In a simple example of a chip capacitor used in a majority of electronic products today, SGS shows how complex it can be to identify and report on the materials used in an electronic component. This is a growing challenge for electrical and electronics suppliers and manufacturers as they need to deal with growing demand to be accountable for every molecule of material contained in their products, which may impact the health of the environment, consumers and workers responsible for the manufacturing of products, and for the recovery, recycling and disposal of end of life products, said SGS.
And the number of environmental regulations continues to grow at an astounding rate. In 2002, there were about 25 enacted regulations for substance restrictions globally, and in 2013, that has grown to about 200, according to SGS. "The products in scope of the regulations also has grown due to legislation such as EU RoHS, EU REACH, China RoHS, Korea RoHS, California Proposition 65 and a long list of similar country legislations either enacted or proposed and soon to be enacted," said Kenneth Stanvick, Environmental Compliance Management, senior consultant, electrical and electronics at SGS North America Inc., in a press release.
Stanvick said the EU REACH is sometimes referred to as an “environmental compliance moving target." Currently, the REACH list of Substances of Very High Concern (SVHC) consists of 144 substances. Stanvick said this will be added to every six months.
"If your company has not put in place processes necessary to cost effectively manage the collection, risk assessment, and quality assessment of material data across a complex supply chain, then your corporate ship has struck the proverbial 'environmental iceberg'," said Stanvick.
Why is materials reporting a daunting task? Take a look at the SGS example. The chip capacitor consists of six homogeneous materials containing seven unique substances that need to be identified and analyzed. They are as follows:
- Ceramic Dielectric – Barium Titanate – Nickel Compound
- Internal Electrode – Palladium – Silver
- Termination – Silver – Sodium Borosilicate
- Plating – Nickel – Tin
In addition, the materials and substances data "must be stored and accessible by various functions within your company, as well as country enforcement agencies, consumers, and possibly your B2B customers," said Stanvick.
"If this component is sourced from multiple manufacturers it is easy to see how this could result in a large increase in the number of records needing to be managed," he further stated.
Three Links in the Chain
The first link in the chain starts with raw materials disclosure. In this example, the materials supplier of barium titanate, silver or tin will need to identify and report the chemical composition of the supplied materials to the capacitor manufacturer. Stanvick said "think of this as the start of a chain of custody for material composition disclosure."
If the chip capacitor manufacturer has obtained material composition disclosure information from its suppliers, of which there may be multiple sources, then the component maker has the necessary information to provide to the customer. This is the second link in the chain, said Stanvick.
However, if the materials supplier cannot or will not provide the materials and substance information, the capacitor manufacturer will need to take further actions such as removing the supplier from the approved vendors list (AVL). If this is not feasible the material will need to be analyzed by an accredited materials testing laboratory until an alternate supplier is found or the supplier is able to provide the data.
Purchasing caveat: It is not a best practice to qualify a supplier who is unable or unwilling to meet a customer's requirements, said Stanvick. "You cannot afford to be the cause of a broken link in the supply chain."
The final link in the supply chain is the original equipment manufacturer (OEM). OEMs need to have a system in place to store and manage the supplier data linked to the product's bill of material (BOM). In addition, the data must be made available to internal departments as well as to external enterprises. For example, the data records, in the case of RoHS II, would become part of the Technical Documentation File for your product and must be kept on file for ten years and made available to an EU member state enforcement officer when requested, said Stanvick.
Now multiple this process by all your BOMs and product lines, and it adds up to a considerable amount of data that must be collected and stored. When it comes to environmental compliance, there can be no shortcuts. Due diligence is the name of the game, and component manufacturers and OEMs need to stay on top of their materials reporting particularly as the number of environmental regulations continue to grow.