environmental regulations (rohs) and their effect on industry

1

Global Standards & Trade GroupCopyright © 2007 Rockwell Automation, Inc. All rights reserved.

(Confidential – For Internal Use Only)

Environmental Regulations (RoHS) and their effect on IndustryRon CollisRockwell AutomationGlobal Standards and Trade GroupAsia Pacific Region

2Global Standards & Trade Group(Confidential – For Internal Use Only) Copyright © 2007 Rockwell Automation, Inc. All rights reserved.

Agenda

• Who is Rockwell Automation?• Economies, Regulations and Definitions• Forbidden materials• Governmental Activity• How does this effect Industry (Rockwell

Automation)• Recommendations• Discussion


Who is Rockwell AutomationRockwell Automation is US 5 Billion Dollar Electrical Controls manufacturing

Company.

What does Rockwell Automation manufacture?– We manufacture Factory Automation products; these are Electrical and Electronic products

used to control the manufacturing processes• These products control Electric motors on pumps, fans, conveyor• Control production quantities, volumes• Monitor product quality and volumes• Initiate Recipes and batch processes.

What are these products?– Motor starters, Variable frequency Drives for Motors, Power and energy Monitors,

Programmable Controllers, Industrial Computers, Operator screen devices, message displays, sensor products.

What is my roll in Rockwell automation?– Identifying new standards initiatives that may impact RA products

• Developing industry positions on key initiatives. • Understanding different economies Regulations• Promoting common Certification Stratergies.

– Assists BU coordination of strategic standards participation, Certification activity for AP and provide Regulatory


Agenda

• Who is Rockwell Automation?• Economies, Regulations and Definitions• Forbidden materials• Governmental Activity• How does this effect Industry (Rockwell



Asia Pacific Environmental Regulations.

New Regulations affecting Industrial Automation products are New Regulations affecting Industrial Automation products are increasing. increasing.


Regulation by CountryCountry requirements that impact our ability to sell and our

customers’ ability to ship product.– China RoHS (MII)

• Major activity with RA to label Electronic Information Products (EIP).

– Korea RoHS (ME, MCIE, MC&T)• Legislation has been passed to allow Regulations to be

established. On their second draft of this legislation.– Japan RoHS (METI)

• implemented Japan-specific labeling requirements only This is much broader and cover RoHS, WEEE, Packaging


Regulation by Country

Country requirements that impact our ability to sell and our customers’ ability to ship product.– Australia RoHS

• Government is reviewing a RoHS Strategy for the whole country.– Taiwan: Considering RoHS Legislation


Definition of producer

• Manufacturers of electrical or electronic products• Importers of electrical and electronic products• Retailers/distributors who sell their own branded products • Assembly companies selling their own branded products.


What is a homogeneous material?• A homogeneous material is a single substance such as a plastic, for example the PVC insulation on

insulated copper wire. Components such as capacitors, transistors and semiconductor packages are not "materials" but will contain several different materials. For example, a semiconductor package will contain at least six as shown below.


Agenda

• Who is Rockwell Automation?• Economies, Regulations and Definitions• Restricted materials• How does this effect Industry (Rockwell

Automation)• Governmental control?• Recommendations• Discussion


RoHS materials and there concentrations

• Maximum concentration in homogeneous materials of the 6 substances.

Substance Maximum concentration

Cadmium (Cd) 0.01% (100 ppm)

Mercury (Hg) 0.1% (1000 ppm)

Lead (Pb) 0.1% (1000 ppm)

Hexavalent Chromium (Cr 6+) 0.1% (1000 ppm)

Bromium flame-retardants (PPB, PBDE) 0.1% (1000 ppm)


Lead (Pb)

• Used in: Solder, pigment, stabilizer in plastic, glass

• Exemptions (EU):– For glass in CTR’s, electronic components and fluorescent tubes– Alloying element in steel, Aluminum and Copper alloys– Solders:

• High temperature solders• For servers, storage and storage array systems • For network infrastructure

– Ceramic parts (Piezo-electrics)

Companies have indicated that to meet compliance with various lead restrictions, alone, The costs are in the billions of dollars.


Cadmium (Cd)

• Used in; Contacts, Pigments, Electroplating, Metal coating

• Exemptions (EU):– Cadmium plating (but NOT if covered by the Cadmium Directive 91/338/EC)


Mercury (Hg)

• Used in; Tilt switches, sensors, fluorescent and discharge lamps

• Exemptions (EU):– Different kind of Fluorescent lamps

http://www.tlc-direct.co.uk/Images/Products/size_3/SR501.JPG


Chromium Vl or Hexavalent Chromium (Cr6+) • Used in; Coatings on metals, Primers, Pigments

• Exemptions (EU): – Anti- corrosion agent for the carbon steel system cooling system in absorption

refrigerators


Bromium flame retardants (PBB’s and PBDE’s)

• Used in; Fire retardants in polymers– Wire insulation– Polymer at higher temperature

• Exemptions (EU):– Deca-BDE

PBB PBDE


Agenda

• Who is Rockwell Automation?• Directives, Regulations and Definitions• Forbidden materials • Government activity• How does this effect Industry (Rockwell



EU RoHS: How do I demonstrate compliance?example UK

• The criteria for analysis will depend on the quantity of product put onto the market, the relationship with suppliers, the risk of banned substances being present, and the potential environmental impact. The UK Regulator recommends using suppliers’ declaration - producer analysis is more suited for specific or unique cases - but in both cases relevant records should be kept for four years after the EEE product was placed on the market. The UK government accepts this approach as a way of demonstrating due diligence.

• Penalties– Failure to comply with the requirements of the UK’s RoHS Regulations will result in the

removal of manufacturers’ products from the market place. In addition, those held responsible face, on summary conviction, a term of imprisonment not exceeding three months and/or a fine of up to £5,000. Where any offence is tried on indictment, the maximum penalties are a term of imprisonment of up to two years and an unlimited fine.”


EU RoHS - A Prediction

Category 3IT & Telecomms

Category 9Monitoring & Control Instruments Excluded

Industrial Computers, Monitors and Accessories

PLCs, Drives, Motor Controlgear, Sensors, PanelViews, Message

Displays

Portable Devices(for data entry retrieval, program

storage, etc.)Jul

y 200 6

Industrial Computers, Monitors and Accessories


Displays


storage, etc.)

201 0

NOTE If intended for incorporation within equipment that needs to comply with RoHS, then the RA product also needs to comply

20

1 X Industrial Computers, Monitors and Accessories


Displays


storage, etc.)


It's not Just Another RoHS. It's CHINA RoHS!Key Differences: •Two phase approach•The scope is different •The requirements are different •There are no exemptions •Labels and marks are required •The concept of "Put on the market" is different •The penalties are different •The responsibilities dictated by the law are different •Material testing down to the homogeneous materials in every single part you use to build your product may be required •You will have to design labels, issue change orders, and assess inventory in order to comply •The standards that you have to comply with are Chinese sector standards

Key requirements of China RoHS


China RoHS Phase 2 Testing of Products will be required to be undertaken at one of the some 23 ( Ministry of Information Industries (MII) designated test Laboratories located in ChinaTesting to a Chinese sector Standard as no International standard exists as these rules go into effect. A Catalogue of effected products will be issued towards the end of 2007. There will be no exemption issuedThere will be a Grace period between the issue of the catalogueCCC Marking of the product will be requiredWill the labelling requirements of phase 1 go away?In country survaillance will be undertaken


Japan RoHS

•Japan feels the methods to decide maximum permissible values (thresholds), scopes for exemption in enforcement are ambiguous with EU RoHS.•The Chemicals/Compounds are the same as for the EU RoHS directive.• Products mentioned in the legislation are IT equipment.• Products must be designed with Recycling in mind.• Information on how to recycle effected products must be supplied to the Recycler if it is requested• Will have limited effect on RA products as the legislation stands at the present time• Voluntary at present•Japan to undertake a risk assessment on health of humans and on environment of the effect of these chemical substances.


Australia RoHS

•The Australian Government commissioned a Study on RoHS last year (2006).

• The results of that study have not been made public as was promised.• Good news here, The Australians haven’t worked out what to do yet!

• If and when they do it will based on the six substances nominated by the EU and being referenced by China, Japan and Korea•What rules will be used to enforce such legislation has yet to be determined.

•RA is at this table and discussion continue.


Key Requirements of Korean RoHS

• On their second draft of this legislation.• The Chemicals/Compounds are the same as for the EU RoHS directive.• Products mentioned in the legislation are IT equipment.• Products must be designed with Recycling in mind.• Information on how to recycle effected products must be supplied to the Recycler if it is requested• Will have limited effect on RA products as the legislation stands at the present time• Become effective on 1 January 2008Industry would like all Economies to have a

harmonised version of RoHS


Agenda

• Who is Rockwell Automation?• Economies, Regulations and Definitions• Forbidden materials• Governmental Activity• How does this effect Industries (Rockwell



What to do?

• As manufacturers/producers, we are expected to exercise ‘due diligence’ to ensure none of the restricted substances are present in each homogeneous (component) element of the equipment we place on the market.


What to do?!

1. For differing economies, the RoHS type regulations may differ. 2. For Multiple markets there maybe differing ways to determine the

levels of restricted materials.3. Manufacturers will require multiple checks of component

supplier’s components for differing levels of Hazardous material4. Component suppliers will have show evidence by declarations5. This may require checks of these declarations via testing.6. It may lead to products being specific to a particular market, (modify

replace, redesign).7. Require multiple labelling of products.


The number in the center of the logo is the “Environment Friendly Use Period”

o This logo indicates that the six hazardous substances are not present in the product or are present in levels not exceeding the maximum concentration values.

oThe other logo indicates that one or more of the six hazardous substances are present in the product at levels exceeding the maximum concentration values. If the size of the Rockwell Automation product is too small to display the Logo at the required size, the Logo will be included in the product literature. An example of the logo is given below.

There is a labelling requirement to indicate whether the Six chemicals/compounds are present within the product

China Labels


Japan labels

Law and Regulation 　　　　　 (Legal

Requirement)

JIS 　(Operation Rule)

6 Substances Contained

6 Substances Not contained

Marking Legal requirement for marking and

information disclosure 　　　　Materials contained are indicated by mark

Operation rules (specific requirements) by JIS

Marks indicated for reference purposes Annex 4 (for reference purposes)

Optional marking Needs be stipulated specifically by JIS 1. For consumers and recyclers2. Marked on materials other than affected materials also


Rockwell product Label


China RoHS content label

• If a Electronic Information Product (EIP) contains more that the maximum concentration of the 6 designated chemicals/compounds;

• A Hazardous contents label table must be fixed to the product indicating what chemicals are in excess of the maximum level within the product.

Part Name

Lead(Pb)

Mercury(Hg)

Cadmium(Cd)

HexavalentChromium

(Cr6+)

Polybrominatedbiphenyls

(PBB)

Polybrominateddiphenyl ethers

(PBDE)

Housing X O O O O O

Display O X O O O O

Printed Circuit Board X O O O O O

Metal Fasteners O O X O O O

Cable Assembly O O O X O O

Fan Assembly O O O X O O

Power Supply Assemblies X O O O O O

Battery O O O X O O

A label indicating the date of EIP manufacture is also required and will be in the following format:

“YEAR, MONTH, DAY”


Japan RoHS content label

• If a Electronic Products contains more that the maximum concentration of the 6 designated chemicals/compounds;

• A Hazardous contents label table must be fixed to the product indicating what chemicals are in excess of the maximum level within the product.

Part Name

Lead(Pb)

Mercury(Hg)

Cadmium(Cd)

HexavalentChromium

(Cr6+)

Polybrominatedbiphenyls

(PBB)

Polybrominateddiphenyl ethers

(PBDE)

Housing X O O O O O

Display O X O O O O

Printed Circuit Board X O O O O O

Metal Fasteners O O X O O O

Cable Assembly O O O X O O

Fan Assembly O O O X O O

Power Supply Assemblies X O O O O O

Battery O O O X O O


Effect of RoHS Regulations on Industry

Non Harmonised Regulations can be disruptive• Even minor differences between an International Standards and a National

Standard/Regulations will cause significant problems for the sales persons– Loss of particular market segment.– Consultants will not recommend products that do not indicate the meeting a particular

standards requirements.• Increased costs in proving that the product does comply with the local

standard/Regulations which may involve additional local Testing


Effect of RoHS Regulations on Industry

When faced with different country compliance systems, companies across supply chain find it extremely costly to operate several production lines at one time.

Restriction of market access – potential for Technical Barriers to Trade if not implemented uniformly

Potential civil and criminal liability for noncomplianceCosts of supply-chain management

More stringent materials content management Reporting and TestingThis will be a huge administrative BurdenAll these extra cost will end up in the price

of the product.

OEMs/Distributors will pass liability to suppliers through contractsOEMs will not purchase non-compliant parts


Agenda

• Who is Rockwell Automation?• Economies, Regulations and Definitions• Forbidden materials• Governmental Activity• How does this effect Industries (Rockwell



• In those APEC economies that have adopted or are about to adopt RoHS-type requirements, those economies should consider harmonizing regulated conformity assessment requirements to facilitate trade of the same RoHS-compliant products globally by;

– Harmonizing with other relevant international standards, including restricted substances lists, allowable limits, analytical testing standards and conformity assessment activity

– Harmonizing of exemptions for technically-justified applications of restricted substances;

– Avoiding country-specific marking and labeling requirements;

– Minimizing or, where appropriate, eliminating unnecessary divergence in requirements (In Country Deviations);

Recommendations

37

Global Standards & Trade GroupCopyright © 2007 Rockwell Automation, Inc. All rights reserved.

(Confidential – For Internal Use Only)

APEC recommendations can be used as a baseline for future standard development on this issue.

If you need additional information contact me at

[email protected]

environmental regulations (rohs) and their effect on industry

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