demonstrate new part numbering system to distinguish between RoHS compliant and non-compliant • Demonstrate verification of incoming material procedures have been revised to address RoHS compliance
Procedure Documentation • Demonstrate material and equipment segregation to prevent contamination by a restricted substance • Demonstrate revised internal procedures and work instructions for RoHS compliance for the following areas: • Stockroom Segregation • Material Handling • Production Processes • Non-conforming Product • Corrective Action and Continual Improvement
Procedure Documentation • Provide internal audit data for RoHS compliance. • Provide supplier audits and assessments for RoHS compliance • Demonstrate that a supplier corrective action process is in place to address RoHS non-conformances. • Demonstrate traceability and containment procedures in the event of contamination.
RoHS Compliance Assurance System (CAS) Solution Step 1: Gap Analysis / Planning (2-day onsite program) • Lead Assessor Training • Gap Analysis • Management Overview Step 2: Implementation / Final Assessment (9-weeks) • Works with specific groups within the organization to address the specific RoHS requirements that impact them. • Modules include:
Restricted Substance Bill of Material (BOM) Conversion • For each submitted BoM and build-to-print drawing, UL will analyze and provide information on the following: • RoHS and Green compliance information for each component or material • Compliant replacements, if necessary and/or available • MSL rating • Peak reflow temperatures • Lead finish • Part identification markings • All supporting vendor documentation • XRF testing for components and materials where there is no data to confirm compliance
Thank You! • Questions and Answers
