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Global RoHS Compliancefor Home Appliance Manufacturers
ASTM International Technical Committee A05 – Metallic-Coated Iron and Steel Products
May 23, 2007
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OutlineWhirlpool Corporation OverviewRoHS OverviewCurrent and Pending RoHS ProgramsPolicy ImplicationsCompliance with RoHSConclusion
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Whirlpool Corporation OverviewLargest global manufacturer and marketer of major home appliancesAnnual sales of more than $18 billion73,000 employeesOver 70 manufacturing and technology research centers around the
globeMarket Whirlpool, KitchenAid, Maytag, Jenn-Air, Amana, Brastemp,
Bauknecht, Consul and other major brands to consumers in more than 170 countries.
Additional information at www.whirlpoolcorp.com.
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Whirlpool Global Operating Platform
Leading an $80 Billion Global Industry Leading an $80 Billion Global Industry
$18 B Revenues73,000 employees
#1 Global Share#1 Global Brand
#1 N.America $12 B Sales 24 Plants
#1 L.America $2.4 B Sales 5 Plants
#4 Europe $3.4 B Sales 13 Plants
Asia $457 M Sales 6 Plants
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Components
Engineering & Design
Components
Strategy Supports Best Cost, Best Quality Products
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What is RoHS?RoHS regulations generally restrict the following substances in
electronic and electrical equipment: Lead Mercury Cadmium Hexavalent Chromium (Cr6+) Polybrominated biphenyls (PBBs) Polybrominated diphenyl ether (PDE)
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Current and Pending RoHS ProgramsEuropean Union – Directive 2002/95/ECChinaJapanKoreaUnited States – State of California (limited to video display devices)
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EU RoHS Implemented July 1, 2006Compliance is the responsibility of the company that puts the product
on the market. In some cases, regulations are inconsistent because each member
state adopted separate implementing standards and enforcement procedures.
Contains broad definition of “electronic and electrical equipment” and contains specific exemptions for certain products.
Maximum concentration is 1000 ppm, except Cadmium, which is 100 ppm.
Everything identified as homogenous must meet the requirements.
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China RoHSPhase 1 (March 1, 2007):
Marking requirements for electronic information products Environment-friendly use period must be indicated inside the pollution
control symbol.
Phase 2 (timetable uncertain, likely 2008): Restrictions on Hazardous Substances
Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs, PBDEs Indications are that major appliances will be excluded, with exception of
microwaves.Replacement parts for appliances will be subject to RoHS if listed on the
catalogue.
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Japan RoHSDesign for Environment (DfE) criteria (promulgated in 2000)
Rationalize use of raw materials Use recycable and reusable parts Promote long-term use of products
The cabinet member with jurisdiction establishes basic policy and requirements for industry
Changes effective July 1, 2006: Manufacturers of computers, televisions, refrigerators, washers, dryers,
microwaves and air conditioners must label products to indicate presence of Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs and PBDEs.
Importers of computers, copiers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must meet Design for Environment Criteria (DfE).
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Korea RoHSRequirements include:
Restrictions of hazardous substances in electrical/electronic equipment and vehicles
Improvement of materials and structure Recycling requirements for manufacturers and importers Mandatory recycling rate Establishment of an Operation and Management Information System
Implementation date: January 1, 2008 However, implementation date does not mean anything until decisions are
ordered by Presidential Decree.
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California RoHSCurrently under consideration in the California LegislatureConsistent with EU RoHS regulations, with the following exceptions:
Applies to products manufactured on or after January 1, 2010 Applies only to mercury, lead, cadmium and hexavalent chromium (PBBs
and PBDEs are excluded) Excludes fixed installations Twenty-four month grace period for products that lose their RoHS
exemption Exempts products that are refurbished or sold for reuse Specific exemptions for spare parts A process for securing exemptions or time extensions
Annual reporting to California Integrated Waste Management BoardPassage is likely in 2007.
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Compliance ChallengesObtaining and verifying data on thousands of parts from around the
worldVague and varying regulationsNo common reporting because of various states, languages, formats,
etc.Constantly changing parts and componentsLack of best practices for mitigating risk
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Various End Manufacturers Strategy for RoHSNo single universal approachCan have thousands of components with multiple homogenous
materials eachToo many components for one company to feasibly deal with by itselfMost rely on reporting from supplier base
Letters of compliance Test data showing compliance
In-house testing3rd party testing
Often requested from Tier 1 suppliers, which trickles down the supply chain
Mixed strategies commonly used Components and suppliers are ranked into categories based on degree of
risk Level of documentation and testing can increase with each category
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Typical Sampling Strategies for Compliance Testing
No single universal approachTest every lot of material
Unusual except when lots of material commonly come from unknown production sources (commodity buyers, resellers, etc).
Test once for each part # produced. Retest when any changes in material, source, or process occurs (similar to
PPAP)
Test once for each part # used to produce multiple part #’s (e.g., cutting a larger coil of steel into various smaller width coils). May apply conformance to all downstream part #’s where no RoHS
materials are added Retest when any changes in material, source, or process occurs.
Typically, any change that occurs that would prompt sending production samples for engineering approval should prompt a decision as to whether a RoHS compliance retest is needed
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Test MethodsNo single universal approachMany various test methods, highly dependant on the material, processing
method, and type of component
3rd Party Testing Currently no official accreditation process for 3rd party labs Some companies have list of labs they use or accept results from
Internal Testing Many large companies use internal screening tests to reduce the amount of
expensive 3rd party tests (~$200-$400/sample) Portable XRF testers have become very popular
30 seconds/test Provides elemental analysis only (cannot tell difference between Cr6+ and Cr) Not very useful for certain materials
ASTM D6492 or ISO 3613 spot tests for detecting presence of chromate conversion coatings
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ConclusionRoHS regulations are being implemented globally, not just in the EUDespite having extensive global supply chains, manufacturers have
developed and are continuing to enhance compliance procedures.
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Questions or Comments?
Contact information:
Brandon Bokhart Luke HarmsSenior Metallurgical Engineer Government Relations SpecialistWhirlpool Corporation Whirlpool Corporation269-923-4210 [email protected] [email protected]