With electronics equipment made using complex electronic
components such as highly integrated semiconductor ICs attained
pervasive nature, the use of harmful substances in components
is affecting the environment and health of living things
on earth. Responsible regions around the world are imposing
ban on substances causing hazard to life and to environment.
Regulations such as RoHS are well implemented in Europe.
Lot more new regulations are in the pipeline in many regions
of world.
New environment regulations and the challenges to meet
them are adding continuous pressure to the suppliers and
manufacturers. The design and manufacturing supply chain
has been pushed into a new uncertain territory due to the
growing number of regulations coming into effect. The number
of regulations and the list of hazardous substances also
grow thereby adding more burdens on the company in their
designing and redesigning efforts. Scrapped parts, customer
complaints and legal issues, downfall in sales and shipments,
and business blockages are few risks to face due to non-compliance
which could potentially lead to heavy revenue losses. Hence
adopting a successful environmental compliance management
solution in a company is one of the core competencies required
for developing compliant products and a successful environmental
friendly venture. The business cost of compliance products
is lower than the cost of non-compliance products because
of better market share, no legal or regulatory penalties
and strategic competitive advantage. Above all, it's about
caring the environment by producing environmental friendly
products.
The critical tasks in managing environment-compliance are
to understand the requirement of applicable regulations,
to collect the required information (data) on the hazardous
substances used in each material or component and to evaluate
the data for non-conformances and risks. Collecting and
managing the compliance data thus becomes extremely difficult
for the company and extra costs are involved. As mentioned
in the introductory
module, the required-right-recent-reliable compliance
information provides the essential metrics and guidance
to the company to demonstrate the product's compliance.
Awareness on the ready solutions available in the market
and their affordability can also help companies to quickly
implement compliance programs company-wide. Company's status
at the corporate level can be determined with the help of
a common solution implemented company-wide (even with the
help of 3rd party ready solutions) irrespective of the number
of factory locations and data sources.
Brief history:
The presence of innumerable substances and materials in
variety of electrical and electronic equipments in one or
the other form is quite evident. In the studies conducted
over years, it was identified that there were so many toxic
and hazardous substances present in the products. Adding
to the presence of the toxic substances, there were no recycling
plans, efforts and methods to dispose these products that
has created severe threats and damages to humans, bio-life
and environment. Harmful effects to humans include nervous
system failures, fall in children's IQ level, brain and
kidney damages, anaemia, lead poisoning, etc.,
Since more than a decade, regulations such as the European
Union's RoHS Directive 2002/95/EC, the China's Administrative
Measure on the Control of Pollution Caused by Electronic
Information Products, the Korea's Act for Resource Recycling
of Electrical and Electronic Equipment and Vehicles, the
State of California's Electronic Waste Recycling Act of
2003, etc., have been working on legislations in bits and
pieces. To create a hazard-free environment and to save
the next-generation, these directives guide the producers
and consumers to effectively and efficiently produce and
use environmental products respectively.
Directive on Batteries and Accumulators - The battery
directive comes in to effect from 18th March 1991 that targets
batteries and accumulators containing certain dangerous
substances. The directive requires batteries to be removed
from separately collected WEEE (Waste Electrical and Electronic
Equipment) and the current disposition within European Union
may introduce new requirements. The directive with 26th
September 2008 as the effective date of compliance seeks
to improve the environmental performance of batteries and
accumulators and all activities of producers, distributors,
end-users, etc., who are involved in the entire life cycle.
All the products containing rechargeable and non rechargeable
batteries are covered under this regulation irrespective
of the type, shape, volume, weight, material composition
or use of the batteries and accumulators. Harmonizing heavy
metal content and labelling through the EU and promoting
high level of recycling and collection is also required.
Packaging Directive - The scope of the EU Packaging
directive includes all packaging and packaging waste placed
in the EU market, whether it is used or disposed of in an
industrial, office, commercial, service, household, shop
or any other setting, regardless of the material used. The
directive lays down measures aimed at preventing the production
of packaging waste by reusing or recycling it thereby promoting
the usage of non toxic and bio-degradable packaging materials.
The effective date of packaging compliance was effect from
30th June 1996. The producers are required to take all necessary
measures to minimize the environmental impact without compromising
the essential functions of packaging and are required to
provide the competent authorities with reliable data on
the type and amount of packaging materials used; including
the toxicity information or danger of packaging materials
and components used for their manufacture.
ELV - The directive on End-of-Life Vehicles poses
general ban on lead with effect from 1st July 2003 as well
as ban on mercury, cadmium, and hexavalent chromium. The
directive offers electronic solder as an exemption and can
use Pb; Non-electronic solder is not exempted and cannot
use Pb; Component coatings are not exempted unless they
become part of the solder joint during processing, etc.,
Directive on BDEs - The prohibition of marketing
and usage of dangerous penta-BDE and oct-BDE (bromodiphenyl)
in a substance or article of levels above 0.1 wt% is the
prime requirement of this directive formed on 6th February
2003. These two BDEs should no longer be used in plastic
housings.
WEEE - The main objective of this directive Waste Electrical
and Electronic Equipment is to prevent and reuse, recycle
and recover WEEE to reduce the disposal of waste and to
improve the environmental performance of all operators involved
in life cycle of electrical and electronic equipment. The
directive places minimum recycling requirements and additional
stringent guidelines can be imposed by the EU member states.
The member states' requirements may be tougher and with
a different financing basis. The document and subsequent
revisions state that producers must register their products
by 13th August 2005 and plan for recycling for compliance
with recycling laws with individual member states. Producers
will be responsible for taking back and recycling their
products.
WEEE is applicable for the following product categories:
1. Large household appliances
2. Small household appliances
3. IT and Telecommunication equipment
4. Consumer equipment
5. Lighting equipment- Light bulbs and luminaries
6. Electrical and electronic tools (with the exception of
large scale stationary industrial tools)
7. Toys, leisure & sports
8. Medical equipment systems (with the exception of all
implanted and infected products)
9. Monitoring and control instruments
10. Automatic dispensers
RoHS (Restriction on the use of certain Hazardous
Substances)-has come in to effect to assist the recycling
efforts set forth by WEEE. The new electrical and electronic
equipment put on the market from 1st July 2006 must not
contain restricted substances. The directive restricts the
usage of hazardous substances which have adverse effects
on human health and the environment. The maximum allowable
concentration values in weight percent per homogeneous material
is given below.
1. 0.1% for Lead, Mercury and Hexavalent Chromium
2. 0.01% for Cadmium
3. 0.1% for PBB and PBDE flame retardants
There are exemptions permitted by the directive and these
exemptions are reviewed at least every 4 years.
China RoHS - China RoHS applies to the products manufactured
after 1st March 2007 and the regulation is intended to prevent
accumulation of toxic substances to health elements and
substances in the environment. China RoHS is similar to
EU RoHS but with few major differences. The China RoHS covers
the same six restricted substances as of the EU RoHS. The
additional requirements are classified in to 2 phases, Information
Disclosure and Material Restrictions. The 1st phase includes
labelling (green and orange) and packaging recycling remarks.
The 2nd phase includes Electronic Information Products (EIP)
listed in the "living" catalog must comply with
the hazardous substances ban and are subjected to China's
Compulsory Certification (CCC) and labelling requirements.
Additionally, requires testing using government approved
Chinese labs.
EuP - The Energy using Products directive requires
producers to design products to meet specific eco-design
criteria over entire life cycle effective 11th August 2007
for certain specific products. The directive regulates the
products that have sales of over 200,000 units per year
in the EU, have a significant environment impact over their
entire life cycle, and present significant potential for
improvement. Also, the implementing measures must not have
a "significant negative impact" on product's price
or performance or on the competitiveness of EU industry.
Korea RoHS - The South Korea's RoHS/WEEE legislation
was effected from 1st July 2007 and is termed as "the
Act for Resource Recycling of Electrical/Electronic Products
and Automobiles".
Norwegian PoHS - Norway has proposed to restrict
18 substances in anything intended for consumers or products
that can reasonably be expected to be used by them. The
products include clothing, bags, toys, food packaging, medical
equipments, fertilizers, tobacco, means of transport, and
does not apply to food products. The legislation "PoHS"
refers to "Prohibition on certain Hazardous Substances"
in consumer products.
REACH - The European REACH regulation (Registration,
Evaluation, and Authorisation of Chemicals came in to effect
on 1st June 2007 and is applicable to manufacturers, importers
and users of chemical substances on their own or contained
in preparations, or in products. REACH requires compulsory
registration of all chemicals sold, imported, manufactured,
or used in articles that are manufactured or imported into
the EU. REACH replaces about 40 existing legislations by
improving the knowledge on the risks posed by chemicals,
with the aim of using them in a safe way. In addition, the
regulation authorises the use of or set restrictions on
the manufacture, placing on the EU market and use of toxic
substances, preparations and articles.
The scope of the regulation is broad and applies to substances
(elements and compounds) on their own, in preparations (mixtures),
or in articles (products). Waste and radioactive substances
are exempt while REACH's provisions do not apply to substances
addressed in other legislations (including food, medicine,
and medical products for humans, animals and cosmetics),
or listed substances with known risks (water, CO2) or found
in nature (minerals, coal).
DfE - Design for Environment offers a structure to
define, configure, measure and reduce the environmental
impact of the products and product packaging. Key measurements
covered by the DfE are Energy use, greenhouse gases, raw
material input, bad actor chemicals, recyclability and carbon
footprint.
RoHS Recast - There have been changes to the exemptions
listed in the RoHS directive and in 2010, the European Union
had agreed to a range of these changes to the directive.
The new version known as "Recast" will take effect
during the following seven years. All exemptions are temporary
and they will be reviewed at least every four years. The
exemptions of the recast RoHS directive will expire on 21
July 2016 unless an earlier date is mentioned against each
of the exemption. RoHS will become a CE marking directive
applying to the finished goods where manufacturers, importers
and distributors are responsible for some or all of the
compliance activities. So, compliance information maintenance
(record keeping) is very much essential as most of the obligations
are to produce documentation that can be assessed by the
enforcement bodies.
India WEEE and India RoHS - The "e-waste (Management
and Handling) Rules 2011" has been published which
comes into effect from 1st May 2012. The regulation is considerably
similar to EU WEEE and RoHS in terms of scope, exclusions,
etc. and is a joint legislation (not separate for WEEE and
RoHS). The regulation does not apply to micro and small
enterprises. Batteries and radio-active waste are out of
scope.
India WEEE defines the responsibilities of the various entities,
producers, consumers, collection centres, dismantlers and
recyclers with the procedures for obtaining registration
and authorisation from the pollution control entities including
sample forms. The storage of e-waste is permitted only for
a period of 180 days and the labelling is similar to that
used in the EU, except the black bar under the crossed out
wheelie bin is not required.
India RoHS restricts the same six substances including their
maximum concentrations as that of the EU RoHS but the scope
of products is different. The RoHS requirements enter in
to force from May 2014.
The equipment manufacturers or the producers need to declare
their products that they are compliant with the applicable
regulations. Declarations of compliance for materials, components
and other parts are obtained from the original suppliers
by the producers and they should be maintained for a minimum
of 4 years. The declarations, in the past, were in the form
of lab test reports/certificates, CoCs (certificate of compliance),
IPC-1752 declarations, custom reports (includes JIG data),
etc., Of late, newer regulations coming to picture, the
suppliers are preferring and declaring full material disclosures
in industry-standard format (say, IPC-1752) so that the
costs and efforts of re-testing and re-qualifying for the
changing regulations can be minimized. The material composition
information can help manufacturers to satisfy legal and
regulatory requirements, improve product designs, and respond
to inquiries from customers and stakeholders.
Learn more in India e-waste initiative at http://www.moef.nic.in/downloads/rules-and-regulations/1035e_eng.pdf
Sustainable Manufacturing - Sustainable manufacturing
approach promotes the concept of "reduce, reuse and
recycle" to preserve the environment and the natural
resources. There is a need for the companies to adopt clean
and lean practices in developing green products that serves
the present need as well as the future generation does not
have any adverse effects by these products. The smarter
approach in managing environmental compliance is by avoiding
the usage of hazardous substances or usage within the allowable
limits; recycling the e-waste under controlled environment;
reusing the applicable scrap materials after proper treatment;
disposing the harmful substances and materials as per the
regulations; finally using the green materials and products
alone in the entire supply chain. The future point where
all the environmental regulations directed are "the
manufacturing for sustainability and the sustainable manufacturing".
Author:
S Jaya Kumar, Consultant, Component Supply Chain Management
Conatct
him at:
Find below links to other parts of
the article on the same subject of smart component sourcing:
Part1:Smart
component sourcing is about green, clean, rugged, and the
$:The basics of
modern component buying methodologies are explained in these
series of articles.
Part2:
Counterfeit components: Methods to protect against fake
parts: Save reputation,
severe loss of time and money by not buying fake parts
Part4:
Electronics component supplier and device selection guide:
Evaluation and selection of semiconductor IC chips and other
parts and their suppliers
Part
5: The principles and process of electronic component selection:
Component Selection; "an art" for SMART and cost-effective
designs
Part
6: Electronic components Life Cycle management:
Methods to manage sourcing issues of obsolete components
