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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 compliance for home appliance manufacturers

Global RoHS Compliancefor Home Appliance Manufacturers

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

May 23, 2007

  • Whirlpool Corporation Overview
  • RoHS Overview
  • Current and Pending RoHS Programs
  • Policy Implications
  • Compliance with RoHS
  • Conclusion
whirlpool corporation overview
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
whirlpool global operating platform
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


  • $457 M Sales
  • 6 Plants

Leading an $80 Billion Global Industry

what is rohs
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)
current and pending rohs programs
Current and Pending RoHS Programs
  • European Union – Directive 2002/95/EC
  • China
  • Japan
  • Korea
  • United States – State of California (limited to video display devices)
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.
china rohs
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.
japan rohs
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).
korea rohs
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.
california rohs
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.
compliance challenges
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
various end manufacturers strategy for rohs
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
typical sampling strategies for compliance testing
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
test methods
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
  • 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.
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]