RoHS Compliance - EFY EXPO...

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RoHS Compliance

TÜV SÜD Product Services TÜV SÜD South Asia Slide 113-02-15 ROHS Compliance

Transition to ROHS compliance

1 RoHS - Overview

2 RoHS - Scope

4 Supply chain management

5 Risk analysis

7 Strategies for compliance

TÜV SÜD South Asia Slide 213-02-15 RoHS Compliance

TÜV SÜD Product Services

Overview – RoHS Basics

• EU Directive 2002/95/EC was issued in Jan 2003 & has been effective since July 1, 2006.

• The recast RoHS Directive 2011/65/EU entered into force on 28 June 2011, draws its scope from the categories laid out in Annex 1 of the Directive.

• Complementary and implemented in parallel to the WEEE Directive.

• Addresses chemical management in EEE by phasing out use of certain hazardous substances



Overview – RoHS Basics

RoHS Directive Requirements

From 1 July 2006, EEE placed on the market shall not contain RestrictedHazardous Substances:

• Heavy metals:– Lead (Pb) – Cadmium (Cd)– Mercury (Hg), – Chromium (VI) (Cr6+)

• Certain brominated flame retardants:– Polybrominated biphenyls (PBB’s)– Polybrominated diphenyl ethers (PBDE’s)


RoHS – Compliance solution

Supply chain management challenges:

• How capable is your 1st tier supplier relative to WEEE/RoHS compliance?

• How capable is your 1st tier supplier in implementing RoHS compliance by cascading the requirements further down to 2nd and 3rd tier component and raw material suppliers?

• Does your 1st tier supplier have capability to control material compliance to RoHS, e.g. internal testing capability?


RoHS Compliance Solution

Risk identification / Risk management:

Objective:Practicing control to reduce the chance of RoHS non-compliance

Two main sources for risk:• Material risk

- Components in BOM- Materials used in manufacturing process

• Supplier risk- Mass production variation- Batch compliance to specifications


RoHS – Risk Assessment

High risk materials:

• Restricted substance being intentionally added for achieving an expected function.

• Known high level of impurities.

• Recycled materials.

• Significant compliance failure statistics.

• Traceability being unable to be established.


RoHS- Risk Assessment

MEXICO

U.S.A.

BRAZIL

CANADARUSSIA

UK

FRANCE

SPAINITALY

POLAND

TURKEY

CZECH REP.AUSTRIA

UKRAINE

EGYPT

ROMANIA

OMAN

SAUDIARABIA

SOUTHAFRICA

CHINA

INDIA

JAPAN

THAILAND

MALAYSIA

INDONESIA

PHILIPPINESVIETNAM

SOUTHKOREA

U.A.E.BANGLADESH

SINGAPORE

High risk components:

Hazardous chemicals High risks components & materials

PbWire with PVC covering, power cord and plug, metal components, glass, ceramics, paints and pigments, lead frame coating, internal cable connector, solder

Cd Wire with PVC covering, power cord and plugs, pigments and paints.

Hg Polyurethane, fluorescent lamps, button cells.

Cr(VI) Metal screws, electroplated parts, corrosion treated metallic surface.

PBB/PBDE Plastic housings (ABS,PP,PE,HIPS), PCB boards.


RoHS –Risk Assessment

Occurrence of Restricted Substances..


RoHS - Risk Assessment

Mercury Hg

Occurrence of Restricted Substances.



PBB/PBDE

Occurrence of Restricted Substances

TÜV SÜD South Asia Slide 1113-02-15 RoHS compliance


BOM analysis:

• BOM analysis is risk assessment performed by technical professionals.

• All components are reviewed and classified into High-risk, Low-risk and Uncertain 3 levels.

• High-risk components will be fully tested.• Low-risk components will be sample tested.• Uncertain items will require more information for classification. • The overall objective is to reduce the testing cost for the client,

can be as much as 60%.



BOM analysis

To develop a compliance plan, information needed includes:

• Complete bill of materials & suppliers• Complete process treatment additives• Classification of component risk level• Compliance qualification & supports• Compliance traceability




Complete bill of materials & suppliers

• Purchased components– Electrical, mechanical, sub-assembly– Designated part number

• Suppliers– Single versus multiple sources

• In-house manufactured parts– Designated part number




Complete process treatment additives

• In-house process materials– Solders– Flame retardants– Colorants including pigment, ink, paint– Plating, coating, surface treatment– Stabilisers, processing aids



Compliance qualification & supports

Compliance evidence may include:

• Certificate of compliance

• Test report incl. test methods

• Material declaration– Substance CAS #– Component construction– Manufacturing process

• Factory audit report



Material ‘Compliance Traceability Tree’

• 1st tier supplier : contract supplier– Compliance evidence for all materials and components as

covered by BOM of EEE.– Process validation: e.g. “lead-free” manufacturing, plating,

plastic molding etc.

• 2nd tier supplier : material & component supplier– Compliance evidence for all materials and sub-components as

covered by BOM of component.

• 3rd tier supplier : raw materials– Compliance evidence for all raw materials.


RoHS – Strategies for Compliance

Supplier System Development

System assessment prior to production System validation during production



MEXICO

U.S.A.

BRAZIL

CANADARUSSIA

UK

FRANCE

SPAINITALY

POLAND

TURKEY

CZECH REP.AUSTRIA

UKRAINE

EGYPT

ROMANIA

OMAN

SAUDIARABIA

SOUTHAFRICA

CHINA

INDIA

JAPAN

THAILAND

MALAYSIA

INDONESIA

PHILIPPINESVIETNAM

SOUTHKOREA

U.A.E.BANGLADESH

SINGAPORE

Control of Procurement

•Design a green procurement system:-Selection of suppliers, subcontractors & laboratories-Evaluation criteria

• Approval vendor list:- Material suppliers- Manufacturers- Assembler- Service providers including laboratory

• Approved product list:- BOM of each product (components, materials)

• A list of banned hazardous substanceTÜV SÜD South Asia Slide 1913-02-15 RoHS Compliance


Control of Process

• Manufacturing, assembling:- Control & segregation of RoHS compliant materials & processes

• Equipment maintenance, upgrading:- Conforming repair processes- Upgrade existing equipment & or phase in lead-free production

• Process change:- Use of new equipment / repaired equipment- Use of new chemicals e.g. cooling liquid, antifreeze, solder, flame retardant, cleaning agent, degreaser, etc.



Control of product development & change

• Product review : identify any banned hazardous substances- Existing: a replacement program will be required- New : materials, components, packaging, marking, etc. assessment

• Product / design change : review & approval



Control of raw materials, components, semi-finished & finished products

• All the raw materials, components, semi-finished & finished products must be :

- identified & traceable- inspected & tested- marked inspection & test status

• All non-conforming products must be controlled including marking, segregation, etc. Corrective & preventive actions must be documented.

• All raw materials, components, semi-finished & finished products must be properly handled, stored, packed, preserved & delivered.



Control of Records

• Records including- Inspection reports- Test analysis reports- Certificate of compliance- Hazardous material list- Letter of guarantee / self-declaration- Abolition plan


India's ROHS…India has enacted the E-Waste (Management and Handling) Rules, 2011. The Rules 2011 cover both the restriction of hazardous materials in electronic and electrical equipment, and also impose responsibility on producers, collection centers, consumers or bulk consumers, dismantlers, and recyclers. Very similar to the European Union’s RoHS directive; restricts the same six substances at the same maximum concentrations as in the EU but the scope of products is different.

WEEE related provisions have entered into force on 1 May 2012, and RoHS related provisions will enter into force on 12 May 2013.

Two year transition period.

RoHS – Updates for India


[email protected]

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