Stuart SleemanPrincipal

Sleeman Hanley & DiNitto, Inc

TI ESH Support

A Review of the Impact of European Union Environmental Directives

Texas Instruments2005

TI Revenues ($Million)

Semiconductor 11,700Sensors & Controls 1,200Educational & 500Productivity Solutions

Ranked 167 – Fortune 500 (Based on Revenue)

Texas Instruments Incorporated

SCS&CEP&C

Striving to be the World’s Premier Electronics Company

S&C Comprised of three major business units:

Sensors

Controls

Radio Frequency Identification

More than 6,000 employees around the globe

Technology Development and Manufacturing in nine locations in the Americas, Asia and Europe

Sensors & Controls

Sensors & Controls

EC Directives/Material Content Reporting

EC Directives (WEEE; ROHS & ELV)

Directive on Waste Electrical and Electronic Equipment (WEEE)Directive on Restriction of Use of Certain Hazardous Substances (RoHS)Directive on End-of-Life Vehicles (ELV)

Product Content Issue ManagementTI Decisions &

Strategy• Business-Wide

Strategy

• Planning and Roadmaps

• TI Ban List Content Decisions

• Strategy for Customers

• Strategy for Suppliers

Execution

• Internal Manufacturing• Specifications• Chemicals & Materials• Equipment• Change Control

• External Manufacturing• Specifications• Subcons/Foundries• Change Control

• R&D• Market Management

• Internal Communication of Decisions

• External Communication and Customer Management

• Supplier Management• Ban List Management

RequirementsCustomer Requirements:

Contracts and specificationsSurveys/DeclarationsInfluence

Current and Horizon Legislation/ Industry Standards

Discover and UnderstandInfluence

Science and R&D

EU Material Content Directives

Vehicle End of Life Directive

Sensors & ControlsS&C manufactures sensors that are used in various automotive systems.

Supply to all the major automakers directly as a tier one supplier or through others as a sub-tier supplier.IMDS Entry Requirements:- existing product lines- new product lines (PPAP)- 50% - 70% complete

Automotive SensorsCoolant Level

AirConditioning

PowerSteering

ABS

OilPressure

AngularRateSensor

Low GAccel.

Trans-mission

OccupantWeight

TirePressure

End of Life Vehicles Directive

The European Parliament & the Council of European Union signed the End-of-Life vehicle directive on 9/18/00. Directive 2000/53/EC, effective 1/03.Objective is the prevention of waste from vehicles and also the reuse, recycle, & recovery of end-of life vehicles and components, thus improving environmental performance for all economic operators involved.Automobile producers to provide appropriate information to treatment facilities, concerning dismantling, and re-use

End of Life Vehicles DirectiveRequirements:

Ban on the use of hazardous substances (lead, mercury, cadmium, hexavalent chromium) with exemptions.

Total limit @ 2.0 grams/vehicle of Cr+6 for corrosion protection purpose only; 0.0 gram for any other application in June 2003

Requirements for the re-use and recovery at vehicle end-of-life.

Achieve re-use and recyclability of at least 85% average vehicle weight by 2005 with greater percentages for 2015

Improve recycled content.

End-of-Life disposition information

End of Life Vehicles Directive

85 % re-use / recovery80 % re-use / recycling

95 % re-use / recovery85 % re-use / recycling

2000 2005 2010Year 20151/20077/2002 7/2003

95 % re-useable / recoverable85 % re-useable / recyclable

delivery to treatment facility with no cost for last holder and/or ownerNew Vehicles

Vehicle Population

delivery to treatment facility with no cost for last holder and/or owner

End-of-Life VehiclesTreatment:Targets to be achieved

2006

provision of dismantling information

TypeApproval

free from lead, mercury, cadmium and chromium VI (exemptions listed in Annex II)

End of Life Vehicles DirectiveIn 2000, the automotive manufacturers were faced with the challenge of how to meet the requirements of the End-of-Life Vehicle directive.

Certify that their products do not contain prohibited hazardous substances.

Demonstrate the percent of recycled content built into their products.

Demonstrate the percent of their products that can be re-used or recycled at end-of-life

Provide appropriate information to treatment facilities concerning the dismantling, re-use and recycling of their products.

End of Life Vehicles DirectiveDevelopment of the Automotive Manufacturer strategy:

Starting in 1996, the Association of Automotive Manufacturers established a procedure for the collection of material content data (Material Data Sheets).

Concurrently, investigation began on automated systems for providing/obtaining material content data:

Individual queries of each and every supplier regarding the material content of their productsProduct Material Content Web (or equivalent) to be queried, as necessaryProduct Material Content Web provided by the customer with data inputs required of the supplier

In 1998, the Automotive Manufacturers developed an electronic system, the International Material Data System (IMDS at http://www.mdsystem.com).

End of Life Vehicles Directive

End of Life Vehicles DirectiveSupplier Responsibilities in IMDS.

It is the position of the automotive manufacturers that suppliers are responsible for both entering their data into IMDS and rolling data entry requirements to their suppliers.

Tier One suppliers to cascade information to their suppliers.Suppliers Register into IMDS.Report the material content of their products directly into IMDSTier One suppliers retrieve the information from IMDS and report to the Automotive Manufacturers.

Penalties for Suppliers who fail to input data.

Preference for Suppliers with products without restricted materials.

Collect Material Account DataOEM

ProductOwner

Material Composition Information

Gather Info Supplier

Supplier

Supplier

SupplierProductOwner

Tier 1Tier 2

Gather Info Supplier

Supplier

Supplier

Supplier

Material Composition Information

IMDS provides a common method for identifying materials, substances and attributesSuppliers proactively send material composition information

IMDS manages aggregated data sent forward through the supply chain.

Gather Info Supplier

Supplier

Supplier

Supplier

Material Composition Information

ProductOwner

Tier 3

End of Life Vehicles Directive

IMDS: One CertificationProcedure for the Industry

20062000 2002

Each Automaker has established their own schedule for entering material content information into IMDS.Each Automaker has defined the criteria of an acceptable IMDS entry.Ford Restricted Substance Management Standard (WS-M99P9999-A1)All substances listed in the Restricted Substance Standard (GMW3059) must be reported

System Description

End of Life Vehicles DirectiveThe IMDS System requires 100% material content reporting including both regulated and non-regulated substances.Significant level of detail – requires input from material and component vendors within the supply chain.

The document generated is called an “MDS” or Material Data Sheet (See following example).

IMPORTANT NOTE: This is different than a Material Safety Data Sheet or MSDS. An MSDS is a document that provides health safety information.

Collect Material Account DataBase Material

SupplierCap Material

SupplierDisc Material

Component Description76118-2 base cap76199-1 cap seal

28924-1 disc seat

28780-1 converter28714-2 washer

37660-1 formed disc28817-2 Hexport28925-1 insulator

28814-1diaphragm

bonded46705-3 USCAR Base76144-1 o-ring

28931-1 gasket76096-1 silicone seal

ULTEM PLASTIC CONVERTER

NICKEL PLATEDTERMINAL BUMP

UV SILICONE SEALANT

BRASS HEX BODY

VITON GASKET

HNBR O-RING

TIN PLATED TERMINAL

SS DISC

SILVER PLATEDCRS DISC SEAT CUP

ZINC PLATED CRS WASHER

2 LAYERDIAPHRAGM

PPS PLASTICBASE

93PSL2-1 / 93PSL2-3

InsulatorSupplier

DiaphragmSupplier

O-ring, GasketSupplier

Silicone SealSupplier

SupplierConverter/Washer

Supplier

HexportSupplier

TI Product Product Material Breakdown Query Suppliers

End of Life Vehicles Directive

APT (2CP15-16) applicable directive: ELVLead: This device uses lead for multiple purposes:

Alloy (12L14 Stainless Steel)Electronics (Solder, Metallization)Ceramic (CSE Glass)

In 2002, the EU developed “Annex II” that established exemptions for lead use.

Lead in Alloys Electronic circuits

End of Life Vehicles Directive

Hexavalent Chromium: This product has been converted to trivalent chromium.

Many automotive products continue to be plated with hexavalent chromium. Conversion to trivalent chromium, other non-chrome coatings, or other material has been driven by OEMs.

“Annex II” provides an exemption until 2007 for situations where hexavalent chromium is the only feasible corrosion inhibitor.

Most OEMs have set elimination dates earlier than 2007.

End of Life Vehicles Directive

Mercury/Cadmium: This product does not contain these metals.Flame Retardants: Based on certifications from resin suppliers, the resins for TI molded components do not contain restricted flame retardants. Flex Circuit supplier has not fully certified all subcomponents of the populated board.

The APT (2CP15-16) conforms to ELV Material Content requirements.

EU Material Content Directives

RoHS & WEEE

Waste Electrical & Electronic Equipment [Directive 2002/96/EC]

Sets criteria for collection, treatment, recycling and recovery of waste electrical and electronic equipment Makes Producers Responsible

Transport from collection facilitiesFinancially responsible for treatment, recovery and disposalHouseholds/Final Holders and Distributors of WEEE can return such equipment free of charge

Recovery Targets Set for Collection from Households

Restriction on Use of Certain Hazardous Substances in EEE [RoHS]

[Directive 2002/95/EC]

Facilitates dismantling and recycling of waste electrical and electronic equipment by restricting use of hazardous substances in manufacturingLead, mercury, cadmium, hexavalent chromium, PBBs and PBDEs banned by July 2006

Sony swaps PlayStation One cablesLast modified: December 5, 2001, 11:55 AM PST

By Reuters

Sony is replacing peripheral cables for 1.3 million PlayStation One game consoles after the Dutch government blocked sales of the machines because of health and environmental concerns.The Dutch government said Tuesday it had blocked shipment of the consoles and 800,000 accessories bound for the European Union market in a warehouse in the Netherlands because the cables contained too much cadmium. On Wednesday, Sony said it had already started replacing the cables. It hoped to resume limited shipments of the consoles by mid-December. "Although we have reservations about the interpretation of the regulations (by the Dutch authorities), we have begun replacing the cables," a Sony representative said. Sony said its newer PlayStation 2 consoles were not affected by the ruling because they do not use the same cables. The company will not replace cables for PlayStation One consoles sold in countries outside Europe if they did not violate environmental regulations in those nations, the company said. Sony also said it will not recall any consoles already sold in Europe because the amount of cadmium in the cables does not--in its view--pose a health risk. The cadmium contained in the cables only poses a risk if incorrectly disposed of, in which case it could have long-term environmental effects, Sony said. Within the European Union, no goods are allowed to be imported that contain more than 0.01 percent cadmium. The Netherlands said the cables contained three times to 20 times the allowed amount. A spokesman for the Dutch Environment Ministry said Tuesday that large concentrations of cadmium are banned in the Netherlands--in line with European Union policy--to prevent it from entering the food chain. "Cadmium damages the kidneys," ministry spokesman Joost Kehrer said. Sony did not say how much the cable replacement will cost the company.

S&C Products Affected by WEEE & RoHS

Reporting Requirements

As with the Automotive OEMs, the electronic OEMs, because the obligation to demonstrate conformance rests with the OEMs, they have developed a variety of mechanisms for obtaining conformance data of their supply chains.A supplier is obligated to utilize whatever mechanism provided by OEM:

Simple and Complex Certification StatementsEIA/EICTA/JGPSSI ToolWeb-based tools (such as IMDS in auto industry)

Reporting Requirements

7AM 024A5Bill of Materials defines the parts that need to be included in Material Content BreakdownFor each part:

Weights to 0.05 gramsSurface Areas to 0.1 cm2Identification of the material of construction

Suppliers/Venders of materials of construction provide elemental breakdown of their materials.

Use of “jokers” allowable if confirmation that none of the prohibited/regulated materials are contained in undesignated portion.

Material Content Breakdown

7AM applicable directive: RoHS7AM contains no Mercury or LeadPolyester resin contains no restricted fire retardants.Monovalent and Trivalent Chromium are not restricted by RoHS and are allowable at any concentration.

NOTE: Both Monovalent and Trivalent Chromium are on the Material Declaration Datasheet as reportable substances.

Material Content Breakdown

7AM applicable directive: RoHSHexavalent Chromium:

RoHS limit for “unintentional incorporated”hexavalent chromium is 1.0 wt%. Hexavalent chromium is intentionally incorporated.RoHS limit for “intentional incorporated” hexavalent chromium is 0.1 wt%. The wt% in 7AM is 0.003% --which means that the chromating surface conforms to the RoHS limit.

In most cases, hexavalent chromium coatings specified by TI will not exceed this limit. Hard or decorative chromium plates will likely exceed.

Material Content Breakdown

7AM applicable directive: RoHSCadmium:

RoHS limit for “unintentional incorporation” is 0.1 wt%. The cadmium contained in this device is intentionally incorporated.RoHS limit for “intentional incorporation” (proposed) is 0.01 wt% of homogeneous material. The cadmium contained in contact material is much greater.

In 1976, EU passed an exemption allowing cadmium in contacts in electromechanical safety devices (Regulation 76/69/EEC) The material content prohibition of RoHS superceded this exemption –although S&C submitted a request in Sept. 2002 to have this exemption added in the list of exemptions in RoHS.

The original design of is 7AM device did not conform to RoHS because of cadmium content of contacts. Communicated to customer via following RoHS Declaration (or using tool required of customer)Product Redesigned to meet RoHS Requirement

Individual MaterialContent Declarations

Supplier Management

Supplier Management ProgramCustomers specifically acknowledge all of the compliance information provided in this survey is accurate and complies with Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE), Directive 2003/108/EC amending Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE) and Directive 2002/95/EC on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS).Should any components/parts you supply become non-compliant with the WEEE/RoHS Directives you will immediately notify, via email, the Texas Instrument WEEE/RoHS Compliance Officer at attle-esh@list.ti.com.

Supplier Management Program

Supplier Management Program

1,921 IMDS Entries Since Inception3.8 – 7.6 Man Years of EffortSmall Percentage of Possible Product Variation

• 2CP15-16– 37 Components– 6 Entries

• 7AM– 6 Components– 6 Entries

Responded to 165 ELV, RoHS & WEEE Requests YTD 2006

66 Product Certification lettersComplete 99 IMDS Entries YTD

1142 S&C Suppliers636 Controll’s Suppliers506 Sensor’s Suppliers

Supplier Management Program

Final Words The Automotive Manufacturers response to the End-of-Life Vehicle directive provides one model for responding to the WEEE and RoHS directives.

Other industry sectors are investigating models for obtaining data similar product content data (electronics, white goods, aerospace).

Impacted industries are likely to extend the requirements of the EC directives to all of their products.

Regardless of the ultimate response model, the collection and management of Material Content Data within every company is a key task.

Final Words Collecting Material Content Data is a cross-functional task and takes time for a company to learn:

Even if your company isn’t yet impacted by material content reporting requirements, it is worthwhile to begin collecting content data about your products (starting with Cr+6, Hg, Pb, Cd).

Level of effort necessary to collect data can be significant.

Be in front of the curve when material content reporting requirements for your industry arrive.

Changing product material content takes time/effort. Begin looking for technology platforms that avoid use of materials prohibited by the directives.

Valuable Links

European Environmental Agencyhttp://www.eea.eu.int/

The EU on-linehttp://europa.eu.int/index_en.htm

EU Directives – Legislative Summarieshttp://europa.eu.int/scadplus/leg/en/s15000.htm