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RoHS II Compliance Presentation - Assent Compliance

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Assent Compliance hosted a free webinar on January 29th, covering RoHS II Compliance and the changes you will need to implement within your existing RoHS program in order to achieve …

Assent Compliance hosted a free webinar on January 29th, covering RoHS II Compliance and the changes you will need to implement within your existing RoHS program in order to achieve compliance.

This webinar will address processes and rules to consider when reviewing your current RoHS program for compliance with RoHS II.

The topics of discussion will include:

o Reviewing RoHS

o Reviewing RoHS II

o Changes between RoHS and RoHS II

o CE Marking Implications

o RoHS II Technical Files

o Standards associated with RoHS and RoHS II

o Exemption Expirations

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  • 1. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 RoHS II Review Update your RoHS Information to Achieve Compliance Assent Compliance Krystal Noseworthy-Baker Regulatory Manager – Key Accounts 613.882.1429 krystal.baker@assentcompliance.comC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 2. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Agenda • Review of Requirements • RoHS • RoHS recast (RoHS II) • DoCs • Technical File • Expiring Exemptions • Due Diligence and Testing • Technical File Sample • Standards associated with RoHS II • Enforcement • Q&A C u s t o m s o l u t i o n s f o r c o m p l i a n c y [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 3. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 About Assent Assent Compliance delivers SaaS Environmental Compliance Services to companies who must comply with local, national and global environmental regulations. Assent also supports its software division with a team of highly experienced industry consultants to provide our clients with turnkey compliance solutions. Industry experts at Tier 1 companies rank Assent Compliance amongst the top environmental compliance solutions in the world and one of the only global solution providers to offer a full service solution from end to end.Our MissionIs to help our clients comply with environmental regulations in themost efficient and cost effective manner possible. This is achievedthrough SaaS automation of processes and working with clientsto build efficient internal compliance programs that meet globalcompliance requirements.C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 4. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 How The Assent Compliance Management System Works Integrates with Pulls Bill of Material (BOM) Communicates with Supply Major ERP/PLM into a centralized compliance Chain in bi-directional fashion Systems data base or operates as a to procure environmental stand-alone system. information from suppliers Modules to Comply with All Major Environmental Build IPC 1752-A FORMS. Regulations Import/Export via XML Built-in CRM for compliance Homogenize proprietarytasks, due diligence reporting supplier DOC formats in xml and audit trails Allows internal Staff to Acts as a repository for any Make Engineering Override compliance related material assessments C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 5. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Consulting Services  Compliance Assessment Services For Environmental Regulations  Internal Standard Operating Procedure Consulting  Compliance Plan Development  Compliance Strategy Consulting  Conflict Mineral Compliance  IT System IntegrationC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 6. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 our offices Munich, Germany london, UK Ottawa, Ontario Can- ada (HQ) Taipei, Taiwan Bangalore, IndiaNew York,New York Kenya (Conflict Minerals) C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 7. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsMajor Differences between RoHS Recast and RoHS• Size and Comprehensiveness • RoHS Recast – Twenty-three (23) pages • RoHS – Five (5) pages• CE Marking• RoHS II is part of the Free Movement of Goods – Regulation 765/2008/EC • Conformity assessment procedures are affected• Scope • Further details given later in the presentationC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 8. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsMajor Differences between RoHS and RoHS II– Key Definition ChangeHomogeneous materials and coatings: • Never mentioned in RoHS • RoHS II states: »» Article 4.2: For the purposes of this Directive, no more than the maximum concentration value by weight in homogeneous materials as specified in Annex II shall be tolerated. »» Annex II of course details the restricted substances which have not changed: • Lead (0,1 %) • Mercury (0,1 %) • Cadmium (0,01 %) • Hexavalent chromium (0,1 %) • Polybrominated biphenyls (PBB) (0,1 %) • Polybrominated diphenyl ethers (PBDE) (0,1 %)NOTE: Article 4.2 goes on to state that the Commission is responsible for creating detailed rules for com-plying with the maximum concentration values for surface coatingsC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 9. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements RoHS II Overview • DIRECTIVE 2011/65/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June on the restriction of the use of certain hazardous substances in electrical and electronic equipment (recast) • Published in the Official Journal of the European Union: July 2011 • In Effect: July 21, 2011 • Into Member State law: January 2, 2013 • Previous RoHS Directive (2002/95/EC) repealed: January 3, 2013 C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 10. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements RoHS II – Categories 1. Large household appliances. 2. Small household appliances. 3. IT and telecommunications equipment. 4. Consumer equipment. 5. Lighting equipment. 6. Electrical and electronic tools. 7. Toys, leisure and sports equipment. 8. Medical devices. 9. Monitoring and control instruments including industrial monitoring and control instruments. 10. Automatic dispensers. 11. Other EEE not covered by any of the categories above. C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 11. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements RoHS II – Scope • Medical devices • Control and monitoring instruments • Category 11 Now all part of RoHS Recast • Directive does not apply to: • Equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes »» Defense • Equipment to be sent into space • Equipment which is specifically designed, and is to be installed, as part of another type of equip- ment that is excluded or does not fall within the scope of this Directive, which can fulfil its func- tion only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment • Large-scale stationary industrial tools • Large-scale fixed installations C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 12. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 • Means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved • Non-road mobile machinery made available exclusively for professional use • Active implantable medical devices • Photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications • Equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis. »» R&D B2BC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 13. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements RoHS II – New products in scope Category 11 TODAY Medical Devices: In Vitro Diagnostic Devices: (other) Equipment: 29 January 2013 22 July 2014 22 July 2016 22 July 2019 Consumer Monitoring and Professional Monitoring Control Instruments: and Control Instruments: 22 July 2014 22 July 2017 C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 14. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II and the CE Mark• CE Marking Directive • DoC, Technical File, CE Mark »» Declaration of Conformity: • Decision No 768/2008/EC • Format in the RoHS recast, Annex VI »» Technical file: • Module A of Decision No 768/2008/EC »» CE Mark: • Directive 93/68/EEC of 22 July 1993 • Subject to Article 30 of Regulation (EC) No 765/2008. • Applicable to: »» Finished products in scope of RoHS recast »» Placed on the market after January 2, 2013 • For those products already under scope of RoHS • For the new products under scope, the previous slide provides the datesC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 15. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II Responsibilities Manufacturer ImporterEU Declaration of Conformity EU Declaration of Conformity from manufacturer on recordTechnical File Ensure manufacturer has completed the technical fileCE Marking Ensure CE Mark is affixed to the productProduct marking Ensure manufacturer has completed required product marking(brand name, serial number, contact information)Note: Article 7(h) states: manufacturers (shall) indicate their name, registered trade name or registeredtrade mark and the address at which they can be contacted on the EEE or, where that is not possible, onits packaging or in a document accompanying the EEE.Article 7(d) states: importers indicate their name, registered trade name or registered trade mark and theaddress at which they can be contacted on the EEE or, where that is not possible, on its packaging or ina document accompanying the EEE.C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 16. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of Requirements (continued)RoHS II ResponsibilitiesArticle 8a allows for an authorized representative to be appointed by written mandate by a manu-facturer. Should an authorized representative be appointed they can deal with all manufacturer’sobligations except for being responsible for the RoHS compliant design and manufacture and thedrawing up of the technical documentation.Practical Application: Non-EU manufacturers can assign an authorized representative and thataddress would be present OR the importer’s information must be on the product or on its pack-aging or in an accompanying document. Having the manufacturer information as well as the im-porter’s is not an issue but the point is to have a member state entity’s information with the EEE.C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 17. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements Declaration of Conformity General Requirements: 1. No… (unique identification of the EEE): 2. Name and address of the manufacturer or his authorised representative: 3. This declaration of conformity is issued under the sole responsibility of the manufacturer (or installer): 4. Object of the declaration (identification of EEE allowing traceability. It may include a photo- graph, where appropriate): 5. The object of the declaration described above is in conformity with Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (recast) C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 18. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.80446. Where applicable, references to the relevant harmonised standards used or references to the technical specifications in relation to which conformity is declared:7. Additional information: Signature: • Signed for and on behalf of: • (place and date of issue): • (name, function) (signature): NOTE: Declaration must be translated into the language or languages required by the Member State of the market on which the product is placed or made available AND safety in- structions must be in a language that can be easily understood in every country in the EU in which the product is sold.C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 19. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements Technical File • Based on Module A of DECISION No 768/2008/EC • Has to contain at least the following elements: • a general description of the product, • conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits, etc. • descriptions and explanations necessary for the understanding of those drawings and schemes and the operation of the product, • a list of the harmonised standards and/or other relevant technical specifications the references of which have been published in the Official Journal of the European Union, applied in full or in part, and descriptions of the solutions adopted to meet the essential requirements of the legislative instrument where those harmonised • standards have not been applied. In the event of partly applied harmonised standards, the technical documentation shall specify the parts which have been applied, • results of design calculations made, examinations carried out, etc., and • test reports. • The documentation shall make it possible to assess the product’s conformity to the relevant requirements, and shall include an adequate analysis and assessment of the risk • N 50581 – Standard for EU Technical Files – Published Sept 2012 C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 20. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements Technical File – EN 50581 Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances • Combination of: • RoHS Recast (Directive 2011/65/EU) • Module A of Decision 768/2008 • IEC 62476 – Guidance for evaluation of products with respect to substance-use restric- tions in electrical and electronic products [Existed Previous to RoHS Recast] C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 21. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements Technical File – EN 50581 Beyond EN 50581, it should not be expected that there will be significantly more detail from the EU Commission. Official statement by the EU Commission regarding RoHS recast: …as a general rule and in the interests of legal certainty, it is inappropriate for the Commission to make interpretative statements on legislative texts, which should be comprehensible in themselves. …note that it is in any event for the Court of Justice alone to provide authoritative interpretations as to the meaning of Union law. C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 22. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements Technical File – EN 50581 FOUR MAJOR TASKS: • Determine the information needed • Collect the information • Evaluate the information for: • quality and trustworthiness • whether to include the documentation in the technical file • Ensure that the technical documentation remains valid C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 23. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Review of Requirements RoHS II – Exemptions RoHS recast has two (2) groups of Exemptions: • Annex III – Applications exempted from the restriction in Article 4(1) • Annex IV – Applications exempted from the restriction in Article 4(1) specific to medical devices and monitoring and control instruments Validity Date • Annex III: • For the exemptions listed in Annex III as at 21 July 2011, the maximum validity period, which may be renewed, shall, for categories 1 to 7 and 10 of Annex I, be 5 years from 21 July 2011 and, for categories 8 and 9 of Annex I, 7 years from the relevant dates laid down in Article 4(3), unless a shorter period is specified. • Annex IV: • For the exemptions listed in Annex IV as at 21 July 2011, the maximum validity period, which may be renewed, shall be 7 years from the relevant dates laid down in Article 4(3), unless a shorter period is specified. • Unless otherwise specified • Thirty-eight (38) Annex III exemptions currently have a specified sunset date C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 24. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044If an exemption is not renewed, it would proceed to a revocation process• Applications for renewal are required to be submitted at least eighteen (18) months before the expiry date of an exemption • Similar to the Authorisation Process under REACH• If a decision is made to revoke an exemption, the exemption will expire twelve (12) to eighteen (18) months from the date of the decisionC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 25. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Mercury in single capped (compact) fluorescent 1 lamps not exceeding (per burner): Expired on 31 December 2011; 3,5 mg may be used per burner after 31 December 1a For general lighting purposes < 30 W: 5 mg 2011 until 31 December 2012; 2,5 mg shall be used per burner after 31 December 2012 For general lighting purposes ≥ 30 W and < 50 Expired on 31 December 2011; 3,5 mg may be 1b W: 5 mg used per burner after 31 December 2011 For general lighting purposes ≥ 50 W and < 150 1c W: 5 mg 1d For general lighting purposes ≥ 150 W: 15 mg For general lighting purposes with circular No limitation of use until 31 December 2011; 7 1e or square structural shape and tube diameter mg may be used per burner after 31 December ≤ 17 mm 2011 1f For special purposes: 5 mgC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 26. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Mercury in double-capped linear fluorescent 2a lamps for general lighting purposes not exceed- ing (per lamp): Tri-band phosphor with normal lifetime and a Expired on 31 December 2011; 4 mg may be 2a1 tube diameter < 9 mm (e.g. T2): 5 mg used per lamp after 31 December 2011 Tri-band phosphor with normal lifetime and a Expired on 31 December 2011; 3 mg may be 2a2 tube diameter ≥ 9 mm and ≤ 17 mm (e.g. T5): used per lamp after 31 December 2011 5 mg Tri-band phosphor with normal lifetime and a Expired on 31 December 2011; 3,5 mg may be 2a3 tube diameter > 17 mm and ≤ 28 mm (e.g. T8): used per lamp after 31 December 2011 5 mg Tri-band phosphor with normal lifetime and a Expired on 31 December 2012; 3,5 mg may be 2a4 tube diameter > 28 mm (e.g. T12): 5 mg used per lamp after 31 December 2012 Tri-band phosphor with long lifetime (≥ 25 000 Expired on 31 December 2011; 5 mg may be 2a5 h): 8 mg used per lamp after 31 December 2011C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 27. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Mercury in other fluorescent lamps not exceed- 2b ing (per lamp): Linear halophosphate lamps with tube > 28 mm 2b1 Expired on 13 April 2012 (e.g. T10 and T12): 10 mg Non-linear halophosphate lamps (all diameters): 2b2 Expires on 13 April 2016 15 mg No limitation of use until 31 December 2011; Non-linear tri-band phosphor lamps with tube 2b3 15 mg may be used per lamp after 31 December diameter > 17 mm (e.g. T9) 2011 No limitation of use until 31 December 2011; Lamps for other general lighting and special 2b4 15 mg may be used per lamp after 31 December purposes (e.g. induction lamps) 2011C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 28. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Mercury in cold cathode fluorescent lamps and external electrode fluorescent lamps (CCFL and 3 EEFL) for special purposes not exceeding (per lamp): No limitation of use until 31 December 2011; 3a Short length (≤ 500 mm) 3,5 mg may be used per lamp after 31 December 2011 No limitation of use until 31 December 2011; 3b Medium length (> 500 mm and ≤ 1 500 mm) 5 mg may be used per lamp after 31 December 2011 No limitation of use until 31 December 2011; 3c Long length (> 1 500 mm) 13 mg may be used per lamp after 31 December 2011C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 29. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability No limitation of use until 31 December 2011; Mercury in other low pressure discharge lamps 4a 15 mg may be used per lamp after 31 December (per lamp) 2011 Mercury in High Pressure Sodium (vapour) lamps for general lighting purposes not exceed- 4b ing (per burner) in lamps with improved colour rendering index Ra > 60: No limitation of use until 31 December 2011; 30 4b-I P ≤ 155 W mg may be used per burner after 31 December 2011 No limitation of use until 31 December 2011; 40 4b-II 155 W < P ≤ 405 W mg may be used per burner after 31 December 2011 No limitation of use until 31 December 2011; 40 4b-III P > 405 W mg may be used per burner after 31 December 2011C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 30. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Mercury in other High Pressure Sodium (va- 4c pour) lamps for general lighting purposes not exceeding (per burner): No limitation of use until 31 December 2011; 25 4c-I P ≤ 155 W mg may be used per burner after 31 December 2011 No limitation of use until 31 December 2011; 30 4c-II 155 W < P ≤ 405 W mg may be used per burner after 31 December 2011 No limitation of use until 31 December 2011; 40 4c-III P > 405 W mg may be used per burner after 31 December 2011 Mercury in High Pressure Mercury (vapour) 4d Expires on 13 April 2015 lamps (HPMV) 4e Mercury in metal halide lamps (MH) Mercury in other discharge lamps for spe- 4f cial purposes not specifically mentioned in this AnnexC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 31. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability 5a Lead in glass of cathode ray tubes Lead in glass of fluorescent tubes not exceeding 5b 0,2 % by weight Lead as an alloying element in steel for machin- 6a ing purposes and in galvanised steel containing up to 0,35 % lead by weight Lead as an alloying element in aluminium con- 6b taining up to 0,4 % lead by weight Copper alloy containing up to 4 % lead by 6c weightC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 32. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Lead in high melting temperature type sol- 7a ders (i.e. lead- based alloys containing 85 % by weight or more lead) Lead in solders for servers, storage and storage array systems, network infrastructure equipment 7b for switching, signalling, transmission, and net- work management for telecommunications Electrical and electronic components containing lead in a glass or ceramic other than dielectric 7c-I ceramic in capacitors, e.g. piezoelectronic de- vices, or in a glass or ceramic matrix compound Lead in dielectric ceramic in capacitors for a rat- 7c-II ed voltage of 125 V AC or 250 V DC or higher Expired on 1 January 2013 and after that date Lead in dielectric ceramic in capacitors for a rat- 7c-III may be used in spare parts for EEE placed on the ed voltage of less than 125 V AC or 250 V DC market before 1 January 2013 Lead in PZT based dielectric ceramic materials for capacitors which are part of integrated cir- 7c-IV Expires on 21 July 2016 cuits or discrete semiconductors (*Amendment on 18/12/2012)C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 33. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Expired on 1 January 2012 and after that date Cadmium and its compounds in one shot pellet 8a may be used in spare parts for EEE placed on the type thermal cut-offs market before 1 January 2012 Cadmium and its compounds in electrical 8b contacts Hexavalent chromium as an anticorrosion agent of the carbon steel cooling system in absorption 9 refrigerators up to 0,75 % by weight in the cool- ing solution Lead in bearing shells and bushes for refrigerant- containing compressors for heating, ventilation, 9b air conditioning and refrigeration (HVACR) applications Lead used in C-press compliant pin connector May be used in spare parts for EEE placed on the 11a systems market before 24 September 2010 Expired on 1 January 2013 and after that date Lead used in other than C-press compliant pin 11b may be used in spare parts for EEE placed on the connector systems market before 1 January 2013C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 34. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions No. exemption Scope and Dates of Applicability Lead as a coating material for the thermal con- May be used in spare parts for EEE placed on the 12 duction module C-ring market before 24 September 2010 13a Lead in white glasses used for optical applications Cadmium and lead in filter glasses and glasses 13b used for reflectance standards Lead in solders consisting of more than two ele- ments for the connection between the pins and Expired on 1 January 2011 and after that date 14 the package of microprocessors with a lead con- may be used in spare parts for EEE placed on the tent of more than 80 % and less than 85 % by market before 1 January 2011 weight Lead in solders to complete a viable electrical 15 connection between semiconductor die and car- rier within integrated circuit flip chip packages Lead in linear incandescent lamps with silicate 16 Expires on 1 September 2013 coated tubes Lead halide as radiant agent in high intensity 17 discharge (HID) lamps used for professional re- prography applicationsC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 35. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions Scope and Dates of Applicabil- No. exemption ity Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as speciality 18a lamps for diazoprinting reprography, lithography, insect Expired on 1 January 2011 traps, photochemical and curing processes containing phosphors such as SMS ((Sr,Ba) 2 MgSi 2 O 7 :Pb) Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tan- 18b ning lamps containing phosphors such as BSP (BaSi 2 O 5 :Pb) Lead with PbBiSn-Hg and PbInSn-Hg in specific compo- 19 sitions as main amalgam and with PbSn-Hg as auxiliary Expired on 1 June 2011 amalgam in very compact energy saving lamps (ESL) Lead oxide in glass used for bonding front and rear sub- 20 strates of flat fluorescent lamps used for Liquid Crystal Expired on 1 June 2011 Displays (LCDs) Lead and cadmium in printing inks for the application 21 of enamels on glasses, such as borosilicate and soda lime glasses Lead in finishes of fine pitch components other than con- May be used in spare parts for EEE placed on 23 nectors with a pitch of 0,65 mm and less the market before 24 September 2010 Lead in solders for the soldering to machined through hole 24 discoidal and planar array ceramic multilayer capacitorsC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 36. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions Scope and Dates of Applicabil- No. exemption ity Lead oxide in surface conduction electron emitter 25 displays (SED) used in structural elements, notably in the seal frit and frit ring Lead oxide in the glass envelope of black light blue 26 Expired on 1 June 2011 lamps Lead alloys as solder for transducers used in high- powered (designated to operate for several hours 27 Expired on 24 September 2010 at acoustic power levels of 125 dB SPL and above) loudspeakers Lead bound in crystal glass as defined in Annex I 29 (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC ( 1 ) Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the 30 voice coil in transducers used in high-powered loud- speakers with sound pressure levels of 100 dB (A) and more Lead in soldering materials in mercury free flat fluo- 31 rescent lamps (which, e.g. are used for liquid crystal displays, design or industrial lighting) Lead oxide in seal frit used for making window as- 32 semblies for Argon and Krypton laser tubesC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 37. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Review of RequirementsRoHS II – Exemptions Scope and Dates of Applicabil- No. exemption ity Lead in solders for the soldering of thin copper wires 33 of 100 μm diameter and less in power transformers Lead in cermet-based trimmer potentiometer 34 elements Mercury used as a cathode sputtering inhibitor in 36 DC plasma displays with a content up to 30 mg per Expired on 1 July 2010 display Lead in the plating layer of high voltage diodes on 37 the basis of a zinc borate glass body Cadmium and cadmium oxide in thick film pastes 38 used on aluminium bonded beryllium oxide Cadmium in colour converting II-VI LEDs (< 10 μg 39 Cd per mm 2 of light-emitting area) for use in solid Expires on 1 July 2014 state illumination or display systems Cadmium in photoresistors for analogue opto- 40 couplers applied in professional audio equipment Expires on 31 Dec 2013 (*Amendment on 10/10/2012)C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 38. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Due Diligence and Testing What is their role in RoHS II Compliance – specifically the Technical File? Determination of Necessary Information • Assess what types of documents are required based on substance presence risk and supplier risk • Technical judgement allowed Collection of Information • Types of allowed documentation »» Supplier declarations »» Material Declarations »» Analytical test results C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 39. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Due Diligence and Testing What is their role in RoHS II Compliance – specifically the Technical File? Evaluation of Data • Mandatory for Manufacturers • Requirements include: • Establish procedures for evaluating collected information / documentation • Evaluate whether each part, component, or material meets the materials restriction re- quirements of RoHS Recast • Evaluate whether the document is of sufficient quality to include in the technical documentation »» Criteria met = Included »» Criteria not met = further corrective actions or analysis Ensuring Validity of Data • Requirements: • periodic review of the documents contained in the technical documentation to ensure that they are still valid; • technical documentation must reflect any changes to materials, parts or sub-assemblies C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 40. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Due Diligence and Testing What is their role in RoHS II Compliance – specifically the Technical File? STANDARD PRACTICE: • Annual Updates – with the Annual Audit! • Significant Product Changes = Update File • Completeness in the Technical File: • Consumables • Out of Scope Parts • Not part of the RoHS Compliance THEREFORE not required to be included »» Recommended that the out of scope and consumable parts are footnoted C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 41. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Due Diligence and Testing – EN 62321What is their role in RoHS II Compliance –specifically the Technical File?Electrotechnical products – Determination of levels of six regulated substances (lead, mercury,cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers) • EU Standard for RoHS testing • Not Mandatory…HOWEVER: »» Most effective method of risk management »» Usually less costly than alternative (further/increased) supplier data gathering and/or corrective action methods »» Testing to an established standard allows you to quote it in the file = lends credibility • If you have done it right, others don’t have to! • Recommended to have at least scan testing to EN 62321:2009 in technical file »» XRFC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 42. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Due Diligence and Testing – EN 62321 Declaration and Test Report Sample Review Test Report No. : CE/2010/22946 Date : 2010/02/24 Page : 4 of 5 BOURNS TRIMPOT ELECTRONICAS, LIMITADA DEL CURCE A SAN ANTONIO DE BELEN AUTOPISTA CANAS-150 MTS *CE/2010/22946* MATERIAL DECLARATION SHEET AL OESTE HEREDIA, COSTA RICA. Test Report No. : CE/2010/22946 Date : 2010/02/24 Page : 2 of 5 BOURNS TRIMPOT ELECTRONICAS, LIMITADA *CE/2010/22946* DEL CURCE A SAN ANTONIO DE BELEN AUTOPISTA CANAS-150 MTS PBB/PBDE analytical FLOW CHART AL OESTE HEREDIA, COSTA RICA. No. Construction Element Material Group Report Note 1) Name of the person who made measurement: Roman Wong Test results by chemical method (Unit: mg/kg) 2) Name of the person in charge of measurement: Shinjyh Chen Test Item (s): Method Result MDL (Refer to) No.1 1 Element Ink + Ceramic B First testing process Cadmium (Cd) (1) n.d. 2 Sample Lead (Pb) (2) 2520 2 Confirmation process Bourns Trimpot Electronicas, Limitada Optional screen process Mercury (Hg) (3) n.d. 2 Hexavalent Chromium Cr(VI) by (4) n.d. 2 2 Back plate 263 Copper alloy A Del Cruce a San Antonio de Belen Sample pretreatment alkaline extraction Sum of PBBs n.d. - Test Report No. 150 Mts Al Oeste : 2010/02/24 Autopista Cañas - : CE/2010/22946 Date Monobromobiphenyl of 5 Page : 1 Dibromobiphenyl n.d. n.d. 3 5 5 Back plate 220 Copper alloy A Screen analysis BOURNS TRIMPOT ELECTRONICAS, LIMITADA Tribromobiphenyl *CE/2010/22946* Heredia, Costa Rica n.d. 5 DEL CURCE A SAN ANTONIO DE BELEN AUTOPISTA CANAS-150Tetrabromobiphenyl MTS n.d. 5 Pentabromobiphenyl n.d. 5 AL OESTE HEREDIA, COSTA RICA. Hexabromobiphenyl n.d. 4 5 Wire Copper Alloy A Sample extraction/ Heptabromobiphenyl n.d. 5 Soxhlet method Octabromobiphenyl n.d. 5 Nonabromobiphenyl The following sample(s) was/were submitted and identified by/on behalf of the client as : n.d. No. : CE/2010/22946 Date : 2010/02/24 5 5 5 Mold compound Page : 3 of 5 Various Test Report A Decabromobiphenyl n.d. (5) BOURNS TRIMPOT ELECTRONICAS, LIMITADA *CE/2010/22946* Concentrate/Dilute Sum of PBDEs n.d. - DEL CURCE A SAN ANTONIO DE BELEN AUTOPISTA CANAS-150 MTS Sample Description Extracted solution : Monobromodiphenyl ether BOURNS MODELS PWR263, PWR163, PWR220T, PWR221T AL OESTE HEREDIA,n.d. COSTA RICA. 5 Test Report No. : CE/2010/22946 Date : 2010/02/24 Style/Item No. Page : 5 of 5 : Dibromodiphenyl ether THICKFILM POWER RESISTORS/ELEMENT ether n.d. 5 Tribromodiphenyl n.d. Note A: RoHS compliance. 5 Sample Receiving Date BOURNS TRIMPOT ELECTRONICAS, LIMITADA : 2010/02/11 Filter *CE/2010/22946* Tetrabromodiphenyl ether n.d. 5 DEL CURCE A SAN ANTONIO DE BELEN AUTOPISTA CANAS-150 MTS Testing Period : 2010/02/11 TO 2010/02/24 Pentabromodiphenyl ether n.d. Note B: ROHS Compliant By Exemption 5 (lead 1) These samples were dissolved totally by pre-conditioning method according to below flow chart. 5 in glass of AL OESTE HEREDIA, COSTA RICA. Hexabromodiphenyl ether (Cr 6+ test method excluded) n.d. 5 Heptabromodiphenyl ether 2) Name of the person who electronic components) n.d. made measurement: Climbgreat Yang 5 Analysis by GC/MS ============================================================================================ person in charge of measurement: Troy Chang Octabromodiphenyl ether 3) Name of the n.d. 5 Nonabromodiphenyl ether n.d. 5 Decabromodiphenyl ether Cutting / Preparation n.d. 5 Test Requested : Issue ReportIn accordance with the RoHS Directive 2002/95/EC, and its amendment Requirement: Review points directives. TEST PART DESCRIPTION: NO.1 : MIXED ALL PARTS Sample Measurement Hg Cr6 + Test Method : Note: 1. mg/kg = ppm; 0.1wt% = 1000ppm With reference to IEC 62321: 2008 Pb、Cd Contain Pb Hg Cr+6 PBB and PBDE< 0.1 % (1000 ppm) by 2. n.d. = Not Detected Procedures for the Determination of Levels of=Regulated Substances in 3. MDL Method Detection Limit Acid digestion by suitable acid weight. digestion with Microwave Add appropriate amount of Electrotechnical Products. • Directive Stated 4. "-" = Not Regulated depended on different sample 5. The sample(s) was/were analyzed on behalf of the applicant astable) sample in one testing. /HCl/HF 0.01 material (as below mixing Contain Cd < HNO3 % (100 ppm) by weight digestion reagent (1) Determination of Cadmium by ICP-AES. The above result(s) was/were only given as the informality value. (2) Determination of Lead by ICP-AES.the results shown in this test report refer only to the sample(s) tested. This test report cannot be reproduced, except in full, without prior written permission of the Company. Unless otherwise stated Filtration (3) Determination of Mercury byReport is issued by the Company under its General Conditions of Service printed overleaf or available on request and accessible at http://www.sgs.com/terms_and_conditions.htm. Attention This Test ICP-AES. 除非另有說明,此報告結果僅對測試之樣品負責。本報告未經本公司書面許可,不可部分複製。 Heat to appropriate • Standard Stated is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein. Any holder of this Test Report is advised that information contained hereon reflects the Company’s findings (4) Determination of Hexavalent Chromium and within the limits of Client’s instructions, if any. The Company’s sole responsibility is to its Client and this document does not exonerate parties to a transaction at the time of its intervention only by UV/Vis Spectrometry. Unless otherwise stated the results shown in this test report refer only to the sample(s) tested. This test report cannot be reproduced, except in full, without prior written permissionfrom exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the content or appearance of this document is unlawful and of the Company. temperature to extractPower Resistor RoHS Test This Test Report is issued by the Company under its General Conditions of Service printed overleaf or available on request and(5) Determination of PBB and PBDE by GC/MS. 除非另有說明,此報告結果僅對測試之樣品負責。本報告未經本公司書面許可,不可部分複製。 offenders may be prosecuted to the fullest extent of the law. accessible at http://www.sgs.com/terms_and_conditions.htm. Attention Ltd. SGS Taiwan Residue ** End of Report ** is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein. Any holder of this Test Report is advised that information contained hereon reflects the Company’s findings Solution 台灣檢驗科技股份有限公司 Chemical-Taipei 33 WuChyuan Road, Wuku Industrial Zone, Taipei County, Taiwan /台北縣五股工業區五權路33號 t + 886 (02)2299 3279 f + 886 (02)2299 3237 www.sgs.com at the time of its intervention only and within the limits of Client’s instructions, if any. The Company’s sole responsibility is to its Client and this document does not exonerate parties to a transaction from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the content or appearance of this document is unlawful and Member of the SGS Group (SGS SA) Cool, filter digestate offenders may be prosecuted to the fullest extent of the law. Test Result(s) : Please refer to next page(s). • Dates through filter Report SGS Taiwan Ltd. 台灣檢驗科技股份有限公司 Chemical-Taipei 33 WuChyuan Road, Wuku Industrial Zone, Taipei County, Taiwan /台北縣五股工業區五權路33號 t + 886 (02)2299 3279 f + 886 (02)2299 3237 www.sgs.com 1) Alkali Fusion Member of the SGS Group (SGS SA) 2) HCl to dissolve Add diphenyl-carbazide for ICP-AES color development Sample Material Steel, copper, aluminum, solder Glass Digestion Acid Aqua regia, HNO3 , HCl, HF, H 2O2 HNO3 /HF • Signature measure the absorbance at 540 nm by UV-VIS MODEL: PWR263S Gold, platinum, palladium, ceramic Silver Aqua regia HNO3 • This lab is fairly well known Plastic H2 SO4 , H2O2 , HNO 3, HCl Others Any acid to total digestion Unless otherwise stated the results shown in this test report refer only to the sample(s) tested. This test report cannot be reproduced, except in full, without prior written permission of the Company. 除非另有說明,此報告結果僅對測試之樣品負責。本報告未經本公司書面許可,不可部分複製。 This Test Report is issued by the Company under its General Conditions of Service printed overleaf or available on request and accessible at http://www.sgs.com/terms_and_conditions.htm. Attention is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein. Any holder of this Test Report is advised that information contained hereon reflects the Company’s findings at the time of its intervention only and within the limits of Client’s instructions, if any. The Company’s sole responsibility is to its Client and this document does not exonerate parties to a transaction • Product Identification is very clear Unless otherwise stated the results shown in this test report refer only to the sample(s) tested. This test report cannot be reproduced, except in full, without prior written permission of the Company. from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the content or appearance of this document is unlawful and 除非另有說明,此報告結果僅對測試之樣品負責。本報告未經本公司書面許可,不可部分複製。 offenders may be prosecuted to the fullest extent of the law. This Test Report is issued by the Company under its General Conditions of Service printed overleaf or available on request and accessible at http://www.sgs.com/terms_and_conditions.htm. Attention SGS Taiwan Ltd. is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein. Any holder of this Test Report is advised that information contained hereon reflects the Company’s findings Unless otherwise stated the results shown in this test report refer only to the sample(s) tested. This test report cannot be reproduced, except in full, without prior written permissionthe time Company. at of the of its intervention only and within the limits of Client’s instructions, if any. The Company’s sole responsibility is to its Client and this document does not exonerate parties to a transaction 台灣檢驗科技股份有限公司 Chemical-Taipei 33 WuChyuan Road, Wuku Industrial Zone, Taipei County, Taiwan /台北縣五股工業區五權路33號 t + 886 (02)2299 3279 f + 886 (02)2299 3237 www.sgs.com 除非另有說明,此報告結果僅對測試之樣品負責。本報告未經本公司書面許可,不可部分複製。 from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the content or appearance of this document is unlawful and This Test Report is issued by the Company under its General Conditions of of the SGS Group (SGSoverleaf or available on request and accessible at http://www.sgs.com/terms_and_conditions.htm. Attention Member Service printed SA) offenders may be prosecuted to the fullest extent of the law. is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein. Any holder of this Test Report is advised that information contained hereon reflects the Company’s findingsLtd. SGS Taiwan at the time of its intervention only and within the limits of Client’s instructions, if any. The Company’s sole responsibility is to its Client and this document does not exonerate parties to a transaction 台灣檢驗科技股份有限公司 Chemical-Taipei 33 WuChyuan Road, Wuku Industrial Zone, Taipei County, Taiwan /台北縣五股工業區五權路33號 t + 886 (02)2299 3279 f + 886 (02)2299 3237 www.sgs.com from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the content or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law. Member of the SGS Group (SGS SA) SGS Taiwan Ltd. 台灣檢驗科技股份有限公司 Chemical-Taipei 33 WuChyuan Road, Wuku Industrial Zone, Taipei County, Taiwan /台北縣五股工業區五權路33號 t + 886 (02)2299 3279 f + 886 (02)2299 3237 www.sgs.com Member of the SGS Group (SGS SA) C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 43. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Due Diligence and Testing – EN 62321 Declaration and Test Report Sample Review 456 Seastrom St. Twin Falls, ID 83301 October 13, 2011 Certificate of Compliance European Union Directive 2002/95/EC Restriction of Hazardous Substances Any Seastrom part number, produced by Seastrom Manufacturing Co., Inc. that meets the following conditions is classified as compliant in accordance with European Union Directive 2002/95/EC (RoHS).  Material: 456 Seastrom St. Twin Falls, ID 83301 Any of the materials listed below without a process/finish. October 13, 2011 Non-Metals:  Delrin (Acetal) Non-Compliance Certificate of  Mica  Polyethylene  Epoxy Glass  Mylar  PVC (Polyvinyl Chloride) (Fiberglass)  Neoprene European Union Directive 2002/95/EC  Santoprene  FluorocarbonHazardous Substances Restriction of (Viton)  Nitrile (Buna-N)  Silicone  Fluorosilicone  Nylatron  Teflon The following materials and processes used at Seastrom Manufacturing Co., Inc. have  Kapton  Nylon been classified as Non-Compliant in accordance with the European Union Directive  Vulcanized Fibre  KEL-F (PCTFE) 2002/95/EC (RoHS). This Directive, however, does not Phenolic affect the use of parts in Metals: applications outside of the Directive’s specified countries. Review points  Brass  Phosphorus Bronze  Stainless Steel Non-Compliant Process/Finish  Copper  Cold Rolled Steel  Steel  Beryllium Copper  Spring Steel  Titanium Process/Finish: Denoted @ end of part # as: • Directive Stated Chemical Film Finish The following base materials contain > 0.1% lead, but are exempt under note 6 of the Directive’s Annex: -CF Hexavalent Chromium Finish -CHR  12L14 Steel (0.35% -C1,weight max) of -C2  C - 360 Brass Rod (3.7% of weight max) • Note that this is in accordance with the “original” RoHS and not the recast however Cadmium Chrome -CHR  Process/Finish: 60/40 Tin Lead Finish -TL1, -TL2 Any Seastrom part number-Z2 Zinc Plate, Type II (Yellow) you will also note that most of the important elements are included produced with a process/finish listed below is compliant under the Chromatic Anodize, Directive, unless the base material is Aluminum. (Contact Seastrom for Aluminum part status) Type I -A1 Standard Electroless Nickel Plating (can be RoHS compliant if specified by customer on Compliant Process/Finish: Denoted @ end of order) part # as: Less Finish -LF • Regulatory wording may be slightly different but the declaration speaks to it! Non-Compliant Materials: Sulfuric Anodize, Type II -A2 2011 Aluminum Rod (primarily used in shoulder washers, spacers, and washers with Black Oxide a specified part. to see if Aluminum 2011 is used for • Highlights non-compliant and compliant parts/processes/finishes thin side walls.) For Aluminum parts, please contact Seastrom at info@seastrom-mfg.com -A3 Hard Anodize, Type III -BO Passivate -P Sincerely, Phosphate Electrolytic Nickel Plate • Includes part # denotations -PH -N Silver Plate -S Maegan Melton Quality Engineer Tin Plate Tin Dip Brad Mohr • Exemptions (as applicable) Process Engineer -T1 -T2 Zinc Plate, Type I (Blue) -Z1 • Dated Seastrom Manufacturing Co., Inc. is Certified ISO 9001:2000 and AS9100:2004 Zinc Plate, Type III (Clear) -Z3 Designated Electroless Nickel Plate (RoHS Compliance must be requested by customer) Sincerely, • Signature and Function Maegan Melton Brad Mohr Quality Engineer • Letterhead Process Engineer • Contact for further information C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 44. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Due Diligence and Testing – EN 62321 Declaration and Test Report Sample Review 1630 McCarthy Boulevard Milpitas, CA 95035-7417 RoHS DIRECTIVE 2011/65/EU MATERIAL DECLARATION CERTIFICATE Linear Technology Corporation certifies the deliverable products, when ordered as lead-free meet the RoHS DIRECTIVE Review points 2011/65/EU. • Restriction of the use of certain hazardous substances in electrical and electronic equipment (Recast) does not pertain to • Directive Stated Linear Technology Corporation. • Linear Technology Corporation also complies with: People’s Republic of China RoHS Directive EIS SJ/T11364-2006 • RoHS recast RoHS Definitions: • Concentration limit of 0.1% by mass (1000 PPM) in homogeneous material for Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr), Polybrominated Biphenyl (PBB), Polybrominated Diphenyl Ether (PBDE), »» Does not include the specific regulatory wording Decabromodiphenyl Ether (Deca-BDE), Toluene, Trichlorobenzene, and Hexabromocyclododecane (HBCDD), Bis (2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutylphthalate (DBP) (as indicated in the earlier slide) • Concentration limit of 0.01% by mass (100 PPM) of homogeneous material for Cadmium (Cd) • Concentration limit of 0.005% by mass (50 PPM) for Perfluorooctane Sulfonates (PFOS) RoHS Exemption: • Confusing wording • Products in the TO-220, DDPAK, SOT223 and TO247 packages are currently assembled with a Soft Solder Die Attach material containing Lead (Pb). Article 4, Annex 7a (>85% Lead, Pb, in high melting point solders) exempts this material at this time. • Certifies that it meets the directive HOWEVER The Chinese RoHS EFUP Logo 2 applies when these packages are shipped to the People’s Republic of China. • The micro modules products contain lead in the glass frit. Article 4, Annex 7(c)-1, (electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound. »» Restriction of the use of certain hazardous substances in The Chinese RoHS EFUP Logo 2 applies when these packages are shipped to the People’s Republic of China. Substances of Concern: electrical and electronic equipment (Recast) does not pertain to • Antimony Trioxide, Sb2O3 (CAS# 1309-64-4) and Bromine, Br (CAS# 10097-32-2) are used as a flame retardant in mold compound in several products. Linear Technology Corporation is evaluating and qualifying new mold compounds that contain Linear Technology Corporation. no Sb2O3, or Br. Once qualified these products will be considered Halogen-Free. • Polyvinyl Chloride (PVC) – in shipping tubes, CAS #9002-86-2. The tubes are reused 2 times then recycled. • Linear Technology Corporation products do not contain or have termination finishes of Pure Lead or Pure Zinc. • Exemptions (as applicable) Linear Technology Corporation’s Device Material Declaration concentrations are estimated and are derived from engineering calculations. Linear Technology Corporation has a lifetime warranty on all our products, with Linear Technology Corporation standard liability • Dated limited to the replacement of confirmed defective products. Linear Technology Corporation’s ongoing Environmental Program will help ensure we are in compliance with our customer’s environmental needs. • Signature and Function _____________________________________________________ Paul Chantalat • Letterhead Vice President, Quality and Reliability LINEAR TECHNOLOGY CORPORATION ACCEPTS NO DUTY TO NOTIFY USERS OF THIS DECLARATION OF UPDATES OR CHANGES TO THIS DECLARATION. • Contact for further information LTC Revision 7 February 3, 2012 CONTACT INFORMATION: Name: Bobbi Bennett Title: QA Specification Review Manager and Product Environmental Specialist Email: bdbennett@linear.com • The final statement does not provide confidence in the long-term compliance Linear Technology Corporation, 1630 McCarthy Blvd, Milpitas, CA 95035-7417, 408-432-1900 C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 45. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Due Diligence and Testing – EN 62321Declaration and Test Report Sample Review Review points • Directive Stated • Note that this is in accordance with the “original” RoHS • Exemption is simply stated as exception with no detail • Dated • No Signature or Function • Letterhead • Contact for further informationC u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 46. AS SENTCOM PLIANCE info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044 Enforcement • Declaration of Conformity • Easy diagnosis of compliance • Technical File • Member State Enforcement Agency’s – first line of defense • RoHS material restrictions are MUCH easier and less destructive to test for than REACH • Be AWARE • Fines – member state by member state • Stuck at Customs • Rejected at Customs C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]
  • 47. AS SENTCOM PLIANCEinfo@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044Questions?Please submit your questions in writing using the Q&A tool along the top menu tool bar.Any questions not addressed during the Q&A portion of this webinar will be addressed in privatecorrespondence after the webinar.C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]