RoHS and Green Flagships Explained @ Special Lighting ......ISO 11885: 1996 EN ISO 5961:1995 Lead and Lead alloys Metal XRF (FP-method (fundamental parameter, handheld) 1. XRF (desktop)

RoHS and Green Flagships Explained @ Special Lighting Roosendaal Marcel JacobsSustainability Officer ProductsPhilips LightingSeptember 4th 2006

CONFIDENTIAL 2RoHS Explained & FAQ by PD Lighting

Today’s objective

• RoHS introduction, explanation and update• RoHS Definitions and Exemptions explained [ELC]

– General Purpose v Special Purpose, Hg and Lead exemptions– Put on the Market

• Our Customers– OEM and Private Label

• RoHS Testing & Enforcement• Market Surveillance

• Green Flagships– Procedure and Process


Introduction RoHS

RoHS =• Restriction of Hazardous Substances• EU Directive 2002/95/EC and came into force per July 1st

2006• Relevant for Lighting products, but specific lighting

exemptions are temporarily allowed.• Products brought in distribution or sold to retailer,

wholesaler, distributor, OEM/ODM or private label after July 1st 2006 must be RoHS compliant

• A lamp can not be considered as Homogeneous material! [Homogeneous material means material that cannot be mechanically disjointed into different materials]

Violations in the past have shown:Costly and additional effort needed

Negative exposure effecting the Brand Image


RoHS Hazardous Substances

Substance Threshold [ppm] [%]Cadmium [Cd] 100 0,01Mercury [Hg] 1000 0,1Lead [Pb] 1000 0,1Chromium 6+ [Cr6+] 1000 0,1PBB Poly Brominated Byphenyls 1000 0,1PBDE Poly Brominated Diphenyls Ethers 1000 0,1

For specific Lighting related exemptions see:http://europa.eu.int/comm/environment/waste/weee_index.htm

http://www.elcfed.org

http://europa.eu.int/comm/environment/waste/weee_index.htm

http://www.elcfed.org/


For which products is RoHS applicable?

• For the Lighting industry the RoHS directive is applicable for almost all products put on the market in the EU, Switzerland, Norway and Iceland.

• The main hazardous materials concerned for lighting products are Lead an Mercury

• In the RoHS directive some products are exempted or are allowed to have a certain maximum level of the material concerned.


What does “RoHS compliant” mean?

• RoHS compliant means that the products fulfil the requirements of the RoHS directive.

• Also exempted products are also called “RoHS compliant” as these are exempted in the RoHS directive


A maximum concentration of 0,1% by weight in homogeneous materials for Lead and Mercury is exempted. • In the EU document “Frequently asked questions on Directive

2002/95/EC (RoHS)” definitions are given:

• As lamps can be ”mechanically disjointed” into different materials they cannot be considered as homogeneous material.


ELC: Exemptions on the use of Mercury

• Mercury -in CFL’s not exceeding 5mg per lamp.• Mercury -in Straight FL’s for general purpose not exceeding

(per lamp):• Halophosphate-10mg• Triphosphate [Triband phoshor](normal lifetime) -5mg• Triphosphate [Triband phoshor](long lifetime) -8mg

• Mercury -in Straight FL’s for special purposes (see slide 7)• Mercury -in other lamps not specifically mentioned in the

RoHS annex(see slide 8)


ELC: Exemptions on the use of Lead

• Lead in glass of Electronic components.– ELC definition is that starters & glow switches are electronic

components.Therefore these are exempted.

• Lead in glass of Fluorescent tubes The original proposal for theexemption was that lead containing glass is needed for exhaust tubes & flares of fluorescent lamps. Therefore this exemption only applies to these parts.

• Lead in high melting temperature type solders. These solders areneeded for high intensity discharge (HID), incandescent lamps for high temperature environments and high wattage incandescent/halogen to provide for safe electrical contact.

• Lead as alloying element in steel containing up to 0.35% lead by weight, in aluminum up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight


ELC: definition of lamps for ‘general purpose’ use

• Lamps for ’general’ lighting service are defined as:– Those products for general use in private & commercial application

areas.

• They generally possess the following characteristics:– General Lighting sources provide a level of visible light in the range

400 to 800 nm.– They are classified by the Energy Label.– They are highly standardized and interchangeable.– They are universally available.


ELC: definition of lamps for ‘special purpose’ use

• Lamps for Special purposes are needed where other, specific characteristics are prescribed.

• They generally have the following characteristics:– They are not marketed or commercialized primarily for the

production of visible light .– They are marketed however:

• Where the non-visible radiation has highest importance.• Where different looking lamp designs are relevant for use.• Where different applications require specific lamps.


ELC: Hg in Straight Fluorescent Lamps for Special Purposes(including diameters from 16mm up to 38 mm.)

• Fluorescent lamps for special purposes include for instance:– Black light lamps– Disinfection lamps– Medical/Therapy lamps– Food lighting applications, bakeries etc– Pet care lamps i.e. aquaria lamps– Lamps designed for UV emission like sun tanning lamps – Lamps with special components like integrated reflectors, external

protective sleeve or with external ignition strip.– Lamps with special ignition features for example those designed for

low temperatures.– Long length lamps (length i.e. 8’/2400mm)– Amalgam lamps– Cold Cathode Fluorescent Lamps


Other ELC definitions• Lead in lamp marking–The mark is part of the lamp glass and is

therefore defined as a homogeneous material below the maximum concentration limit of 0.1% by weight.

• Put on the market–The ELC supports the text defined in the European Commission Frequently Asked Questions on Dir RoHS 2002/95/EC andWEEE 2002/96/EC.

• “The words ‘put on the market’ in Article 10(3) of the WEEE directive and Art 4(1) of the RoHS directive refer to the initial action of making a product available for the first time on the community market. This takes place when the product is transferred (e.g. physical handover or transfer of ownership) from the producer to a distributor or final consumer or user in the community market.”

• Discharge lamps for special purposes containing lead as activator in the fluorescent powder (1% lead by weight or less).Lead is essential for creating the proper lamp emission spectrum and lamp efficacy.


Lamps ‘put on the market’ by OEM's

• A lamp is an 'electrical and electronic equipment' in the sense of the Directive, therefore:

– Any lamp supplied to an OEM prior to 1 July 2006, is put on the market (and thus RoHS compliant).


‘Put on the market’ for Private Label

• A private label owner is also considered a producer (art. 3 of Directive) and has an independent obligation under the RoHS Directive to sell compliant products after 1 July 2006.

• Private label owners have an independent obligation to supply compliant products as of 1 July 2006 onwards.

• The products that are on the shelves of the private label owners on 1 July 2006 are compliant with the RoHS Directive since they have been put on the market prior to 1 July by ELC member companies.

• There is no need to treat products carrying a private label, more severely than similar products without private label.


Supply Chain Responsibility

High RiskComponents

Supplier PhilipsSG

PhilipsNSO

EU MarketSurveillance

Non RoHS compliant product:1. Additional sampling2. Check Self Declaration3. Verify testing/screening

Evidence

Eliminate High Risk and reduce

Medium Risk Components

Verification focus on:Incident versus structural problem

Medium RiskComponents

Low RiskComponents

IQC via SOP /Guideline

OQC via SOP /Guideline


RoHS testing methodsSubstance class Matrix Method for

screening Method for Verification Standard Reference

Cadmium Compounds Lead compounds

Plastic, rubber, paints, inks

XRF (handheld) 1. XRF (desktop) 2. AAS 3. ICP-OES

Sample preparation Cd only EN1122:2001 Analytical method Cd: ISO 3856-4:1984 ISO 11885:1996 Sample preparation Pb and Cd EN 13346:2000 or EPA 3052:1996 EPA3050B Rev. 2: 1996 or EN 13346:2000 BS EN 1122:2001 (modified) Analytical method Pb and Cd ISO 11885: 1996 EN ISO 5961:1995

Lead and Lead alloys Metal XRF (FP-method (fundamental parameter, handheld)

1. XRF (desktop) 2. ICP-OES

Mercury compounds Plastic, rubber, paints, inks

XRF (handheld) 1. XRF (desktop) 2. CV-AAS with vapour hydride generation apparatus 3. CV-AAS with thermal decomposition and/or gold-amalgamation 4. ICP-OES with vapour hydride generation apparatus

Sample preparation EN 13346 EPA 3052:1996 Analytical method EN 12338

Mercury Metal CV-AAS with thermal decomposition for analyzing Mercury content in fluorescent tubes

Hexavalent Chromium compounds

Metal 1. XRF (handheld, total chromium) 2. Dip test (qualitative)

1. Derivatization with Diphenylcarbazide followed by UV/VIS spectroscopy at 540nm 2. Grinding and measuring the water extract with ICP-OES (method not verified)

ISO 3613:2000 Dip test: ZVO-0102-QUA-02 UV/Vis method: ZVO-0101-UV-05

Polybrominated biphenyls (PBB) Polybrominated diphenyl ethers (PBDE)

Plastics Total bromine content/ for confirmation of total bromine free: 1. XRF (handheld) 2. HPLC 3. Ion chromatography

For identification of PBB and PBDE >30000ppm: FT-IR For identification and quantification: GC/MS (HRGC/MS)

Method currently under development, eg Raman Spectroscopy


RoHS enforcement Guidance

• Presumption of Conformity• Self-declaration from producers as key principle underlying

the enforcement process• Step-by-step

– Initial self declaration: “ Supply Chain RoHS management process”• Based on documentary evidence of structured internal systems (based

on quality assurance processes)• Process facilitation by initial provision of compliance documentation for

products /parts– Followed by more detailed assessment in those cases where

evidence from producers does not assure compliance (product / part / material)

– In case of concern, detailed sampling and testing may or could be required


General comments on Enforcement

• At the highest level: show evidence of supply chain RoHS management process

– It should be integrated in Company Quality management system– For example: ISO9001 and 14001 (latter: legal requirements)– Sub-tier suppliers are responsible to manage RoHS and provide

evidence accordingly [based on Self Declaration]

• Note: we want to avoid third party certification– Still running is a “fast track” standardization approach– Quality management systems are externally certified– When proper integrated, a separate RoHS certification is not

required


RoHS Compliance Self Declaration


RoHS self declaration GeneralTable 1 - Typical List of Overview Documentation

Contact information

Point of contact within the organization that will deal with the RoHS enforcement request.

Company information

This should include the size of the organization, product range and approximate levels of sales. This will aid the enforcement authority in assessing the technical data specified in Table 2 in the context of its potential environmental impact.

Approach to compliance

This should be a general overview of any compliance systems that the company has in place and which are suitable for assisting compliance with the RoHS Directive.

An overview of the data quality systems, (in those cases where the producer relies significantly upon supplier information to demonstrate compliance)

This could include risk assessments, acceptance criteria, purchasing procedures and any other relevant documentation and may be a combination of both process-based and product/part-based documentation.


RoHS Self Declaration ProcessRoute A: Process-based Technical Documentation(Typical information relating to the producer’s internal system to ensure RoHS compliance)

Compliance Assurance System (CAS)• 1) A definition of the purpose of the system, its essential requirements and specification. This

specification should cover compliance both within the company and within the supply chain • 2) A formally defined process which implements the requirements of the system and is integrated

within the organisation’s quality and management systems• 3) A technical documentation system (paper and/or electronic) to support the process and

measures to assure conformity with the requirements of the system together with necessary training, tools and infrastructure.

Evidence of Active Control of the CAS• 4) Results of internal and supplier audits to validate Compliance Assurance System and/or

processes. i.e. the supplier’s ability to assure compliance. • 5) Evidence that the system is being followed including results of product specific conformance

assessments comprising items such as product assessments (including justification of RoHS categorisation and use of exemptions), materials declarations, procurement, inventory and production controls and substance analysis where appropriate

• 6) Overview of any internal data system used for the management of RoHS compliance data


RoHS Self Declaration ProductsRoute B: Product/Part-based Technical Documentation(Typical information relating to a product’s/part’s physical attributes that ensures RoHS

compliance of a specific product)

• 7) Producers’ or suppliers’ warranties /certificates declaring that the use of the restricted substances is within the permitted levels

• 8) Producers’ or suppliers’ completed materials declaration for each part (including revision for revised parts) and justification of RoHS categorisation and use of exemptions. These declarations would be limited to the list of RoHS substances, not full materials declarations

• 9) Analysis report for homogeneous materials in parts/components, (which could be the producers or suppliers own internal or external test results). The test results should refer to homogenous materials in parts/components.

• 10) Those who use approach B only (SMEs) must also provide evidence that procedures are being followed to show that materials declarations have been assessed to determine if they can be trusted. Enforcement authorities will also need to see documented compliance procedures


Sampling & Testing (2)

Screening via ED-XRF [Energy Dispersed X-Ray Fluorescence]

Niton XLT 797 ZW [Gold tube]• Cheap and quick scanning method [5* 100sec.]• For screening purposes Niton has sufficient accuracy• Flexible equipment, table top and portable• Many substances can be measured in one test• For verification purposes, no destruction of components or

products• Customs use same type of equipment for legal compliance

testing and screening• One Philips approach [Lighting, CE, DAP]• 2 way-NDA with NITON and full support


What does “put on the market” exactly mean (1)?

• In the EU document “Guide to the implementation of directives” placing on the market means:

– “A product is placed on the Community market when it is made available for the first time. This is considered to take place when the product is transferred from the stage of manufacture with the intention of distribution or use on the Community market”

• The ELC interpretation based on above mentioned definition:

– “This takes place when the product is transferred (e.g. physicalhandover or transfer of ownership) from the producer to a distributor or final consumer or user in the community market.”


What does “put on the market” exactly mean (2)?• The EU and ELC interpretation mean

– when the product is delivered from the Philips warehouse to a distributor or final customer it is put on the EU market

– when a non RoHS compliant product has been delivered before 1-7-2006 to a distributor, the product may be distributed further in the EU market after 1-7-2006 (as it was “put on the market” before 1-7-2006)

– The industry may deliver non RoHS complying products till 1-7-2006


Market Surveillance

National Authorities[RIVM, VROM]

• Penalties [app. 10K-1MEur]• Shipment Blocking• Media Coverage

Compliancy Verification

Status of preparation,

When starting??

NationalConsumer

Associations• Media CoverageCompliancy

Verification

When, How, Whom, Where???

General BrandDamaged!


What about the stocks of non complying products with our customers after 1-7-2006?

• In case our customer is a distributor, the products delivered before 1-7-2006 have been “put on the market” before 1-7-2006. The customer may distribute these products further in the EU market after 1-7-2006.

• When the OEM is our customer, the situation is different:– Lamps are not considered as component. – OEM is considered as distributor. – OEM is allowed to supply non-complying lamps with its luminaires

after 1-7-2006. – Gear is considered as component of a luminaire. After 1-7-2006

OEM may only supply luminaires with RoHS complying components.

– OEM had to finish its stock before 1-7-2006.


Spare parts are exempted in RoHS. When is a product a spare part?ELC expects the following definition for spare part:• A product meant to be used for the repair, or the re-use, of

electrical and electronic equipment put on the market before 1 July 2006 can be considered as spare part. [Lamps and Gear in lighting systems].

• The product is not commercial available anymore in the current portfolio but can be listed in a separate spare part catalogue or listing

• Inform customers having long term service and maintenance contracts started before [I.e. 2003] on the possible implications Spare parts can not be sold to extend existing installations or in new installations

• In general, lamps for replacement in existing installation cannot be considered as spare parts


Which official information can we give to customers?

• There are official PD Lighting RoHS compliancy declarations available drafted by the Sustainability Support Team and checked by Legal department.

• Translations to be made locally and to be checked by local legal department.

• Certificates provided via Sustainability Support team:– Data provided by BU is Product name, EOC & Customers Address


How to handle in case customers ask for external test reports?

• It is not feasible to test all our products externally

• Customers will have to accept our general conformity certificates

• ELC standpoint: no test reports to customers, conformity will be checked by official authorities according EU guidelines


How to deal with return shipments?

• Return shipments will disturb this process and should be avoided as much as possible.

• Return shipments will be blocked and checked on RoHS compliance (at extra cost). No credit notes for non complying products.

• ELC standpoint:

• convince customers that they may continue distribution of products put on the market before 1-7-2006

Documents

RoHS and Green Flagships Explained @ Special Lighting ......ISO 11885: 1996 EN ISO 5961:1995 Lead and Lead alloys Metal XRF (FP-method (fundamental parameter, handheld) 1. XRF (desktop)