a decade of environmental regulations and new technologies · a decade of environmental regulations...

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A Decade of Environmental

Regulations and New Technologies

July 2011

Jackie Adams, Senior Technical Staff

Member

Global Lead for the Center of Excellence

for Product Environmental Compliance

SMTA Carolinas

July 27, 2011

Agenda and contents

Product Compliance

– Global Business Structure, Resources and Schedule

– Strategic Alignment: across the supply chain and the

– Operational Alignment: Material handling, Design, Supply Chain,

Manufacturing and Business

– Overview technology alignment to various regulations

– E.g. EU REACH substances, lead and halogen reduced

technologies, batteries and external power supplies

– Life cycle assessments when choosing alternatives

Conclusion

Global product compliance can effect all products and services a company manufactures/sells/imports

Types of Environmental Regulations

7/27/2011

Energy/Power

Substances

Climate change

Global Product Environmental Regulations

7/27/2011

US and Canada

Asia Pacific

Customers

Governm’al

Orgs

Effects more and more of the total electronic supply chain

OEM Semi/Raw Mfr Sub Assemblers

Mining

Fabless

Foundry

Electronic

Mfg

Supplier

Component

Suppliers

Semicon

Distribution

Channel /

Partner

Retailers

Resellers

Distributors

Consumers

GO’s/ NGOs

Headquarters

In\outbound Warehousing

Factories Contract Mfr

Original

Design Mfr

Product Regulations and Complexity Overtime Geographies vs. Type of Regulation

0

20

40

60

80

100

120

Co

mp

lexit

y Documents of Conformance

J Adams; IBM page 7

Data Collection

Labelling

Reporting/ Registration/

Tracking

EU ROHS Recast

CE Marking

Packaging

Compliance

Compliance effects the value chain

DfE Manufacture Supply Chain Take-Back, Disposal,

& compliance

Design for

Environment

Material

Compliance

for RoHS

Design

For RoHS

Design

For EuP

Design

For IPP

Disposal

Operations

Lead Free

Compliant

RoHS /REACH

Compliant

Safety

Compliance

Proof Of

Compliance

Compliant

Processes

Batteries

Identify Parts

& Assemblies

Alternative

technologies

Substance

Data mining

(IT)

Material

Declaration

(PCD)

Ship to

Restrictions

HazMat

Country Specific Legislation

Waste Water

and Energy

WEEE

Recovery

Treatment

Disposal

Confirmation

HazMat)

Material

Manifest

Destruction

Certificate

Audit

Non-

Conformance

Corrective

Action

Process

Categorize Identify Treatment Reporting/

Analysis Site

Inspection

Air Quality

Transportation

Design

For PS

Design

verification

ESI Package

distribution

Areas I will touch on in the next series of slides

External Power Supplies, Monitors, Stand alone Systems etc. Labeling by Type and Energy Criteria - dependent on country requirements

Taken from the website of the – World Energy Council

Member Countries

Founded in 1923, the World Energy Council is the only truly global

and inclusive forum for thought-leadership and tangible

engagement committed to our sustainable energy future. Our

network of 93 national committees represents over 3000 member

organizations including governments, industry and expert

institutions

Existing or emerging

Energy regulations

http://www.worldenergy.org/about_wec/wec_history/default.asp

http://www.worldenergy.org/

Example of batteries that have initiatives, labeling, and take back

Battery Type

Cost $ per Wh

Wh/kg Joules/kg Wh/liter

Lead-acid $0.17 41 146,000 100

Alkaline long-life $0.19 110 400,000 320

Carbon-zinc $0.31 36 130,000 92

NiMH $0.99 95 340,000 300

NiCad $1.50 39 140,000 140

Lithium-ion $0.47 128 460,000 230

http://www.worldenergy.org/

DIRECTIVE 2002/95/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 January 2003 - on the *restriction of the use of certain hazardous substances (RoHS) in electrical and electronic equipment

Lead-free (Pb)

Cadmium (Cd)

Mercury (Hg)

Hexavalent Chromium (Cr6+)

PBDE (Polybrominated biphenyl ethers)

PBB (Polybromobiphenyl)

*Restrictions with diminimus level and exemptions

Example, Lead restriction–

ELEVATED LEAD-FREE PROCESS WINDOWS

SnAgCu based alloys continue to be the leading choice for

surface mount technology (SMT) assembly interconnections.

With this change from eutectic SnPb solders to SnAgCu based solders has

come a 34 degree Celsius increase in melt.

Elevated Temperature SnAgCu Process Window

*M. Kelly et al 2011

SMTAi Toronto

Hexavalent Chromium- Testing challenges

In a controlled experiment, IBM scientists were able to further demonstrate that antimony

trioxide, a synergist to enhance the activity of halogenated flame retardants, reacts with

hexavalent chromium by converting Cr(VI) to Cr(III)4, leading to an artificially low detected

hexavalent chromium levels.

. However, in the presence of trivalent antimony, Sb(III), color formation is completely

absent. Therefore, simultaneous extraction of both the trivalent antimony flame retardant and

the hexavalent chromium pigment in plastics results in facile reduction of Cr(VI) leading to

erroneous quantification of hexavalent chromium.

The discovery of antimony(III) synergist matrix interference is key to unlocking the Cr(VI)

recovery puzzle; there are still challenges ahead to research and develop methods to

counteract the effect of the antimony synergist. IBM and IEC experts will continue to

collaborate on developing viable solutions to this industry challenge, but with this discovery,

are one step closer to a reliable test standard for Cr(VI) in plastics to confirm regulatory

compliance.

http://www.plasticstoday.com/articles/progress-made-test-

standard-identifying-hexavalent-chromium

Joe Kuczynski - STG Packaging Engineering for Adhesives, elastomers, polymers

Sophia Lau - ISC Center of Excellent for Product Environmental Compliance

14 IBM Confidential 14

2011 European Union Restriction

of Hazardous Substances RoHS RECAST: Directive 2011/65/EU Published on July 1, 2011 in the Official Journal of the European Union. Entry into force July 21, 2011.

Member States are required to transpose the Directive into National law by Jan. 2, 2013

The first operative date of the Directive is Jan. 3, 2013 No additional substances added

All Electronic Equipment is now in scope, Medical devices (category 8), monitoring & control instruments (category 9) & “other EEE” (category 11) added to the scope. Compliance dates vary depending on the application.(2017)

Manufacturers are required to complete a conformity assessment and EC Declaration of Conformity (DOC). CE mark is required on all finished products.

In support of this requirement one will need to demonstrate there is a process in place that ensures on-going compliance of products and supplier deliverables.

Technical documentation and the EU DOC needs to be retained for 10 years.

Exemptions that were not assigned an expiration date (eg. 7a – lead in high melting temp. type solders ; 7b – lead in Server/Storage.; 15 -lead in flip chip) are projected to expire July 21, 2016. There is a chance that companies may request an earlier expiration if an alternative technology exists. Requests for renewing an exemption must be submitted no later than 18 months prior

to the expiry date. There is a transition period of 12 – 18 months from when an exemption renewal is

rejected or exemption is deleted.

No legislation driving halogen free initiative.

Certain halogens are restricted by EU RoHS and similar laws.

Phthalates are not restricted but monitored and reported in REACH SVHCs

Halogen-free initiative is in focus for many reasons most due to the non regulated

incineration of parts these substances are exposed to. This inappropriate

incineration releases Furans and Dioxins that are carcinogenic

Many global IT consumer and enterprise OEMs have had objectives to be flame

retardant (BFR) and (PVC) free in 2009 and now in 2012 respectively

Removing PVC reduces flexibility (inherent in the phthalates) including flammability

attributes of (Cl-)

When developing an alternative typical attributes being considered are low smoke,

product safety, electrical and mechanical properties

Most companies do not consider trade offs on cost, quality or availability

Why target Halogens, PVC and Phthalates with non regulations

Driver

Global Environmental Responsibility

Non-Governmental Organization (NGO) pressure to address environmental issues

Commodities Cable Jacketing, Connectors, BGA substrate /Mold compounds,

Printed Wire Boards, Polymeric Enclosures

Materials Involved

All Halogenated Flame Retardants

Brominated Flame Retardants (TBBPA is main FR in substrate & PCB Materials)

All Chlorinated Flame Retardants and PVC

Standards

(PCB Material Only)

IEC 61249-2-21

JPCA-ES-01-1999

IPC - 4101B

Publication

(Solid State Devices Only)

JEP - 709

Standards

(Passives, Connectors and Solid State Devices)

J-STD-709

(Replaces JEP-709) (Joint JEDEC – ECIA Standard)

Low-Halogen Flame Retardant (FR) Standards

Low Halogen Roadmap

1985 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

IEC / JPCA / IPC

Standards

(PCB Laminates) Nov 1999

Consumer products

Increase business applications

EHS concerns with use

of certain halogenated

flame retardants Mid 1990s

Industry

discussions &

studies begin Late 1990s

Greenpeace

1st revision Guide to

Greener Electronics August 2006

J-STD-709

(System Level) June 2010

X-Industry movement

in this direction

More to look for in the next decade when evaluating alternative materials Sustainable development is a trend in the coming decade

Life Cycle Assessments for new technologies

Close cooperation across the value chain is key to have the right

materials available in time.

Connectors/ Sockets and Cables/Wires remain the two top critical

aspects in the halogen free conversion.

High melt solder technologies, Flip chip technologies, with respect to

lead reduction

Green design will evolve from a differentiator to a qualifier for most

industry segments the environment needs a joint commitment of

the industry to make it happen

IBM engineering &

manufacturing

standards

Government

Environmental

Regulation

IBM Environmental

Standards

Engineering Data

Mngt System

Material Content

Declarations

Design for Environment Supplier Compliance

Design engineering Data collection

validation, retention

Compliance Validation 2 1

3

Product top-

level BOM lists

Product Environmental Profile

Product Environment

Profile

4

Automated

Compliance

Determination

Automated

Compliance

Analysis

BOM & Part design

data and documents

BOM Scrub

Environment

al

Compliance

attributes

Data

loadin

g

Mfg

6

Logistics

7

Shop Floor

Control

Shipping

Customer Fulfillment

Pricing and Invoice

(via Announce process)

5

Service

8 Service

Parts

Data

loadin

g

Demands on Material and Engineering Data : Data Integrity tools/process(s)

Envi

ron

men

tal P

rod

uct

Co

mp

lian

ce P

ort

folio

Product environmental compliance through 2015 – Examples

2006 2007 2008 2009 2010 2012 2011 2013 2014

Product take back – started with WEEE ( 2002) now many geo’s adopted , track sales by geo

and pay a recycle fee or prepare a third party - include commercial system and peripherals

Rare Earth and Conflict metals -

DoC

Data collection -, requirement has expanded Proof of material composition and origination

(testing, DoCs, CE markings)

EU REACH SVHC, can not import articles with controlled substances

(~1000) from the SIN List (Substitute It Now). This means permission to

import into the EU or resource

Battery regulations, recycling and product take back, material data collection for batteries on OEM cards, and in OEM products

2015

Restriction of Hazardous Substances - 30 Exemptions requiring future replacement technologies

a) Material initiatives in the industry is removal and or restriction of PVC, BFRs, CFRs - Cables, PCBs, connectors, logo and non logo systems solutions

b) Labeling and certification

c) Global requirements may vary

RoHS/

Recast

Energy Certification and Reduction –Increase in requirements to decrease standby and power utilization

Battery

Traceability

Energy and Water

Conservation

PTB for

Systems

EU REACH Substances

Maintaining a consistent and performance driven supply chain

Concluding Thoughts New global environmental requirements continue to multiply – fast and

the industry must work together to effectively respond

Many various types are developed globally

– battery and chemical restrictions, hazardous substance eliminations, electronic and electrical recycling, product take back, power and energy regulations.

Industry needs to be more proactive in developing solutions that:

– Are based on science and engineering, delivering value to customers

– Are available in advance of new regulations

– Can influence future regulations and stakeholder groups for more sustainable results

Sustainability in HFR and PVC alternatives has been a major undertaking for the electronics industry similar to Lead free/reduction and other required substances changes

Where the technology exists it will be important for the electronic supply chain to use them where ever applicable

Thank you

For questions

contact:

[email protected]

J Adams page 23