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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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OutlineWhirlpool Corporation OverviewRoHS OverviewCurrent and Pending RoHS ProgramsPolicy ImplicationsCompliance with RoHSConclusion

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Whirlpool Corporation OverviewLargest global manufacturer and marketer of major home appliancesAnnual sales of more than $18 billion73,000 employeesOver 70 manufacturing and technology research centers around the

globeMarket 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

Leading an $80 Billion Global Industry Leading an $80 Billion Global Industry

$18 B Revenues73,000 employees

#1 Global Share#1 Global Brand

#1 N.America $12 B Sales 24 Plants

#1 L.America $2.4 B Sales 5 Plants

#4 Europe $3.4 B Sales 13 Plants

Asia $457 M Sales 6 Plants

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Components

Engineering & Design

Components

Strategy Supports Best Cost, Best Quality Products

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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 ProgramsEuropean Union – Directive 2002/95/ECChinaJapanKoreaUnited States – State of California (limited to video display devices)

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EU RoHS Implemented July 1, 2006Compliance 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 RoHSPhase 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 RoHSDesign 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 RoHSRequirements 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 RoHSCurrently under consideration in the California LegislatureConsistent 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 BoardPassage is likely in 2007.

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Compliance ChallengesObtaining and verifying data on thousands of parts from around the

worldVague and varying regulationsNo common reporting because of various states, languages, formats,

etc.Constantly changing parts and componentsLack of best practices for mitigating risk

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Various End Manufacturers Strategy for RoHSNo single universal approachCan have thousands of components with multiple homogenous

materials eachToo many components for one company to feasibly deal with by itselfMost rely on reporting from supplier base

Letters of compliance Test data showing compliance

In-house testing3rd 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 approachTest 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 MethodsNo single universal approachMany 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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ConclusionRoHS regulations are being implemented globally, not just in the EUDespite 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 HarmsSenior Metallurgical Engineer Government Relations SpecialistWhirlpool Corporation Whirlpool Corporation269-923-4210 [email protected] [email protected]

Documents

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