Professor Dr. Kun-Mo Lee 13 August 2007 Green Manufacturing Seminar Hong Kong

Transcription

1 Korea's Experience on Managing RoHS Compliance Professor Dr. Kun-Mo Lee 13 August 2007 Green Manufacturing Seminar Hong Kong

2 EU RoHS update

3 The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2006 ( the RoHS Regulations ) in UK Came into force on 1 July 2006 Implemented the provisions of the EU RoHS Directive 3

4 31 exemptions so far (Hg: 4, Pb: 24, Cd: 2 (1 with Pb), Cr: 1, PBDE: 1) A decision tree ; whether or not a product is within the scope of RoHS Needs electric currents or electromagnetic fields to work? Less than 1,000v AC or 1,500v DC? Fits within one of the 8 product categories? (lighting equipment, ) Covered by a specific exemption? Intended for a specific national security and/or military purpose? Main power source is electricity? Electricity is needed for primary function? Forms part of equipment not included in product categories?

5 Put on the market" is not defined in the Regulations or in the Directive, but it is being interpreted in the same way as the term placing on the market, The initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community. A product is placed on the Community market when it is made available for the first time.

6 Homogeneous material A material that cannot be mechanically disjointed into different materials. homogeneous "of uniform composition throughout", Examples of "homogeneous materials" individual types of plastics, ceramics, glass, metals, alloys, paper, board, resins and coatings. mechanically disjointed the materials can, in principle, be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.

7 Self-declaration Producers of EEE could obtain an assurance from their suppliers that any materials, components, assemblies or equipment provided do not contain more than the permitted level of any of the six restricted substances 7

8 Assessment of materials declarations and suppliers analysis certificates Declarations and analysis certificates must be assessed for accuracy. Declarations and analysis data based on homogeneous materials A statement that all six RoHS substances are absent and a list of maximum concentration values If an exemption is utilized, a statement to that effect specifying which one this is Supplier name and contact details 8

9 Producers must be able to demonstrate compliance by submitting technical documentation or other information to the enforcement authority on request and retain such documentation for a period of four years after the EEE is placed on the market. 9

10 Various powers of enforcement: Making test purchases Requesting compliance documentation, inspecting processes and performing analytical tests Issuing of a compliance notice requiring certain action to be taken 10

11 Which EEE categories and products to be selected for further investigation? Decision criteria Market intelligence Random selection Products known to contain materials of high concern; High volume products Short life products Consumer products unlikely to be recycled Notification of concern from external parties Notification of concern from other Member States 11

12 RoHS Penalty 2003/02/ /07/ /02/ /08/ /02/ /07/01 RoHS directive became EU law 18months National legislation of member states and its implementation 24 Months lead, mercury, cadmium, Cr +6 PBB, PBDE banned [ 06.3] Type Stage Custom entry Wholesale End user Monetary fine England, Hungary, Italy, Spain, Sweden, Switzerland, Cyprus, Portugal, Slovakia, Lithuania, Latvia, Estonia Austria, Germany France Finland, Belgium Punishment England, Switzerland, Cyprus Denmark Belgium Prohibition on sales, Product recall Poland, Portugal, Spain, Sweden Germany, Czech Ireland, Belgium Others Greece, Luxembourg, Malta Netherlands, Norway Slovenia Offences and penalties; UK s leading (Individuals might be punished) Contravening or failing to comply with the regulation 5,000 on summary conviction Failing to submit compliance documentation fine up to level five on the standard scale 12

13 Korean industry activity A company Case A product case Response to RoHS RoHS response examples

14 A company case 14

15 RoHS Compliance Product Roadmap Users and global status Eu RoHS Eu WEEE RoHS Mark Chip resistor Production of lead free Production of lead free SVS parts Lead free parts with existing P/N

16 RoHS Compliance Y : Under the Limit (COMPLIANT) E : Exemptions (COMPLIANT) N : NOT COMPLIANT RoHS Compliant for Material Listed RoHS information Soldering conditions Product Cd Cr+6 Pb Hg PBB PBDE Status Date code MLCC Y Y Y Y Y Y Y Tantalum Capacitor Chip Resistor Chip Inductor Y Y Y Y Y Y Y Y Y E Y Y Y Y Y Y Y Y Y Y Y Chip Beads Y Y Y Y Y Y Y 2003/08/ /02/ /08/ /08/ /08/0 1 MSL Rating Maximum temperature Plating of terminals of RoHS X 260 C Matte Sn C Matte Sn X 260 C Matte Sn X 260 C Matte Sn X 260 C Matte Sn Remark Important remarks : - Use PbO in glass frit of chip resistor. Annex 5 of RoHS indicate that the Pb in glass of electric components is exemption material. 16

17 Quality System Certification of a company Plant A Plant B Plant C Plant D ISO/TS16949 BSI TS [MLCC] BSI TS [MLCC] BSI TS [MLCC/ CR/ TC] ISO 9001 [Product] UL A14163 [MLCC/ CR] TL 9000 [Product] BSI FM90588 [MLCC/CI] ISO14001 BSI EMS BSI EMS BSI EMS CNAB 02103SI0055ROL OSHAS18001 BSI OHS BSI OHS CCEMS 012RO 17

18 A product case - CHIP Capacitor 18

19 Internal structure INNER ELECTRODE(Pd or Ni) TERMINATION Ag or Cu (Contact with Body) Ni (Barrier Layer) Sn (Matte Tin) CERAMIC BODY (CaTiO3 or BaTiO3) 19

20 RoHS status Material Analysis Table. RoHS compliance of the chip capacitor RoHS Substance USE (O/X) Content (ppm) Lead and its compounds X Not Detected Mercury and compounds X Not Detected Hexavalent Chromium X Not Detected Cadmium and its compounds X Not Detected Polybrominated biphenyls(pbbs) X Not use Polybrominated diphenyls ethers(pbdes) X Not use Analysis Report by Other agency 20

21 Response to RoHS 21

22 BUYER TRENDS on the request of hazardous substance information phase year scope contents Ⅰ '95.6~'99.12 Cleaning agents used in unit processes Use of ozone layer depleting substances Ⅱ '00.1~'01.12 Restricted use substances in the products Regulated heavy metals and others Ⅲ '02.1~'02.6 type and content of major materials and substances in processes and products (including certificate) If regulated substances are used, show their content Ⅳ '02.7~ type and content of all materials and substances in processes and products (including certificate) Information disclosure on the composition of the entire product - mass basis/ application/composition 22

23 Information (document) requested by BUYER NO. Document Description 1 EMS certificate 2 Non use certificate certificate that do not use six RoHS hazardous substances (Pb, Cd, Cr+6, Hg, PBB, PBDE) Mandatory requirements for supply of products to all buyers Meeting the criteria set by the buyer on the six RoHS hazardous substances proof that those six were not present in the materials used for the product Description on the use of raw materials Analysis results of hazardous substances Environmental improvement plan Hazardous substance analysis certificate (icp) Pb free reliability test Necessary to trace hazardous substances Preparation in accordance with the form by the buyer (no acceptable to modify the form) proof that satisfies the requirements on the restricted substances set by the buyer Preparation in accordance with the form by the buyer (no acceptable to modify the form) Notify buyer corrective measures and implementation schedule for the parts which exceeded the concentration limit of the hazardous substances set by the buyer certificate issued by a certified laboratory expired period : 1 year within 6 months since issued date Solderability Flow / Reflow Profile Tin Whisker test 23

24 Case 1 : Letter of Warranty supplier name Signature by CEO 24

25 Case 2 : Non-use certificate 25

26 Case 3 : Analysis report of environment-related related substances PART NO location Material used in the part N.D (Not Detect), or Concentration if detected 26

27 RoHS response examples 27

28 Case 1 of environmental compliant Company : A Detail : Cd/Cr detected above the limits Detected concentration : Cd - >250 ppm / Cr >3000 ppm Test tool : SEA 1000A X-RAY XRF After : claim that XRF error had occurred in testing verified by ICP test 28

29 Case 2 of environmental compliant Company : B Detail : Cd/Cr detected Test tool : X-RAY XRF After : claim that XRF error had occurred in testing verified by ICP 29

30 Example - Samsung Electro-mechanics LANGUAGE: Korean/English CLICK: By Application Web site URL [

31 Example - Samsung Electro-mechanics CLICK: target product

32 Example - Samsung Electro-mechanics CLICK: Certificate/ Environment

33 Example - Samsung Electro-mechanics BUYER G/P Certificate ISO certification status of the factory

34 Example - Samsung Electro-mechanics Material composition table Test results

35 Korea RoHS Key Points of the ACT Countermeasures of SEC

36 Key Points of the Act (The Act for Resource Recycling of Electrical/Electronic Products and Automobiles) Enforcement: January 1 st, 2008 (the date of manufacture/import) Target products: TV, Refrigerator, Home washing machine, Air-conditioner, PC(including monitor), Audio, Mobile phone terminal, Printer, Copier, Facsimile / A passenger car, Van, Truck The system of the Act Current system E/E Products Automobiles System under ARREA E/E Products Automobiles Recycling policy (prior) Recycling policy (posterior) Recycling guidelines for the merchants dealing with substances and structures Extended Producer Responsibility No Policy Recycling policy (prior) Recycling policy (posterior) The Act for Resource Recycling of Electrical/Electronic Products and Automobiles(ARREA)

37 Key Points of the Act Prior prevention provision 1. Type of restricted hazardous substances: same as EU RoHS(exemption included) Official announcement of observance of the hazardous substance content standards (The declaration form announced in accordance with the Ordinance) Announcement method & time( self evaluation & its official announcement ) - Announcement method 1 Post the announcement on the operation and management information system or 2 Post the announcement on the company website managed by the manufacturer or importer of E/E products or automobiles ( should be notified to the authority) - Announcement time 1 For manufacturer: within a month from taking goods out of warehouse 2 For importer: within a month from the date of an import declaration Announcement shall include information below - Manufacturer information : manufacturer name, contact point, etc. - Product information : product type, product name, product no., release year, etc.

38 Key Points of the Act 2. Provision of recycling information Shall provide recycling information Methods & announcement time - Methods 1 Post the recycling information on the operation and management information system 2 Post the recycling information on the company website managed by the manufacturer or importer of E/E products or automobiles 3 Provide in document ( including electronic document ) 4 Provide in electronic medium where the data is stored - Announcement time : within 6 months from the date of receipt of request for information Announcement shall include information below - product information, disassembly/ dismantling procedure,.. - substance composition of the synthetic resin parts, the location of hazardous substance should be removed and removal methods,.. - Efficient treatment of parts and recycling methods,..

39 Key Points of the Act Operation and Management information system; prior prevention Administration body Self declaration & announcement Provision of recycling information Request submission of information for confirmation Submission of information necessary to verify the compliance Provision of recycling information manufacturer/importer Product design & manufacturing Removal of hazardous materials Assessment for recyclability Preparation for provision of recycling information Product sale & distribution Provision of recycling information Recovery & recycling business [Recovery & recycling of wastes] < Source : MoE >

40 Key Points of the Act Additional information - Committee on environment-friendliness/recyclability of the products Role; review the restricted hazardous substances, improvement on materials/structure of, required recycling rate, target product Composition; the relevant authorities, experts and representatives - Operation and management information system Verify whether the manufacturer carries out his obligations according to the law Promote the related training program and activities -Fine Impose a fine in violation of ARREA (1million KRW~ 30 million KRW ) Further schedule - Announcement of an enforcement ordinances and regulations - Preparation of operation and management information system

41 Countermeasures of SEC Prior Prevention Provision Restriction on the use of hazardous substances - Post self declaration of new products from 1 st January 2008 Improvement proposal on materials/structure of the product Verify compliance with the same law which has been taken effect since Provision of recycling information - Preparation of recycling information for the standard model of the product Post recycling information required on the company website

42 Prof. Dr. Kun-Mo Lee