Materially deficient
Think your parts are green? Be prepared to prove it!
By Michael Kirschner -- EDN, August 1, 2004
Companies may be facing fireworks come the 4th of July weekend in 2006, and not because it'll be the 230th anniversary of America's Declaration of Independence. It's because July 1, 2006, will require a different kind of declaration—one in which the EU will require companies to show they've essentially eliminated hazardous materials in their electronics components.
Compliance with the EU's two directives—Reduction of Hazardous Substances (RoHS) and Waste Electrical and Electronic Equipment (WEEE)—requires understanding which materials are contained in the components OEMs use to build their products. My firm, Design Chain Associates, among the other services it provides, helps electronics OEMs collect and roll up this kind of data (commonly called Material Declaration or Material Content Forms), and I'm here to tell you that what we've seen in the component industry (not to mention in the machine shops and injection molders) in terms of compliance has been generally underwhelming.
There are exceptions. Both Texas Instruments and Samtec (neither of which DCA represents) have detailed component-specific information easily accessible on their Web sites. But generally, it's alarming how many semiconductor and other component manufacturers seem to be unaware of detailed and precise information regarding the material content of their products or are unable or unwilling to provide this information to their customers. And many of them are extraordinarily prominent.
What we hear more often than we'd like when we ask component manufacturers for detailed material content information is variations of the following:
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"Our parts don't have any hazardous materials in them, so why are you asking?"
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"Here's a letter stating that we're green."
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"We provide the minimum amount of information on a few of the materials as required by the as-yet unapproved Joint Industry Guide's Material Composition Declaration Guide. (We know that the JIG doesn't meet the requirements of most large electronics OEMs, but it meets our needs as a component supplier)."
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"Here's a big pile of data on packages, not specific to the part you're using—and by the way, it's not all the material in the package, just some of it we thought you might be interested in; now you go figure out what applies to the parts you buy from us."
This is surprising, given that many large OEMs have taken it upon themselves to require this information from their supply base over the past few years. Maybe it's just that our clients use a supply base orthogonal to those of Sony, Nokia, Toshiba, Hitachi, Motorola and the automotive industry. But I doubt it.
The number of manufacturers that are currently unaware of or unable to provide detailed information about material content is alarming.
Besides meeting the WEEE directive's required level of materials disclosure, it's also important to be able to put together a convincing story about your product's compliance with RoHS. Although there is (as of this writing) no defined mechanism for proving product-level compliance (perhaps in a court of law), the only way that's obvious to us is to provide evidence of component-level material compliance. Another reason this is important: It will become even more critical to know what your product is made of as more and more chemicals, compounds and materials are added to the directive.
So this is our message to the component industry: Please gear up and help your customers with this task. Your customers need to understand today where they stand, so they can deal with existing products, products currently in design and their product road maps.
Are you encountering problems when it comes to keeping green? Tell us your troubles in an e-mail tofeedback@eb.reedbusiness.com .
Michael Kirschner is president of Design Chain Associates, a consulting firm that helps companies attain supply chain efficiency.
