1. Test Methods for Determining RoHS Substances in Electronics Markus Stutz, Dell Convenor IEC TC 111 WG 3

2. 2 WW Environmental Affairs Dell Confidential Key Messages RoHS is a reality worldwide Enforcement uses testing as one element Standardized testing methods for RoHS are urgently needed IEC standard on analytical testing (IEC 62321) nearly completed, finds wide political, industry & laboratory acceptance IEC 62321 standard contains useful guidance for sampling Opportunity exists to use nearly finished standard on sample disjointment, builds on Chinese standard proposal

3. 3 WW Environmental Affairs Dell Confidential RoHS: Substance Bans for Electronics Worldwide Legislation targets the use of certain substances in electrotechnical products – Europe: Restriction of Hazardous Substances (RoHS) – Korea: The Act for Resource Recycling of Electrical/Electronic Products and Automobiles (Korean WEEE, RoHS, EuP) – China: Management Methods on the Prevention and Control of Pollution Caused by Electronic information Products (Chinese RoHS) – US (California): Electronic Waste Recycling Act (S.B. 20), Electronic Waste, Advanced Disposal Fees (S.B. 50) Pb, Hg, Cd, Cr VI, and two types of brominated flame retardants (PBB, PBDE) are restricted Maximum Concentration Values (MCV) in homogeneous material (EU RoHS): – 0,1 % (weight) for Pb, Hg, CR VI, PBB, PBDE – 0,01 % (weight) for Cd – Homogeneous material: a material that can not be mechanically disjointed into different materials homogeneous: of uniform composition throughout mechanically disjointed: materials can be separated by mechanical actions

4. 4 WW Environmental Affairs Dell Confidential Position on RoHS Enforcement UK DTI guidance document : 1. Introduction: Aims, Objectives, Principles and Enforcement Process – Consistently applied and common interpretation regarding those products considered to fall within scope of RoHS – Presumption that products falling within scope of RoHS conform with its requirements – Self-declaration by producers 2. RoHS Compliance Documentation 3. Sampling & Testing Issues EICTA principles: 1. Presumption of Conformity 2. Providing evidence of compliance - no mandatory third party certification 3. Common agreed sampling and testing methodologies 4. Common approach and cooperation in market surveillance

5. 5 WW Environmental Affairs Dell Confidential EICTA Proposal Compliance Process

6. 6 WW Environmental Affairs Dell Confidential Why Testing? And How? Testing may be performed for a variety of reasons: – As an alternative to supply chain material declarations – As a supplement to a material declaration – As a “spot check” to confirm supplier compliance – As a basis to assess compliance (enforcement) Certain test methods to determine regulated material content already exist, but: – Most are not appropriate for testing electrotechnical products – Testing methods differ from each other – Methods are not internationally recognized – Not agreed upon by countries regulating substances in EEE

7. 7 WW Environmental Affairs Dell Confidential Importance for a Standard Testing Method Compliance checks have to be performed in a consistent and reliable manner Need for detailed specifications of methods to verify compliance with regulations Methods need to be implementable by laboratories all around the world International standards encourage trade of products by avoiding technical barriers Harmonisation of compliance and enforcement methods is essential for a proper functioning of the global market

8. Procedures for Determination of Levels of Six Regulated Substances in Electrotechnical Products IEC 62321, Ed. 1

9. 9 WW Environmental Affairs Dell Confidential Scope IEC 62321 Standard provides test procedures for determining the levels of Pb, Hg, Cd, Cr VI and their compounds, and two types of brominated flame retardants (PBB, PBDE, except DecaBDE), contained in electrotechnical products Outside of scope: – Definition of a sample (e.g. homogenous material, component) – Disassembly procedure to get to a sample – Assessment procedures (is sample compliant with RoHS?) “Practical Guide for Testing Electronic Products” (Annex A): – Practical guide to disassembly, sample selection and application of test methods

10. 10 WW Environmental Affairs Dell Confidential Sample: Homogeneous Material or Component Standard refers to the “sample” as object to be tested What sample is (product, field replaceable unit (FRU), component, homogenous material) is decided by entity Entity can decide to prepare a sample – homogenous material (according to EU definition) Procedures for metals and/or polymers – Component, FRU, product Procedures for electronics

11. 11 WW Environmental Affairs Dell Confidential Guidance: Product to Sample Samples Metallic Materials, Polymer Materials, Electronics (PWB/ Component ) Verification Test Procedure Various Methods Screening? Meets limits? Meets limits? Entity based conforming sample Decision Decision criteria will be entity based Further testing? Yes Fail Pass Yes No Entity based non conforming sample No Pass Fail Screening Procedure Mechanical Sample Preparation Sample uniform? Nondestructive Sample Preparation No Yes Entity based conforming sample Entity based non conforming sample Test Procedure Flow: Screening and/or Verification

12. 12 WW Environmental Affairs Dell Confidential A Variety of Test Methods, adapted for EEE StepsSubstancesPolymersMetalsElectronics ScreeningPb, Cd, Hg, Cr, BrEDXRF or WDXRF (handheld or desktop) Mechanical sample preparation Direct measurement Grinding Direct measurement Grinding Chemical sample preparation Microwave digestion Acid digestion Dry Ashing Solvent extraction Acid digestionMicrowave digestion Acid digestion Solvent extraction Analytical technique PBB/PBDEGC-MSNAGC-MS Cr VIAlkaline Digestion/ Colorimetric Method Spot-test procedure/ boiling-water- extraction procedure Alkaline Digestion/ Colorimetric Method HgCV-AAS, AFS, ICP-OES, ICP-MS Pb/CdICP-OES, ICP-MS, AAS EDXRF: Electron dispersive X-ray Fluorescence WDXRF: Wavelength dispersive X-ray Fluorescence GC-MS: Gas Chromatography - Mass Spectrometry ICP-OES: Inductively Coupled Plasma Optical Emission Spectrometry ICP-MS: Inductively Coupled Plasma Mass Spectrometry CV-AAS: Cold Vapor Atomic Absorption Spectrometry AFS: Atomic Fluorescence Spectrometry

13. 13 WW Environmental Affairs Dell Confidential Screening : EDXRF/WDXRF, non-destructive or mechanical sample prep Equipment: XRF (X-Ray Fluorescence) – EDXRF (Energy Dispersive) – WDXRF (Wavelength Dispersive) Screens for Pb, Cd, Hg, total Cr, total Br – Cannot differentiate Cr species (Cr III, Cr VI) – Cannot differentiate brominated flame retardants (PBB,PBDE, TBBA) Two means to carry out screening: – Directly measuring the sample (non-destructive sample preparation) – Destructing the sample to make it uniform (mechanical sample preparation) – Decision must be made by judging the uniformity of the sample Plastics, alloys, glass are usually uniform Components, populated PWB need mechanical sample preparation Pros of screening: Fast and resource efficient Cons of screening: Has limitations to use and applicability of results Take special precaution when using handheld equipment

14. 14 WW Environmental Affairs Dell Confidential Verification: Test Methods adapted for EEE GC-MS (Gas Chromatography - Mass Spectrometry) – PBB, PBDE – Based on German BAM method Spot-test procedure/ boiling-water-extraction procedure – Cr VI screening (present/not present) – Based on ISO 3616 Alkaline Digestion/ Colorimetric Method – Cr VI – Based on US EPA method CV AAS (Cold Vapor Atomic Absorption Spectrometry), AFS (Atomic Fluorescence Spectrometry) – Hg ICP-OES (Inductively Coupled Plasma Optical Emission Spectrometry), ICP-MS (Inductively Coupled Plasma Mass Spectrometry), AAS (Atomic Absorption Spectrometry) – Pb, Cd, Hg – Split for metals, polymers, electronics

15. 15 WW Environmental Affairs Dell Confidential Testing Methods Document & Timeplan Committee Draft for Voting (CDV) "Procedures for the Determination of Levels of Regulated Substances in Electrotechnical Products" (IEC Project number: IEC 62321, 111/54e/CDV) Document available at the appropriate National Committee Timeplan – Committee Draft for Voting (CDV)5. May ’06 – International Interlaboratory Study (IIS)March – June ‘06 – Voting period endsOctober ’06 – Final Draft International Standard (FDIS)December ’06 – Standard (printed)March ‘07

16. Practical Guide for Testing Electronic Products IEC 62321, Ed. 1 Annex A (Informative)

17. 17 WW Environmental Affairs Dell Confidential EU “homogenous material” definition impractical for testing a finished electronic product (e.g. PC, cell phone, etc) Need to develop a practical approach to testing a finished electronic product. – Government officials likely to test – Companies want to be able to screen their products to ensure that compliance statements from suppliers are accurate Background

18. 18 WW Environmental Affairs Dell Confidential Develop an annex to the standard that provides practical guidance for applying the test methods defined in the standard Provide general guidance for “typical” electronic products Impossible to give detailed guidance for all electronic products Detailed guidance, if required, should be developed by sector specific groups Proposal and Scope of Guidance Document

19. 19 WW Environmental Affairs Dell Confidential Evaluation without disassembly Homogenous Materials (evaluation often impractical) Solders, finishes, plastics, metals, etc. Evaluation with simple disassembly Evaluation with detailed disassembly Testing Principles for Electronic Products

20. 20 WW Environmental Affairs Dell Confidential Guidance Document Approach Identifies “high risk” areas for each level – No disassembly (external parts) – Simple disassembly (internal parts) – Detailed disassembly (internal parts) “High risk” based on historical use of these materials in electronics Limitations: – Use of restricted materials in unknown applications – Difficult to include all potential applications due to large number of electronic products

21. 21 WW Environmental Affairs Dell Confidential Historical Use of Restricted Materials – Potential “High Risk” Areas External PartRestricted SubstanceHistorical Use Plastic enclosures, fasteners, clips, screws, etc. LeadAdditive to plastic CadmiumAdditive to plastic, plastic colorant PBDEsFlame retardant Metal enclosures, fasteners, clips, screws, etc Hexavalent ChromiumPlating Cables, cords, wiresLeadAdditive to plastic, stabilizer CadmiumAdditive to plastic, stabilizer Decorative name plates, buttons, etc MercuryAdditive to certain plastics; curing agent Printed circuit boardsLeadSolder, finishes Electrical componentsLeadSolder on terminal finishes Switches, relaysMercuryComponent of switch/relay BulbsMercuryUsed in florescent bulbs

22. Sample Disjointment Scheme IEC 111/44/INF

23. 23 WW Environmental Affairs Dell Confidential Sample Disjointment Scheme: Standard Proposal from China Sample Disjointment Scheme for the Determination of Regulated Substances in Electrotechnical Products (IEC 111/44/INF) Proposal by Chinese NC to IEC TC 111 (Jan. ’06) Standard disjointment schemes to get to the sample needed for complying with regulations Disjointment standard interfaces with IEC62321 to complete system to determinate regulated substances Takes into account: – Requirements of chemical analysis – Requirements of conformity assessment – Efficiency – Balance between industry and environment

24. 24 WW Environmental Affairs Dell Confidential Guiding Principles The aim of disjointment is to obtain homogeneous material from electrotechnical products – In some (most?) cases this will be impossible Concept of “non-homogeneous” sample – If parts are too small (mechanical disjointment) – If sample cannot satisfy the requirements of chemical analysis (minimal sample mass) In every step of disjointment, risk levels of disjointed parts is identified (historical use) – High risk parts are further disassembled

25. 25 WW Environmental Affairs Dell Confidential Sensible Thresholds for Disjointment Quantity/Mass – Minimal quantity required for chemical analysis (MQCA): If part is smaller than minimal sample quantity, part is taken as sample – Takes into account issues during chemcials sample preparation and analytical testing – Minimal sample quantity proposed: 10 g – Minimal sample quantity for IEC 62321: 1000 mg (1 g) Volume – Minimal volume of sample: If part is smaller than minimal sample volume, part is taken as sample – Takes into account issues during mechanical separation – Minimal sample volumen proposed: 1,2 mm 3 (volume of 0805 component) Area – Minimal area of sample (for Cr VI analysis) – Minimal sample area proposed: 50 cm 2

26. 26 WW Environmental Affairs Dell Confidential Dashed parts mean optional MQCA: Minimal quantity for chemical analysis Flowchart Simple disjointment Yes Catego- rization Test Unit? Test necessary? MQCA? Exempt part? Risk assessment Detailed disjointment Low risk part No submit Submit Submit according to exemption requirement (or no submit) No Yes No Catego- rization Preparation Yes No Yes

27. 27 WW Environmental Affairs Dell Confidential Example: Populated PWB

28. Adoption of IEC Standards by EU Bodies

29. 29 WW Environmental Affairs Dell Confidential UK DTI RoHS Enforcement Guidance Document Document describing guidance on RoHS enforcement In the process of being adopted by EU member states enforcement bodies Positive on IEC standard – “A variety of recommended testing approaches and standards are being established by international standards organisations” – “One existing specific example of a standard procedures for analytical testing (which is being widely promoted for use by the IT, telecoms and consumer electronics sector) is IEC 62321.Ed.1, 111/24/CD”

30. 30 WW Environmental Affairs Dell Confidential EICTA Position Paper on RoHS Enforcement Document describing industry position on RoHS enforcement Urge for “common agreed sampling and testing methodologies” EICTA emphasizes the need for standardized sampling and testing methods such as IEC CDV 62321, that can be adopted consistently by Member State enforcement bodies and used by industry EICTA asks for the RoHS enforcement guide currently being developed by TAC to include: – Recognition of IEC 62321 as the standard for determination of levels of the six RoHS substances in Electrotechnical Products – Recognition of the "state of the art" work in IEC TC111 about sample preparation from electrotechnical products (informative annex of IEC 62321 “A practical guide for testing electronic products”) – Recognition of the informal document IEC 111/44/INF on sample disjointment, which takes into account requirements on mechanical disjointment

31. Act for Resource Recycling of Electrical/Electronic Products and Automobiles Dell Key Messages

32. 32 WW Environmental Affairs Dell Confidential Dell Key Messages Harmonize covered substances and European Union approved exemptions Adopt relevant or imminent international standards to ensure smooth market access – Test methods: IEC standards – Labeling: J-Moss Develop necessary guidance allowing manufacturers adequate time to meet the proposed entry into force of July 2007 Engage with industry to develop guidance (e.g. sub decrees)

33. 33 WW Environmental Affairs Dell Confidential Summary RoHS is a reality worldwide Enforcement uses testing as one element Standardized testing methods for RoHS are urgently needed IEC standard on analytical testing (IEC 62321) nearly completed, finds wide political, industry & laboratory acceptance IEC 62321 standard contains useful guidance for sampling Opportunity exists to use nearly finished standard on sample disjointment, builds on Chinese standard proposal

34. 34 WW Environmental Affairs Dell Confidential Thank you markus_stutz@dell.com markus_stutz@dell.com