RoHS and Siemon's Commitment

RoHS stands for Restriction on the use of Hazardous Substances. It is the European Directive 2002/95/EC that published in the Official Journal of the European Union in February of 2003. This RoHS directive provides preventive measures on a legal basis to restrict the use of certain hazardous substances in various types of new electronic and electrical equipment.

Siemon has a long-standing reputation for its environmental consciousness. Over the years, it has won numerous awards including the William O. Jeffrey III Irmco Environmental Improvement Award, a CBIA Environmental Success Award, induction into the EPA's New England Star Track Program, State of CT DEP Green Circle awards, and ISO 14001:2004 certification.

Siemon has achieved full compliance with the RoHS Directive. Our compliance strategy includes:

Comprehensive systems that control inbound and outbound finished good and subcomponent material for all Siemon operations and stocking locations
Identification and qualification of RoHS compliant materials for all of our products.
Compliant product markings applied to packaging.

The execution of this strategy means that Siemon meets EU directive 2002/95/EC. Specifically:

All Siemon products shipped to EU Member States from our factories are fully RoHS compliant
All Siemon products shipped in packaging marked with the designation are RoHS compliant

In respect to the vast quantity of part number databases owned and operated by our distributors, installers and customers and because many of our products have never contained these substances, we have decided not to change finished good part numbers to reflect compliant product. During the transition period, specific compliancy requests can be directed to any regional Siemon sales office. For a list of regional contact information, please contact us.

RoHS Overview

The components used to build current electrical and electronic equipment may contain various hazardous substances and materials. The extraction of these hazardous raw materials and their eventual disposal can damage human health from occupational and disposal exposure as well as to pollute the environment.

As result of these concerns, the RoHS directive was created to protect human & animal health, reduce the occupational risk to recycling personnel, reduce the need for special handling and treatment, and place fewer toxins into landfills and the environment.

In addition, the RoHS directive is also closely linked with the Waste Electrical and Electronic Equipment (WEEE) Directive (2002/96/EC). Electrical and electronic waste (e-waste) is one of the fastest growing waste streams. To solve this e-waste problem, the WEEE directive was created to set collection, recycling and recovery targets for electrical products. The role of RoHS is to reduce harmful substances at the source, and it leads on to a further saving in recycling costs. RoHS references Annex 1A of WEEE to specify its scope of coverage.

RoHS is a Single Market Directive and as such must be implemented in the same way across all EU Member States. The directive goes into effect on July 1, 2006. Over time, this directive will likely be implemented in the national laws of each EU Member State.

RoHS is part of a growing wave of environmental regulations or "green" initiatives. It will be the most complex and expensive undertaking our industry has experienced and will have a direct and significant impact on the entire electronics industry at every level, from the retail store, to manufacturers, distributors, integrators, supply chain and OEMs as well as marketing and R&D etc. Manufacturing companies around the globe are finding that the RoHS compliance are costly and pose significant technical challenges. However, in order to ensure that their products can be freely specified and used throughout the world, view compliance as essential.

Understanding the RoHS Directive and associated Guidance Notes is the first step.

Restricted Substances

RoHS is often referred to as the "lead-free" directive, but removing lead alone will not achieve RoHS compliance. Currently, the RoHS directive identifies the following six restricted substances:

Lead (Pb). Ex. solder alloys, PCB coating, etc.
Mercury (Hg). Ex. fluorescent lamps and switches
Cadmium (Cd). Ex. switches, paint, etc
Hexavalent Chromium (Cr-VI). Ex. metal plating
Polybrominated Biphenyls (PBB). Ex. flame retardants
Polybrominated Diphenyl Ethers (PBDE). Ex. flame retardants

These restricted substances are known to be harmful to humans and animal health as well as the environment. Those restrictions are in addition to existing regulations, such as the 47 categories of dangerous substances restricted for use in nearly every product by EU Directive 76/769/EEC and its numerous amendments.

Lead is the first and the foremost substances detailed in the RoHS directive. It is a core component of the solder that goes into the manufacture of printed circuit boards (PCBs). The removal of lead from the PCB production process represents a challenge for the manufacturer. However, it is a trend that electronics industry is moving towards Lead (Pb)-free or green manufacturing.

In order to achieve RoHS compliance, manufacturers have to find some alternatives for the restricted materials. However, the RoHS/WEEE directives do not call for a total 100% elimination of these substances. RoHS has specified the maximum concentration values (MCV's) for each material.

Effective July 1st, 2006, producers of new electrical and electronic equipment must demonstrate that their products do not contain more than the maximum permitted levels which shown in below table:

Restricted Materials	Maximum Concentration Value (MCV)
Lead (Pb)	0.1% by weight
Mercury (Hg)	0.1% by weight
Cadmium (Cd)	0.01% by weight
Hexavalent Chromium (Cr-VI)	0.1% by weight
Polybrominated Biphenyls (PBB)	0.1% by weight
Polybrominated Diphenyl Ethers (PBDE)	0.1% by weight

The MCVs are limits set by the European Commission for each RoHS-restricted substance in the Commission Decision 2005/618/EC amending the RoHS Directive.

The MCVs are 0.1% by weight (1000 ppm) in "homogeneous materials" for lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenylethers, and 0.01% by weight (100ppm) for cadmium.

According to the commission, "homogeneous" material in defined as a material that cannot be mechanically disjointed into different materials. The term homogeneous is understood as "of uniform composition throughout". Examples include plastics, glass, and metals.

Remember, RoHS compliance is based on each homogeneous material and not components or devices.

Scope - Covered Product Categories

According to Directive 2002-95-EC (RoHS), the definition of "electrical and electronic equipment" (EEE) is equipment which depends on electric currents or electromagnetic fields in order to work properly as well as equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out in Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current.

The scope of RoHS or impacted electrical and electronic equipment category by this Directive is given in the EU WEEE Directive Annex IA, categories 1 -7 and 10. It also applies to additional household products:

Category 1: Large Household Appliances (Ex. fridges, washing machines, electric ovens)
Category 2: Small Household Appliances (Ex. vacuum cleaners, toasters, irons, clocks, scales)
Category 3: IT and Telecommunications Equipment (Ex. computers, photocopiers, telephones)
Category 4: Consumer Equipment (Ex. televisions, video recorders, hi-fi equipment)
Category 5: Lighting Equipment (Ex. fluorescent lamps, discharge lamps)
Category 6: Electrical and Electronic Tools (Ex. drills, sewing machines, lawnmowers)
Category 7: Toys, Leisure and Sports Equipment (Ex. video games and consoles, train sets)
Category 10: Automatic Dispensers (Ex. drinks machines)
Electric light bulbs
Luminaries/Light Fittings in households

Currently, medical equipment (category 8) and monitoring and control equipment (category 9) are exempt from RoHS requirements, but they will eventually be regulated (estimates in 2008 or 2009).

Exemptions

RoHS directive provides the following EXEMPTIONS from the restrictions and Scope of Coverage:

The Annex of the RoHS Directive provides a list of exemptions for certain applications of lead, mercury, cadmium and hexavalent chromium where no current alternative exists.

With the October 25, 2005 amendment to the RoHS Directive, the Annex exempts some additional applications from the ban in Article 4.1.

Large-scale stationary industrial tools.
There is also an exemption for spare parts used for the repair of equipment put on the market before 1 July 2006. The Regulations do not apply to the re-use of equipment placed on the market before 1 July 2006.
Aerospace, military and medical industry EEE are exempt from RoHS Directive, but may be subject to change later on.
Lead in solders for network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunication.

Note: Exemptions to the maximum allowed concentrations of restricted materials exist in cases of technology does not yet allow for substitutions, or when alternatives may have a worse impact on human health and the environment.

A lack of long-term reliability data for lead-free interfaces, the long life of the equipment, and the high costs of product failures drove the exemption for network infrastructure equipment. There is currently a great deal of research underway on lead free solder so this exemption may be eliminated in the future.

The list of exemptions is continually growing. Exemptions may be found in RoHS amendment and the RoHS Directive Annex. Information on further pending exemptions may be found at the UK DTI website.

Typically, the exemptions will be reviewed every four years.

Who will be affected?

The RoHS directive places the responsibility of compliance on the "producer" of the equipment. According to RoHS, the "producer" is defined as any person who, irrespective of the selling technique used, including by means of distance communication according to Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997 on the protection of consumers in respect of distance contracts:

(i) manufactures and sells electrical and electronic equipment under his own brand;

(ii) resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the 'producer' if the brand of the producer appears on the equipment, as provided for in sub point (i); or

(iii) imports or exports electrical and electronic equipment on a professional basis into a Member State.

Producers will be responsible for self-declaring if products comply with the RoHS directives or obtain material declarations or certificates from their suppliers. Producers must be able to demonstrate compliance by submitting technical or other information to the enforcing authority on request. They must retain such documentation for four years after the EEE is placed on the market.

Each European Union member state will adopt its own enforcement and implementation policies using the directive as a guide. Failure to comply with the requirements of RoHS Regulations will result in heavy fines, or the removal of manufacturers products from the market place in some EU member states. At this time, standard test methods to assess RoHS compliance are under development. The EU Member States have not communicated how they may ultimately test products for compliance.

Although RoHS is a European Union (EU) Directive, manufacturers of EEE outside Europe must also abide by this legislation if their produces are ultimately imported into a EU member state.

The RoHS Directive is a reality. Even if the manufacturer doesn't face regulation directly, its customers probably will, and they will push the requirements down to the manufacturer. Failure to comply will be a competitive disadvantage that can result in customer and market share loss.

Global Impact

The RoHS Directive is not only a single EC market directive; it's leading a worldwide shift to environmental regulation. Since it was introduced in 2003, the RoHS Directive has been a de facto global environmental standard for the world's electronics industry.

In addition to RoHS Directive for Europe, many other countries are making progress toward introduction of their own versions.

In the US, California's Electronics Waste Recycling act of 2003 (SB 20, Chapter 526) will use the RoHS Directive as its guide and scheduled to take effect January 1, 2007. Besides California, more than other 20 states are also creating various laws restricting the use of hazardous substances.

China's Ministry of Information Industry, near the time of the 2006 RoHS deadline, will release the "China RoHS" -The Administration on the Control of Pollution Caused by Electronic Information Products. It is currently scheduled to take effect on January 1st, 2007 and may contain more stringent requirements that the current RoHS directive.

Japanese companies have created a non-governmental group (i.e., Japan Green Procurement Survey Standardization Initiative-JPSSI) to standardize Japanese Green Procurement that is also considered to contain more stringent mandates than the RoHS directive. Further, many Japanese manufacturers are changing to lead-free technology as a result of recycling laws. 'Sony Green' is becoming an Industry Understanding.

Thailand has created a high-level governmental committee specifically to monitor the RoHS and WEEE Directives and develop a plan of action. Canada, Taiwan, Korea, and Australia are all in the initial stages of their own versions of the RoHS or WEEE directive, and many other countries can be expected to follow suit soon thereafter.

International companies that are seeking to expand globally must work to ensure that their manufactured products are RoHS or/and WEEE compliance.

Emerging Environmental Compliance Standards

Parallel to these EC directives, international standards / guidelines for environmentally conforming product development is under study. Examples include IEC/TC111, IPC1752, and IECQ 080000. The International Electrotechnical Commission (IEC) created technical committee TC111- Environmental Standardization of Electronic Products and Systems in 2004 to address a gap in emerging environmental legislation of Electronic Equipment. It currently has four work group projects (WG) underway.

WG1 - Materials Declaration
WG2 - Environmentally Conscious Design
WG3 - Test Methods for Six Restricted Substances
WG4 - Environmental Information

Pending the anticipated success and widespread acceptance of these industry standards, it can be expected that additional standards will be developed.

Reference and Resources:

European Commission:
http://europa.eu.int/comm/environment/waste/weee_index.htm
The Department of Trade and Industry (DTI) in the UK has played a major part in the original proposal, development and implementation of RoHS and WEEE. The DTI site also includes an up to date guide to the transposition of the WEEE and RoHS Directives for each EU Member State.
http://www.dti.gov.uk/sustainability/
National Weights & Measure Laboratory (NWML)
http://www.rohs.gov.uk/
The US Commercial Service provides some useful information
http://www.buyusa.gov/europeanunion/weee.html
A California Integrated Waste Management Board site with some useful information
www.ciwmb.ca.gov/Electronics
This link provides more guidance documents and includes a self-assessment/decision tree to see if the product falls under the scope of the RoHS Directive.
http://www.pb-free.info/survey/index.htm
This US association provides information about upcoming events dealing with WEEE/RoHS in the US.
http://www.aeanet.org/events/