RoHS Compliance One-stop testing, inspection, certification and training solutions Presented by Sunanda Kadam

TÜV SÜD South AsiaServices TÜV SÜD Product

13-02-15

ROHS Compliance

Slide 1

Transition to ROHS compliance

TÜV SÜD South Asia

13-02-15

1

RoHS - Overview

2

RoHS - Scope

4

Supply chain management

5

Risk analysis

7

Strategies for compliance

RoHS Compliance

Slide 2

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

TÜV SÜD South AsiaServices TÜV SÜD Product

13-02-15

RoHS Compliance

Slide 3

Overview – RoHS Basics

RoHS Directive Requirements From 1 July 2006, EEE placed on the market shall not contain Restricted Hazardous 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)

TÜV SÜD South AsiaServices TÜV SÜD Product

13-02-15

RoHS Compliance

Slide 4

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 2 nd 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? TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 5

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

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 6

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.

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 7

RoHS- Risk Assessment High risk components: CANADA Hazardous chemicals

High risks components & materials UK

FRANCE

U.S.A.

Pb

MEXICO

SPAIN

RUSSIA

POLAND CZECH REP. UKRAINE AUSTRIA ROMANIA ITALY

TURKEY

JAPAN CHINA Wire with PVC covering, power cord and plug, metal components, glass, ceramics, paints andINDIA pigments, lead frame coating, internal cable connector, solder EGYPT

SOUTH KOREA

SAUDI ARABIA

BANGLADESH

U.A.E.

OMAN

THAILAND

VIETNAM

PHILIPPINES

MALAYSIA

Cd

SINGAPOREand Wire with PVC covering, power cord and plugs, pigments BRAZILpaints. INDONESIA

Hg

Polyurethane, fluorescent lamps, button cells. SOUTH AFRICA

Cr(VI)

Metal screws, electroplated parts, corrosion treated metallic surface.

PBB/PBDE

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

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13-02-15

RoHS Compliance

Slide 8

RoHS –Risk Assessment Occurrence of Restricted Substances..

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RoHS Compliance

Slide 9

RoHS - Risk Assessment Occurrence of Restricted Substances.

Mercury Hg

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13-02-15

RoHS Compliance

Slide 10

RoHS - Risk Assessment Occurrence of Restricted Substances

PBB/PBDE

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13-02-15

RoHS compliance

Slide 11

RoHS - Risk Assessment

BOM analysis: • BOM analysis is risk assessment performed by technical professionals. • All components are reviewed and classified into High-risk, Lowrisk 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%.

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 12

RoHS - Risk Assessment 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

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 13

RoHS- Risk Assessment

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

TÜV SÜD South AsiaServices TÜV SÜD Product

13-02-15

RoHS Compliance

Slide 14

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

TÜV SÜD South AsiaServices TÜV SÜD Product

13-02-15

RoHS Compliance

Slide 15

RoHS- Risk Assessment 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 TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 16

RoHS- Risk Assessment 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. TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 17

RoHS – Strategies for Compliance Supplier System Development System assessment prior to production System validation during production

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13-02-15

RoHS Compliance

Slide 18

RoHS – Strategies for Compliance Control of Procurement •Design a green procurement system: RUSSIA -Selection of suppliers, subcontractors & laboratories -Evaluation criteria CANADA

UK

FRANCE

SPAIN

U.S.A.

POLAND CZECH REP. UKRAINE AUSTRIA ROMANIA ITALY

TURKEY

CHINA EGYPT

MEXICO

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

SAUDI ARABIA

INDIA U.A.E.

SOUTH KOREA

JAPAN

BANGLADESH

OMAN THAILAND

VIETNAM

PHILIPPINES

MALAYSIA

SINGAPORE

BRAZIL

INDONESIA

SOUTH AFRICA

• Approved product list: - BOM of each product (components, materials) • A list of banned hazardous substance TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 19

RoHS – Strategies for 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. TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 20

RoHS – Strategies for Compliance

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

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 21

RoHS – Strategies for Compliance

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.

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 22

RoHS – Strategies for Compliance Control of Records •

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

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 23

RoHS – Updates for India

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.

TÜV SÜD South Asia

13-02-15

RoHS Compliance

Slide 24

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