1. A Review of the Impact of European Union Environmental Directives
Provide background on the three Environmental Directives issued by the European Union – Impacting TI Manufacturing Operations
Stuart Sleeman
Principal
Sleeman Hanley & DiNitto, Inc

2. Sensata Technologies Comprised of three major business units:
Sensors
Controls
More than 6,000 employees around the globe
Technology Development and Manufacturing in nine locations in the Americas, Asia and Europe

4. Product Content Management
Requirements
Customer Requirements:
Contracts and specifications
Surveys/ Declarations
Influence
Current and Horizon Legislation/ Industry Standards
Discover and Understand
Science and R&D
Decisions & Strategy
Business-Wide Strategy
Planning and Roadmaps
TI Ban List Content Decisions
Strategy for Customers
Strategy for Suppliers
Execution
Internal Manufacturing
Specifications
Chemicals & Materials
Equipment
Change Control
External Manufacturing
Subcons/Foundries
R&D
Market Management
Internal Communication of Decisions
External Communication and Customer Management
Supplier Management
Ban List Management

5. EC Directives (WEEE; ROHS & ELV)
EC Directives/Material Content Reporting
EC Directives (WEEE; ROHS & ELV)
Directive on Waste Electrical and Electronic Equipment (WEEE)
Directive on Restriction of Use of Certain Hazardous Substances (RoHS)
Directive on End-of-Life Vehicles (ELV)

6. Germany’s Packaging Ordinance of 1991 created the Green dot System

7. Sony swaps PlayStation One cables
Last modified: December 5, 2001, 11:55 AM PST
By Reuters        
Sony is replacing peripheral cables for 1.3 million PlayStation One game consoles after the Dutch government blocked sales of the machines because of health and environmental concerns.
The Dutch government said Tuesday it had blocked shipment of the consoles and 800,000 accessories bound for the European Union market in a warehouse in the Netherlands because the cables contained too much cadmium.
On Wednesday, Sony said it had already started replacing the cables. It hoped to resume limited shipments of the consoles by mid-December.
"Although we have reservations about the interpretation of the regulations (by the Dutch authorities), we have begun replacing the cables," a Sony representative said.
Sony said its newer PlayStation 2 consoles were not affected by the ruling because they do not use the same cables.
The company will not replace cables for PlayStation One consoles sold in countries outside Europe if they did not violate environmental regulations in those nations, the company said.
Sony also said it will not recall any consoles already sold in Europe because the amount of cadmium in the cables does not--in its view--pose a health risk.
The cadmium contained in the cables only poses a risk if incorrectly disposed of, in which case it could have long-term environmental effects, Sony said.
Within the European Union, no goods are allowed to be imported that contain more than 0.01 percent cadmium. The Netherlands said the cables contained three times to 20 times the allowed amount.
A spokesman for the Dutch Environment Ministry said Tuesday that large concentrations of cadmium are banned in the Netherlands--in line with European Union policy--to prevent it from entering the food chain.
"Cadmium damages the kidneys," ministry spokesman Joost Kehrer said.
Sony did not say how much the cable replacement will cost the company.
Estimated costs to Sony were $86M

8. EU Material Content Directives Vehicle End of Life Directive

9. Manufactures sensors that are used in various automotive systems.
Supply to all the major automakers directly as a tier one supplier or through others as a sub-tier supplier.
IMDS Entry Requirements: - existing product lines - new product lines (PPAP) - 50% - 70% complete
Automotive Sensors
Air Conditioning
Coolant Level
Low G Accel.
Trans- mission
Occupant Weight
Tire Pressure
Oil Pressure
ABS
Power Steering
Angular Rate Sensor

10. End of Life Vehicles Directive
The European Parliament & the Council of European Union signed the End-of-Life vehicle directive on 9/18/00. Directive 2000/53/EC, effective 1/03.
Objective is the prevention of waste from vehicles and also the reuse, recycle, & recovery of end-of life vehicles and components, thus improving environmental performance for all economic operators involved.
Automobile producers to provide appropriate information to treatment facilities, concerning dismantling, and re-use

11. End of Life Vehicles Directive
Requirements:
Ban on the use of hazardous substances (lead, mercury, cadmium, hexavalent chromium) with exemptions.
Total 2.0 grams/vehicle of Cr+6 for corrosion protection purpose only; 0.0 gram for any other application in June 2003
Requirements for the re-use and recovery at vehicle end-of-life.
Achieve re-use and recyclability of at least 85% average vehicle weight by 2005 with greater percentages for 2015
Improve recycled content.
End-of-Life disposition information

12. End of Life Vehicles Directive
Treatment:
Targets to be achieved
85 % re-use / recovery 80 % re-use / recycling
95 % re-use / recovery 85 % re-use / recycling
Type
Approval
95 % re-useable / recoverable
85 % re-useable / recyclable
free from lead, mercury, cadmium and chromium VI (exemptions listed in Annex II)
provision of dismantling information
New Vehicles
delivery to treatment facility with no cost for last holder and/or owner
Year
2000
7/2002
7/2003
2005
1/2007
2010
2015
2006
Vehicle Population
delivery to treatment facility with no cost for last holder and/or owner

13. End of Life Vehicles Directive
IMDS: One Certification
Procedure for the Industry
2000
2002
2006

14. Collect Material Account Data
Gather Info
Supplier
Material Composition Information
IMDS provides a common method for identifying materials, substances and attributes
Suppliers proactively send material composition information
IMDS manages aggregated data sent forward through the supply chain.
Product
Owner
Tier 3
Gather Info
Supplier
Product
Owner
Tier 1
Tier 2
OEM
Product
Owner
Material Composition Information

15. EU Material Content Directives RoHS & WEEE

16. Waste Electrical & Electronic Equipment [Directive 2002/96/EC]
Sets criteria for collection, treatment, recycling and recovery of waste electrical and electronic equipment
Makes Producers Responsible
Transport from collection facilities
Financially responsible for treatment, recovery and disposal
Households/Final Holders and Distributors of WEEE can return such equipment free of charge
Recovery Targets Set for Collection from Households
Waste from electrical and electronic equipment (WEEE) is a priority waste stream of the European Commission because it is growing faster than other forms of waste and can contain certain hazardous substances

17. Restriction on Use of Certain Hazardous Substances in EEE [RoHS] [Directive 2002/95/EC]
Facilitates dismantling and recycling of waste electrical and electronic equipment by restricting use of hazardous substances in manufacturing
Lead, mercury, cadmium, hexavalent chromium, PBBs and PBDEs banned by July 2006
EEE = electrical and electronic equipment
Targets Specific Compounds
RoHS intended to support WEEE Directive

18. Categories of Electrical and Electronic Equipment Covered by WEEE Directive
Large household appliances
Small household appliances
IT and telecommunications equipment
Consumer equipment
Lighting equipment
Electrical and electronic tools (with the exception of large-scale stationary industrial tools)
Toys, leisure and sports equipment
Medical devices (with the exception of all implanted and infected products)
Monitoring and control instruments
Automatic dispensers

19. WEEE Directive - requirements
Register with each EU country
Finance for your obliged allocation of WEEE:
Separate collection
Recycling
Treatment / Recovery
Provide information to recycling/treatment facilities
Report evidence of proper management
Report evidence that targets have been met
Ensure marking of equipment
Producer pays from collection onwards: Producers must finance the treatment, recovery and disposal of the waste arising from this equipment unless they make alternative arrangements with the business users.
MUST have been ready by August 13, 2005

20. Sensata Products Affected by WEEE & RoHS

21. Reporting Requirements
As with the Automotive OEMs, the electronic OEMs, because the obligation to demonstrate conformance rests with the OEMs, they have developed a variety of mechanisms for obtaining conformance data of their supply chains.
A supplier is obligated to utilize whatever mechanism provided by OEM:
Simple and Complex Certification Statements
EIA/EICTA/JGPSSI Tool
Web-based tools (such as IMDS in auto industry)

22. Collect Material Account Data
Base Material
Supplier
7AM
Cap Material
Supplier
Disc Material
Supplier
Converter/Washer
Supplier
Hexport
Supplier
Insulator
Supplier
Diaphragm
Supplier
O-ring, Gasket
Supplier
Silicone Seal
Supplier
Product Product Material Breakdown Query Suppliers

23. Reporting Requirements
Product Information
Bill of Materials defines the parts that need to be included in Material Content Breakdown
For each part:
Weights to 0.05 grams
Surface Areas to 0.1 cm2
Identification of the material of construction
Suppliers/Venders of materials of construction provide elemental breakdown of their materials.
Use of “jokers” allowable if confirmation that none of the prohibited/regulated materials are contained in undesignated portion.

24. Material Content Breakdown
7AM Full Material Content Breakdown
Hexavalent Chromium

25. Material Content Breakdown
7AM
Cadmium

26. Material Content Breakdown
7AM
Monovalent Chromium

27. Material Content Breakdown
7AM applicable directive: RoHS
7AM contains no Mercury or Lead
Polyester resin contains no restricted fire retardants.
Monovalent and Trivalent Chromium are not restricted by RoHS and are allowable at any concentration. NOTE: Both Monovalent and Trivalent Chromium are on the Material Declaration Datasheet as reportable substances.

28. Material Content Breakdown
7AM applicable directive: RoHS
Hexavalent Chromium:
RoHS limit for “unintentional incorporated” hexavalent chromium is 1.0 wt%. Hexavalent chromium is intentionally incorporated.
RoHS limit for “intentional incorporated” hexavalent chromium is 0.1 wt%. The wt% in 7AM is 0.003% -- which means that the chromating surface conforms to the RoHS limit.
In most cases, hexavalent chromium coatings specified by Sensata will not exceed this limit. Hard or decorative chromium plates will likely exceed.

29. Material Content Breakdown
7AM applicable directive: RoHS
Cadmium:
RoHS limit for “unintentional incorporation” is 0.1 wt%. The cadmium contained in this device is intentionally incorporated.
RoHS limit for “intentional incorporation” (proposed) is 0.01 wt% of homogeneous material. The cadmium contained in contact material is much greater.
In 1976, EU passed an exemption allowing cadmium in contacts in electromechanical safety devices (Regulation 76/69/EEC)
The material content prohibition of RoHS superceded this exemption – although S&C submitted a request in Sept to have this exemption added in the list of exemptions in RoHS.
The original design of is 7AM device did not conform to RoHS because of cadmium content of contacts.
Communicated to customer via following RoHS Declaration (or using tool required of customer)
Product Redesigned to meet RoHS Requirement

30. Supplier Management
Individual Material Content Declarations

32. Supplier Management Program
Customers specifically acknowledge all of the compliance information provided in this survey is accurate and complies with Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE), Directive 2003/108/EC amending Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE) and Directive 2002/95/EC on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS).
Should any components/parts you supply become non-compliant with the WEEE/RoHS Directives you will immediately notify, via , the Sensata Technolgies WEEE/RoHS Compliance Officer

33. Supplier Management Program

34. Supplier Management Program

35. Supplier Management Program
1,921 IMDS Entries Since Inception
3.8 – 7.6 Man Years of Effort
Small Percentage of Possible Product Variation
2CP15-16
37 Components
6 Entries
7AM
6 Components
Responded to 165 ELV, RoHS & WEEE Requests YTD 2006
66 Product Certification letters
Complete 99 IMDS Entries YTD
1142 Sensata Suppliers
636 Control’s Suppliers
506 Sensor’s Suppliers

36. Final Words
The Automotive Manufacturers response to the End-of-Life Vehicle directive provides one model for responding to the WEEE and RoHS directives.
Other industry sectors are investigating models for obtaining data similar product content data (electronics, white goods, aerospace).
Impacted industries are likely to extend the requirements of the EC directives to all of their products.
Regardless of the ultimate response model, the collection and management of Material Content Data within every company is a key task.

37. Final Words
Collecting Material Content Data is a cross-functional task and takes time for a company to learn:
Even if your company isn’t yet impacted by material content reporting requirements, it is worthwhile to begin collecting content data about your products (starting with Cr+6, Hg, Pb, Cd).
Level of effort necessary to collect data can be significant.
Be in front of the curve when material content reporting requirements for your industry arrive.
Changing product material content takes time/effort. Begin looking for technology platforms that avoid use of materials prohibited by the directives.

38. Regulatory Drivers Global View Current EU Directives:
WEEE, RoHS, ELV, EuP Battery, Packaging
Piecemeal state laws
(California SB 20/50, Maine, Ontario)
Pending EU Directives:
REACH, IPP, Battery Revision
China has RoHS and is preparing WEEE legislation
Japan Pb standards have been in place and electronics manufacturers have already responded

39. Valuable Links European Environmental Agency http://www.eea.eu.int/
The EU on-line
EU Directives – Legislative Summaries