The Tip of an Environmental Iceberg
Electrical and electronics (E&E) manufacturers across the globe are dealing with an ever increasing demand, both legislated and consumer driven, to be held accountable for every molecule of material contained in their products which may impact the health of the environment, health of consumers and the health of individuals responsible for the manufacturing of products, and for the recovery, recycling and disposal of end of life products. What we are experiencing today is only the “tip of an environmental iceberg”. If your company has not put in place processes necessary to cost effectively manage the collection, risk assessment, and quality assessment of material data across a complex supply chain, then your corporate ship has struck the proverbial “environmental iceberg”, is taking on water and is in danger of sinking. In this article we will identify some of the challenges and techniques associated with keeping your corporate ship afloat.
The Challenges faced by E&E suppliers and product manufacturers today include:
AN EXPONENTIAL GROWTH IN GLOBAL REGULATIONS
The number of product targeted environmental regulations has grown at an explosive rate. Looking back to 2002, there were about 25 enacted regulations for substance restrictions globally, fast forwarding to 2013 the number has grown to about 200. The products in scope of the regulations have also grown due to the impact of legislation such as EU RoHS, EU REACH, CHINA RoHS, Korea RoHS, California Proposition 65 and a long list of similar country legislations either enacted or proposed and soon to be enacted. EU REACH is sometimes referred to as an “environmental compliance moving target”. As of the publishing of this article, the REACH list of Substances of Very High Concern has grown to 144 substances and will be added to every 6 months.
THE COMPLEXITY AND VOLUME OF MATERIAL IDENTIFICATION AND REPORTING
If we break down a common chip capacitor, contained in the vast majority of electronic products manufactured today, we have the following materials and substances:
- Ceramic Dielectric – Barium Titanate – Nickel Compound
- Internal Electrode – Palladium – Silver
- Termination – Silver – Sodium Borosilicate
- Plating – Nickel – Tin
This simple example contains 6 homogeneous materials containing 7 unique substances which should be identified, analyzed and the data must be stored and accessible by various functions within your company, as well as country enforcement agencies, consumers, and possibly your B2B customers. If this component is sourced from multiple manufactures it is easy to see how this could result in a large increase the number of records needing to be managed.
STEPS THAT CAN ENSURE A SMOOTH VOYAGE
If you are a supplier of materials
Such as Barium Titanate, Silver or Tin you will need to identify and report the chemical composition of your supplied materials to the capacitor manufacturer. Think of this as the start of a chain of custody for material composition disclosure.
If you are the manufacturer of the chip capacitor
If you have obtained material composition disclosure information from your suppliers, which you may have multiple sources for, then you have the necessary information to provide to your customer. Think of this as a 2nd link in the chain. If your material supplier cannot or will not provide you with the information you will need to take further actions such as removing the supplier from your Approved Manufacturers List (AML) or if that is not feasible having the material analyzed by an accredited materials testing laboratory until such time as you have either found a replacement supplier or the supplier is able to provide you with the information you need. Please keep in mind that it is not a best practice to qualify a supplier who is unable or unwilling to meet your requirements. You cannot afford to be the cause of a broken link in the supply chain.
If you are an original equipment manufacturer
You will need to have a system in place to store, manage and make available, both within and external to your company, the data you received from your suppliers, and linked to your product Bill of Material. These data records, in the case of RoHS II would become part of your Technical Documentation File for your product and must be kept on file for ten years and made available to an EU member state enforcement officer when requested. Think of this as the final link in the supply chain starting with raw material disclosure and ending with finished product manufacturing.
SUPPORT IS AVAILABLE
SGS has a global network of environmental compliance experts locally available to provide you with tailored services that meets your needs, objectives, and budget.
We offer technical assistance, process assessment, materials testing, and consulting services for:
- EU WEEE
- USA WEEE
- California Proposition 65
For further information please visit our Electrical and Electronics website.
For more information, please contact:
Environmental Compliance Management
Electrical and Electronics
SGS North America Inc.
t: +1 603 305 4103