UL Ro HS 2007 Vincent Sylvester NA Regional

UL Ro. HS 2007 Vincent Sylvester NA, Regional Business Manager Ro. HS Solutions (603) 370 -7162 Vincent. Sylvester@us. ul. com Partners Working For A Green Planet!

Restricted Substances Regulations Stretch Across the Globe Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Ro. HS Directive Restricted Substances and Limits Restricted Substances Ro. HS Limits* Lead 1000 ppm Hex. Chromium 1000 ppm Mercury 1000 ppm Cadmium 100 ppm PBB 1000 ppm PBDE 1000 ppm Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Mechanically Disjointed Material • Mechanically Disjointed – Refers to materials that, in principle, can be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes • Semiconductor package containing six different homogeneous materials • Insulated wires comprised of metal wire inside plastic insulating material Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

“Green” Products – Restriction of 29 Total Substances Found in Annex A and B of Joint Industry Guide “JIG” (also called IPC 1065) developed by the EIA, JGPSSI and EICTA Annex A (includes Ro. HS material which are not shown below) • • • Asbestos Certain azocolourants and azodyes Ozone depleting PCBs Polychlorinated naphthalenes (>3 Cl) • Radioactive substances • Certain shortchain polychlorinated paraffins • Tributyl/triphenyl tin • Tributyl tin oxide Annex B • • • Antimony/Antimony Compounds • Brominated Flame Retardants (other than PBBs or PBDEs) Arsenic/Arsenic Compounds • Nickel/Nickel Compounds Beryllium/Beryllium Compounds • Selenium/Selenium Compounds Bismuth/Bismuth Compounds • Polyvinyl Chloride (PVC) Certain Phthalates Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Three Steps to Ro. HS Compliance • Understand It • Implement It • Prove It Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Ro. HS Enforcement Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Keys of “Ro. HS Enforcement Guidance Document” • Testing • Enforcement Process • Compliance Assurance System (CAS) Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

XRF Testing • EU will carry out X-Ray Fluorescence (XRF) analysis of products to detect infringements • XRF is a Screening Tool Capable of Detecting: – Pb, Cd, Hg – Cr (VI), Hexavalent Chrome • (for Cr total presence) – PBB’s and PBDE’s (Br compounds) • (for Br total presence only) • Note: Products must be submitted to China laboratories for testing Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Enforcement Process • Market surveillance activities – 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 Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Requirements for a Compliance Assurance System (CAS) • Testing • Component Documentation • Procedure Documentation Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Testing Requirements • Demonstrate that your finished products pass XRF screening • Demonstrate that your suppliers’ components pass XRF screening Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Component Documentation Requirements • Provide all converted Bill of Materials for Ro. HS compliance • Provide Build to Print documentation for Ro. HS compliance for the following high risk parts and assemblies • • • Printed circuit boards Cable assemblies Metal Finishes Plastics Hardware Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Levels of Preferred Component Documentation Preferred • Provide material declarations at homogeneous levels for all components • Where material declarations are not available, provide test verification that no restricted substances are present at the homogeneous level Least Preferred • Where material declarations or test results are not available, provide certificates of conformance or producers’ warranties for evidence of compliance Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Procedure Documentation Requirements • Demonstrate that Management has provided Ro. HS compliance objectives, and resources to ensure progress toward Ro. HS compliant products and production • Provide evidence that Ro. HS compliance assurance is included in Management Review. • Provide training records for all employees for Ro. HS compliance Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Procedure Documentation • Demonstrate the design process contains Ro. HS compliance • Demonstrate your internal data and records system reflects Ro. HS compliance data Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Procedure Documentation • Supply Chain Management – Provide evidence that you have communicated Ro. HS requirements to your Suppliers – Demonstrate new part numbering system to distinguish between Ro. HS compliant and non-compliant – Demonstrate verification of incoming material procedures have been revised to address Ro. HS compliance Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Procedure Documentation • Demonstrate material and equipment segregation to prevent contamination by a restricted substance • Demonstrate revised internal procedures and work instructions for Ro. HS compliance for the following areas: • • • Stockroom Segregation Material Handling Production Processes Non-conforming Product Corrective Action and Continual Improvement Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Procedure Documentation • Provide internal audit data for Ro. HS compliance. • Provide supplier audits and assessments for Ro. HS compliance • Demonstrate that a supplier corrective action process is in place to address Ro. HS non-conformances. • Demonstrate traceability and containment procedures in the event of contamination. Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Ro. HS Compliance Assurance System (CAS) Solution Step 1: Gap Analysis / Planning (2 -day onsite program) • Lead Assessor Training • Gap Analysis • Management Overview Step 2: Implementation / Final Assessment (9 -weeks) • Works with specific groups within the organization to address the specific Ro. HS requirements that impact them. • Modules include: 1. 2. 3. 4. Quality Management Responsibility and Resources Design and Development Purchasing 5. Production Process 6. Measurement and Analysis 7. Internal Training 8. Final Process Assessment Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Restricted Substance Bill of Material (BOM) Conversion • For each submitted Bo. M and build-to-print drawing, UL will analyze and provide information on the following: – Ro. HS and Green compliance information for each component or material – Compliant replacements, if necessary and/or available – MSL rating – Peak reflow temperatures – Lead finish – Part identification markings – All supporting vendor documentation – XRF testing for components and materials where there is no data to confirm compliance Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.

Thank You! • Questions and Answers Proprietary and Confidential ® All rights reserved by Underwriters Laboratories Inc.