Green Legislation: Implications For The Electronics Supply ... · Quarterly Forum for Electronics...
Transcript of Green Legislation: Implications For The Electronics Supply ... · Quarterly Forum for Electronics...
Green Legislation: Implications For The Electronics Supply Chain Understanding Your Exposure, Planning For Mitigation, Preparing For Competitive Advantage
Glenn Bassett VP, Strategic Business DevelopmentAvnet Electronics Marketing Americas
Agenda
Green Legislation Multiple regionsFirst Understand WEEE/RoHSRoHS Implications
What The Industry Is DoingSurvey
Customer Issues & OpportunitiesPlanning
Avnet CapabilitiesCall To Action
Why LeadWhy Lead--Free? Why Green?Free? Why Green?
When lead or other hazardous materials within electrical and When lead or other hazardous materials within electrical and electronic equipment is discarded into landfills it can leach electronic equipment is discarded into landfills it can leach into the soil and contaminate drinking water supplies. And into the soil and contaminate drinking water supplies. And
supplier of drinking water are limited…supplier of drinking water are limited…
Creates Sever Health Issues:Creates Sever Health Issues:
Brain & NeurologicalBrain & Neurological
Immune SystemImmune System
Multiple Essential Body SystemsMultiple Essential Body Systems
Effects everyone but Children are at Effects everyone but Children are at
Greatest RiskGreatest Risk
Green Legislation – Get ReadyDriving Issues
Drinkable Water Supply Needs Are Increasing Beyond AvailabilityWater Supplies Being PollutedMany Countries Now Regulating Pollutants
Implications Polluting Substances Are Being RegulatedStand By For Added Effort & ExpenseThis Train Is Leaving The Station
Don’t Hope For A Push Out
Environmental RegulationsA paradigm shift for design and manufacturing
RegulationsRestrict use of hazardous
materials In productsRequire material disclosure
(electronic products)Vary by region
CA SB 20/50
NAS 411ISO-14001
ELVELV
IEC Guide 113JapanJapan
RoHSRoHS
weeeweee
Engineering & Purchasing mustDesign for environmentDesign for new manufacturing
processesProcure & Certify
2004 2005 2006 2007July 1, 2006 E-Day
“Dutch customs and the state's health inspection service had discovered the consoles and 800,000 accessories -- estimated to be worth around $162 million -- during an inspection of a distribution center in the Netherlands.” CNN
WEEE & RoHS: The Main Event Everything Begins With WEEE/RoHSWEEE
Law in place to govern financing and obligations around return of assemblies to depots for safe disassembly
Clear Issue for “Producers” In Selling In EU
RoHSLaw in place to limit hazardous substances in manufacturing which would be later be dealt with at a WEEE disassembly depot.
The Major Supply Chain Issue
The RoHS DirectiveRestriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (2002/95/EC)
Limits the following substances in Electrical and Electronic Equipment (EEE) to 1000 PPM In “Homogeneous Material”
Lead Cadmium (100 PPM)Mercury Hexavalent ChromiumPolybrominated Biphenyl - PBB Polybrominated Diphenyl Ether – PBDE
Substances must be limited in all “product put on market” after 7/1/2006
More Substances Coming Joint Industry Guide A & B
EEE: Electrical & Electronic EquipmentScope
Large Household AppliancesSmall Household AppliancesIT & Telecommunications EquipmentConsumer EquipmentLighting EquipmentElectrical and Electronic Tools
With exception of large scale stationary industrial tools
Toys, Leisure & Sports EquipmentMedical Equipment
WEEE now, RoHS review 2/13/2005 With exception of implanted or infected products
Monitoring and Control Equipment WEEE Now, RoHS review 2/13/2005
Automatic Dispensers
ExemptionsDefense And Security Equipment
Not Dual Use – Military or Security Specific OnlyAirbus 400 vs. Airbus 380
High Voltage Equipment 1000V (DC) and 1500V (AC)
As noted on previous pageMedical & Control Equipment – Feb 2005 Review
Many Exemptions Under ConsiderationMany Limitations Are UnclearBest To Think Worst Case And Be Pleasantly Surprised
Exemptions Continuedmercury in straight fluorescent lamps for special purposes lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunications (with a view to setting a specific time limit for this exemption) light bulbs compliant pin & press fit connector systems lead as a coating material for thermal conduction module C-ring lead and cadmium in optical and filter glass optical transceivers for industrial applications lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 85 per cent in the proportion to the proportion to the tin-lead content (exemption until 2010) lead in high melting temperature type solders (i.e. tin-lead solder alloys containing more than 85 per cent lead) and any lower melting temperature solder required to be used with high melting temperature solder to complete a viable electrical connection lead in solders to complete a viable electrical connection internal to certain IC packages (flip chips) (exemptions until 2010) safety equipment for fire and rescue services
Regulations Aren’t PreciseRoHS—Directive 2002/95/EC
More than a year after passage of RoHS, the details are still being worked outSubstance threshold values are not clearReporting level (product, component, material) is not clearCompanies and industry groups have been interpreting on their ownThe Technical Adaptation Committee is proposing clarifications; but these aren’t clear either (for example: “homogeneous” material)
Due to the evolutionally nature of hazardous substance Due to the evolutionally nature of hazardous substance regulations and manufacturers ability to report them, regulations and manufacturers ability to report them, continually updated quantitative data is a mustcontinually updated quantitative data is a must
Demonstration Of Compliance
OptionsGathering Of Ad Hoc Data From Various SourcesReliance On Legally Binding Data From SuppliersGrind It Up
Carry Out Spot ChecksAnalyze Everything
Due DiligenceHomogeneous Material – How Low Do You Go
ProblemsSupplier Data AccuracyGrind Up Expense
Compliance Rollup for RoHS
Assemblies
Components
Finished Product
Requires DataRequires DataAggregation at allAggregation at all
Levels of theLevels of theFinished ProductFinished Product
Not A Spreadsheet Problem Not A Spreadsheet Problem –– Get Ready For IT Investment Get Ready For IT Investment
Lead / Lead Free DilemmaLead / Lead Free Dilemma
High Reliability Parts will Not Change to Tin (Sn). However, Commercial Parts are widely used for Cost Purposes
Tin Whiskers
Lead Part Procurement
Mixed Inventory
Tin WhiskersTin Whiskers
Manufacturing Processes Change
230°C 260°C
Manufacturing IncompatibilitiesCannot necessarily mix lead-based
and lead-free parts on same boardLead-free alternative solders require
higher temperaturesMany lead-based parts cannot
withstand higher temps
Manufacturing change from lead-based to lead-free
Regulations affect lead-finish on terminals and board soldering
Manufacturing lines and processes must change to accommodate
Expensive and time-consuming transition period between 2004-2006
Supply DiscontinuityChangeover occurs asynchronously
across all suppliers, all partsDemand and supply curves fluctuate
Shortage of lead-free and excess of lead-based (and visa versa)
Varies over time, by part
Manufacturing ImplicationsDifferent Solders
Numerous compounds being reviewedIPC, SMT Web Sites – White Papers
Process change overchange over expense may be high
ReliabilityLead Solder Joint Reliability Well Understood
50 years of experienceLead-Free Not Well Understood
Summary of RoHS RequirementsCurrent State
Restrict usage of 6 substancesApplies to certain categories of
productsLead, mercury, cadmium,
chromium VI, PBB, PBDECurrent guidance
Threshold on cadmium is 100 ppm, rest are 1000 ppmMeasurement is at
homogeneous material level, which is defined at lowest material level (cannot be mechanically disjointed)Measurement not at device or
assembly levelMaterials cannot be
intentionally added
Other impacts
Many OEMs are restricting usage of additional substances beyond the 6 mandated by RoHS
OEMs may be subject to other requirements from their customers, or other regulatory requirements from other regions
ManufacturabilityLead Free/Mixed Issues
Certain exemptions applyExemptions may only be
temporary, and do not necessarily apply to WEEE
WEEE reporting
So What Is Happening Now?Confusing Guidance, Leading To…
Country By Country Interpretation
Manufacturer By Manufacturer Interpretation
OEM By OEM Interpretation
CM By CM Interpretation
Department By Department InterpretationOpinions Abound
So We Commissioned A Survey…
Meaningful Standards for Part Numbering in Light of Substance-Restriction Requirements
A 2004 Study sponsored jointly by Avnet and TFI
(Abbreviated summary for webcast)
Pamela J. Gordon, CMC
President, Technology Forecasters Inc.Information, Insight, Interaction for Effective Manufacturing
Relationships
Study Methodology
Research conducted in July and August 2004. Objective:Understand component suppliers’ part numbering plans for products free of restricted substances (RoHS, other requirements)See what OEMs and contract manufacturers want and needRecommend to the industry viable and cost-effective practices
Funded jointly by Avnet and TFI’s Quarterly Forum for Electronics Manufacturing Outsourcing and Supply Chain, Sept. 30, 2004TFI interviewed in person and by telephone:
53 component suppliers13 contract manufacturersAbout 120 more contract manufacturer and OEM respondents from Electronic Supply & Manufacturing web survey, co-sponsored by Avnet
Analysis and report by TFI, for independent and objective view
Component Suppliers Interviewed by TFI
AavidAMDAmphenol-TuchelAmphenolAerospaceAnalogAromatArtesynAtmelAustin SemiconductorAVXC&KCherryComairCondor
ConfidentialCypressElcoteqFCIFreescaleFujitsuInfineonIntersilITT (Switches)KemetLamdaLatticeLeachMaxim
MicrosemiMurataNational SeminconductorNSC (division)NECNICNichiconOmronOn SemiOsramPanasonicPanduitPower OnePulse
QuickLogicSamtecSandiskSharpSTMSunonTIToshiba AmericaTyco Electronics IncTyco Electronics PowerYageo
How Component Suppliers Plan to Designate Compliance
21
2
21
27
31
37
52
0 20 40 60 80 100
Percentage of Suppliers (%)
New pb-free part #'s
Info on packaging
Date of manufacture
Mark on component
New RoHS part #'s
RFID technology
Other
Suppliers that will not change part numbers: 42%
Demand Component Suppliers Receive for Lead-Free Components
"Less than 5 percent"
26%
"5 to 15 percent"
33%
"15 to 25 percent"
13%
"More than 25
percent"28%
n=53
When Suppliers Expect More than 50% of Customer Orders to be Lead-Free
By 20076%After 2007
4%
Don't know or N/A
6%
Within 200612%
Within 200556%
Within 200416%
n=53
How will Component Suppliers Communicate Compliancy?
31
10
12
35
39
46
79
0 20 40 60 80 100Percentage of Suppliers (%)
Data accessible online
By request only
Paper catalogues
Report other substances
RosetteNet PIPs
Access code required
Other
n=53
Effect on Lead Times
Don't know or N/A23% Will not affect
delivery75%
Will extend delivery
2%
n=53
Effect on Price
Don't know or N/A12%
No change in price53%
Potential
increase35%
price
n=53
CM’s that expect to be fully Compliant by July 2006
Will not be compliant
31%Will be compliant
69%
n=13
How CMs Want Component Suppliers to Designate Compliancy
15
23
31
46
54
54
85
0 20 40 60 80 100Percentage of CMs (%)
New pb-free part #'s
Mark on component
New RoHS part #'s
Info on packaging
RFID technology
Date of manufacture
Other
n=13
Will Designation of Compliancy Affect Buying Decisions?
Will not affect buying
decision25%
Type of designation will affect
buying75%
n=12
Study Conclusions
•Confusion abounds within the supply chain
•Lack of Standardization
•Part Numbers Not Changing = Nightmare
•Lead-Free product demand will pick up dramatically in 2005
•RoHS material reporting will be a challenge
•Many firms are underestimating the task
•Many firms will be caught by surprise
Now We Know The Problems…So What Does All This Mean?
New Pervasive Legislation With Major Supply and Manufacturing Impacts On Financial Performance
Who Should Be Concerned?Anyone With Electronic Component Related Revenue Dependant On EU Sales
With follow-on concerns in Asia and AmericasAnyone Concerned About Lead Based Component Supply Discontinuity
Head in sand = future cost & producibility problems
Hazmat: Financial ImpactsCost & Risk MitigationCost & Risk Mitigation
Ensure continuity of EU/Asian Sales (regulations start 7/1/06)
Applies to sales of affected products
Other regions likely will follow suit (California, China, etc.) with their own regulations
Comply with customer requirements
Often more strict than RoHSBid and comply with Defense
contracts that require NAS 411Hazardous materials mgmt
programCompetitive marketing
advantageBeat competitors to market
with environmentally-friendly products that comply with regulations (first to market advantage)
Avoid fines and excess inventory for non-compliant products
Better manage supply base to make intelligent sourcing decisions
Continually track supplier status & roadmap
Cost and time-to-market advantage of 3rd party solutions make sense
Internal “make” costs very highLarge front end spike in resources
on non recurring level of effortNo time to waste – must act now
Proactive visibility to component obsolescence issues
CEO & CFOCEO & CFO -- Sarbanes Oxley Disclosure: SEC 10Q / 10KSarbanes Oxley Disclosure: SEC 10Q / 10KLack Of Preparedness Could Lack Of Preparedness Could Materially Impact Stock PriceMaterially Impact Stock Price
RevenueRevenue
AMR Research Report
Planning For RoHSRoHS – Planning
19 months to GO LIVE!Exemptions not solid
Supply Chain/ProcurementBOM Evaluation: Lead or lead free mfg
process and part crossing as appropriateLeaded part sourcing evaluationPlan for added E&O ExpenseSourcing of certification data
Engineering & Design New designs must be compliant Old designs need to be re-qualifiedPlan for Productivity Decline - Double WorkTools to leverage compliance data
Information TechnologyTools For Tracking & Proving ComplianceIntegration of data into systems
Sales & Marketing Kill off certain products/product linesLeverage compliance against competitorsReturns Planning
ManufacturingOutsourcing - Evaluate EMS ProvidersSet up parallel Lead Free and Lead LinesMillions in expense – Time to Outsource?
Warehouse/LogisticsIncoming Inspection – No Part # ChangeDual Inventory Planning – IT SupportRight part, right place, right line – How?Physical Inventory, Returns Management
ReliabilitySystem Retest, UL, FDA, FAA, approvals Tin Whiskering and other failure modes
ExportSystems to Manage CertificationsAmerican and Asian companies may be
purposefully challengedFinance
Expense budget of 2% of sales per year for 2005/2006
CEO/CFO Sarbanes-Oxley10-K/Q protection of revenue stream
June2004
Dec2004
June2005
Dec2005
Plans, budget, organization in place. Manufacturing approach and limitations determined. Manufacturing requirementsdefined and communicated to design, sourcing, EMS. Supplier requirements defined. Green procurement policy andplans in place. Sourcing requirements communicated to suppliers. Supplier questionnaires initiated.
July 2004
Ongoing internal and supplier communications and collaboration. Executive awareness and support is also critical.
80% suppliers
compliant.
Products analyzed. Issues and alternate supply sources identified & qualified. BOMs & AMLs updated
as required to bring products into compliance.
Additional IT system upgrades and content sourcing, as required.
90% suppliers
compliant.
Updated supply chain strategy/plans in place: planning, inventory, logistics, spares, etc.
100% suppliers
compliant.
Updated design & sourcing processes
implemented and in use.
Legal policies defined. Risk mitigation plans in
place.
Sales & marketing “green”programs defined,
communicated.
Production quantities available.
Final product issues addressed.
Update product repair procedures and
capability.
Green product shipments commence.
Purge non-green component stock and
product inventory.
Rollout of “green” sales and marketing
messaging, packaging.
Evaluate & select 3rd
parties
IT systems upgraded (includes 3rd party IT).
Hazmat content sourced.
Supplier roadmaps available & tracked.
Updated design & sourcing processes
defined.
Supplier/component risk mitigation plans defined.
Internal communic-
ation.
RoHS Compliance TimelineUrgency to Act Now is Real
Allproducts
green(7/1/06).
Sept2004
March2005
Sept2005
March2006
June2006
Material Disclosure for RoHS
Assemblies
Components
Finished Product
Requires DataRequires DataAggregation at allAggregation at all
Levels of theLevels of theFinished ProductFinished Product
Not A Spreadsheet Problem Not A Spreadsheet Problem –– Get Ready For IT Investment Get Ready For IT Investment
Avnet’s Solution Set
Avnet Capabilities…
RoHS Yes/No & Substance PPM levels for Franchised Components purchased in the last 6 months.
Access to world class Component data from I2 thru PrómierePrómiere Basic
– Basic Lead Free Manufacturing and RoHS Y/NPrómiere Advanced
– Six substance PPM and weight, Recommend RoHS alternatePrómiere Custom
– JIG A&B, Certifications, Expedited part creation, custom catalog
Overview of Promiere
Provide Supply Chain Visibility Insight and Solutions.Over 100 active customers using our various services
Size ranging from Fortune 100 to $20M in revenueServices from software to content to excess inventory
Partnered with i2, Agile, America II and AvnetAble to offer both Avnet franchised and non-franchised content to help you get the most data for your parts.
Promiere Green Basic –Attributes Included in Subscription
Parametric Search/Research EngineSide-by-Side Component Comparison
End-of-Life / Life Cycle ForecastingLead-Free & RoHS Basic Information
Lead free yes/noContact material (connectors)RoHS yes/noRoHS Compliant by virtue of thresholds or by virtue of exemptionTerminal / contact finishPeak reflow temperatureMSL @ peak reflow temperatureProduct Change Notices
Promiere Green Advanced
Attributes included with Promiere Subscription:Cadmium / Cadmium (Cd) compoundsChromium VI / Chromium VI (Cr VI) CompoundsLead / lead (Pb) compoundsPolybrominated Biphenyls (PBBs)Polybromninated Diphenylethers (PBDEs)Recommended RoHS-compliant replacement part (part number or date code)Method of distinguishing replacement part vs. originalJESD-97 codesPredicted End of Life
Promiere Green CustomAttributes included with Promiere Subscription:
11 Advanced Manufacturing Variables24 + Joint Industry Guide List A and List B VariablesMaterial Declaration sheetsExpedited Part Data CreationNon-electronic component data creation
Promiere Green CustomAttributes included with Promiere Subscription:
11 Advanced Manufacturing Variables24 + Joint Industry Guide List A and List B VariablesMaterial Declaration sheetsExpedited Part Data CreationNon-electronic component data creation
Make vs. BuyOutsourcing the responsibility offers numerous benefits (time, cost, people, risk)
Consider the following Content implications:Scope and timeline of content collection –
do a staffing analysisRealistic assessment of number of
resources requiredEven a medium-sized job can call for 25 full-time resources
This is an ongoing task, not a one-time effort?
Consider expertiseDoes your company have the tools,
process, experience and trained resources to do a better job than a content provider?
Consider quality levelsExtremely high quality is critical – does
your company have an ISO 9001 content process?
Cost and opportunity assessmentDo you have better economies of
scale than an off-shore dedicated content provider can offer?
Is content collection a core competency where you want to focus your limited resources?
Time-to-complianceDo you have the time and staff to
adequately build/expand your own IT applications, or would you benefit from a comprehensive, off-the-shelf maintained solution?
How many free IT resources do you have?
Recap of Promiere Service
Easy to navigate and use the systemHosted solution available Extensive data for parts to help find any problem parts and/or selecting the correct partsQuickly identify the parts at riskAllows you to easily determine which business options you have available with a discontinued or soon to be discontinued component:
Last Time BuyAlternate SourceRedesign of Board
RoHS Information – customized Green Product to meet the level of complexity as defined by you.
Call To Action1. Secure an Executive Sponsor
Management Focus / Attention, Budget and overall Alignment2. Determine an effective transition plan
EngineeringSupply ChainManufacturingCompliance/ExportDisclosure
3. Develop a Strategy that supports World Wide challengesRegulations will continue to change and evolve by region
4. Cross Function teams 5. Increase best practice participation with Industry
Consortiums like IPC, JEDEC, NEMI6. Procure tools to manage, access, and communicate data
Thank You
www.em.avnet.com/leadfree
Reporting RequirementsDue to the nature of reporting, many documents will need to be provided in a PDF format that cannot be altered versus in excel or other standardized file formats.OEMs will be responsible for preparing a Material Declaration regarding the compliance of their product(s).
Green Compliance Management IssuesLegislative and industry mandate
RoHS (including lead-free) and WEEE compliance not an option for most companies (discrete products containing electronics)
Why comply?Protect revenuesAvoid potential fines/penaltiesElectronics supply chain
mainstreamQuestion is how to best respond
1) Solve problem from within2) Leverage partners and 3rd
party solutions and consulting3) Hybrid (mix of above 2
options)
IT solution value prop driversAbility to achieve timely
complianceLook for opportunities to improve
product design/cost at same timeOptimize cost, risk and time of
available optionsIncludes resource availability
Compatibility with enterprise infrastructure (systems, data)
“Yes/No” compliance optionReasons why Yes/No is not enough
RoHS Directive not finalizedGuidance document still in flux
Interpretation of requirements like “intentionally added” and “homogeneous material”
Other requirements emerge that may differ from RoHS
Regional differences in environmental directives (China, Japan, U.S., etc.)
Example: may impact exemptions
Customers may mandate more stringent requirements
RoHS itself will likely change over time
A “yes” today may be invalid tomorrow
Defending an allegation
Material declarationCustomers or regulators may
require quantitative dataExample: along the lines of the
proposed Joint Industry GuideProduct testing/compliance
A material concentration near the threshold limit could fail a lab test
Testing has up to 20% varianceWEEE implications
May need to know amount of controlled substances so recyclers know what to recover at disposal
WEEE text: … keep records on the mass of WEEE, their components, materials or substances …
A Quantitative Data Approach is RequiredA Quantitative Data Approach is Required
Spreadsheet optionReasons why spreadsheet/paper is not enough
Risk/cost of error much higherNo centralized enterprise data
mgmtNo formal document/change
controlWould a company manage their
BOMs using spreadsheet?Consequence of 1 error is
extremely high
No traceability and due diligenceIf challenged, would a company
want to defend themselves with paper and spreadsheet?
Approach falls apart when changes occur
No automated alert notificationNo ability to do automated impact
assessment triggered by a change (part, BOM, regulation)
How to re-analyze BOMs, flag issue parts, do what-if analysis
No business process integrationSpreadsheets and paper not an
integral part of design & sourcing processes and systems
No enterprise decision supportHow to do analytics ?How would an engineer know if
they are selecting a part that is compliant and manufacturable?
An Enterprise Approach is RequiredAn Enterprise Approach is Required