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Global RoHS Compliance for Home Appliance Manufacturers. ASTM International Technical Committee A05 – Metallic-Coated Iron and Steel Products May 23, 2007. Outline. Whirlpool Corporation Overview RoHS Overview Current and Pending RoHS Programs Policy Implications Compliance with RoHS

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Global RoHS Compliancefor Home Appliance Manufacturers

ASTM International Technical Committee A05 – Metallic-Coated Iron and Steel Products

May 23, 2007


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Outline

  • Whirlpool Corporation Overview

  • RoHS Overview

  • Current and Pending RoHS Programs

  • Policy Implications

  • Compliance with RoHS

  • Conclusion


Whirlpool corporation overview l.jpg
Whirlpool Corporation Overview

  • Largest global manufacturer and marketer of major home appliances

  • Annual sales of more than $18 billion

  • 73,000 employees

  • Over 70 manufacturing and technology research centers around the globe

  • Market Whirlpool, KitchenAid, Maytag, Jenn-Air, Amana, Brastemp, Bauknecht, Consul and other major brands to consumers in more than 170 countries.

  • Additional information at www.whirlpoolcorp.com.


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Whirlpool Global Operating Platform

#1 N.America

  • $12 B Sales

  • 24 Plants

#4 Europe

  • $3.4 B Sales

  • 13 Plants

$18 B Revenues

73,000 employees

#1 Global Share

#1 Global Brand

#1 L.America

  • $2.4 B Sales

  • 5 Plants

Asia

  • $457 M Sales

  • 6 Plants

Leading an $80 Billion Global Industry



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What is RoHS?

  • RoHS regulations generally restrict the following substances in electronic and electrical equipment:

    • Lead

    • Mercury

    • Cadmium

    • Hexavalent Chromium (Cr6+)

    • Polybrominated biphenyls (PBBs)

    • Polybrominated diphenyl ether (PDE)


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Current and Pending RoHS Programs

  • European Union – Directive 2002/95/EC

  • China

  • Japan

  • Korea

  • United States – State of California (limited to video display devices)


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EU RoHS

  • Implemented July 1, 2006

  • Compliance is the responsibility of the company that puts the product on the market.

  • In some cases, regulations are inconsistent because each member state adopted separate implementing standards and enforcement procedures.

  • Contains broad definition of “electronic and electrical equipment” and contains specific exemptions for certain products.

  • Maximum concentration is 1000 ppm, except Cadmium, which is 100 ppm.

  • Everything identified as homogenous must meet the requirements.


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China RoHS

  • Phase 1 (March 1, 2007):

    • Marking requirements for electronic information products

    • Environment-friendly use period must be indicated inside the pollution control symbol.

  • Phase 2 (timetable uncertain, likely 2008):

    • Restrictions on Hazardous Substances

      • Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs, PBDEs

      • Indications are that major appliances will be excluded, with exception of microwaves.

      • Replacement parts for appliances will be subject to RoHS if listed on the catalogue.


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Japan RoHS

  • Design for Environment (DfE) criteria (promulgated in 2000)

    • Rationalize use of raw materials

    • Use recycable and reusable parts

    • Promote long-term use of products

  • The cabinet member with jurisdiction establishes basic policy and requirements for industry

  • Changes effective July 1, 2006:

    • Manufacturers of computers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must label products to indicate presence of Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs and PBDEs.

    • Importers of computers, copiers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must meet Design for Environment Criteria (DfE).


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Korea RoHS

  • Requirements include:

    • Restrictions of hazardous substances in electrical/electronic equipment and vehicles

    • Improvement of materials and structure

    • Recycling requirements for manufacturers and importers

    • Mandatory recycling rate

    • Establishment of an Operation and Management Information System

  • Implementation date: January 1, 2008

    • However, implementation date does not mean anything until decisions are ordered by Presidential Decree.


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California RoHS

  • Currently under consideration in the California Legislature

  • Consistent with EU RoHS regulations, with the following exceptions:

    • Applies to products manufactured on or after January 1, 2010

    • Applies only to mercury, lead, cadmium and hexavalent chromium (PBBs and PBDEs are excluded)

    • Excludes fixed installations

    • Twenty-four month grace period for products that lose their RoHS exemption

    • Exempts products that are refurbished or sold for reuse

    • Specific exemptions for spare parts

    • A process for securing exemptions or time extensions

  • Annual reporting to California Integrated Waste Management Board

  • Passage is likely in 2007.


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Compliance Challenges

  • Obtaining and verifying data on thousands of parts from around the world

  • Vague and varying regulations

  • No common reporting because of various states, languages, formats, etc.

  • Constantly changing parts and components

  • Lack of best practices for mitigating risk


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Various End Manufacturers Strategy for RoHS

  • No single universal approach

  • Can have thousands of components with multiple homogenous materials each

  • Too many components for one company to feasibly deal with by itself

  • Most rely on reporting from supplier base

    • Letters of compliance

    • Test data showing compliance

      • In-house testing

      • 3rd party testing

    • Often requested from Tier 1 suppliers, which trickles down the supply chain

  • Mixed strategies commonly used

    • Components and suppliers are ranked into categories based on degree of risk

    • Level of documentation and testing can increase with each category


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Typical Sampling Strategies for Compliance Testing

  • No single universal approach

  • Test every lot of material

    • Unusual except when lots of material commonly come from unknown production sources (commodity buyers, resellers, etc).

  • Test once for each part # produced.

    • Retest when any changes in material, source, or process occurs (similar to PPAP)

  • Test once for each part # used to produce multiple part #’s (e.g., cutting a larger coil of steel into various smaller width coils).

    • May apply conformance to all downstream part #’s where no RoHS materials are added

    • Retest when any changes in material, source, or process occurs.

  • Typically, any change that occurs that would prompt sending production samples for engineering approval should prompt a decision as to whether a RoHS compliance retest is needed


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Test Methods

  • No single universal approach

  • Many various test methods, highly dependant on the material, processing method, and type of component

  • 3rd Party Testing

    • Currently no official accreditation process for 3rd party labs

    • Some companies have list of labs they use or accept results from

  • Internal Testing

    • Many large companies use internal screening tests to reduce the amount of expensive 3rd party tests (~$200-$400/sample)

    • Portable XRF testers have become very popular

      • 30 seconds/test

      • Provides elemental analysis only (cannot tell difference between Cr6+ and Cr)

      • Not very useful for certain materials

    • ASTM D6492 or ISO 3613 spot tests for detecting presence of chromate conversion coatings


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Conclusion

  • RoHS regulations are being implemented globally, not just in the EU

  • Despite having extensive global supply chains, manufacturers have developed and are continuing to enhance compliance procedures.


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Questions or Comments?

Contact information:

Brandon Bokhart Luke Harms

Senior Metallurgical Engineer Government Relations Specialist

Whirlpool Corporation Whirlpool Corporation

269-923-4210 202-639-9420

[email protected] [email protected]


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