Z-404: The Kohler Engines
Material Restriction Standard
Mike Major
michael.major@kohler.com
Introduction
Z-404 specifies that components must be free of
regulated substances in excess of REACH and RoHS
concentration limits as well as free of ozone depleting
chemicals.
Z-404 communicates the requirement to the supplier on
the drawing and for quoting purposes.
However, Kohler Engines will verify Supplier’s
acknowledgement and compliance with a recently
purchased software package, Actio.
Actio allows supplier to declare compliance status and
answer several simple questions by following the
internet link provided in an Actio generated email.
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Regulation Applicability
REACH and RoHS concentration limits
apply to homogenous materials (any
single substance that could theoretically
be separated mechanically). For example:
a wiring harness may comprise a plastic
connector, solder, plastic sheath, wire,
wire coating etc. Even the wire coating
must comply with the concentration limits.
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Regulation Applicability
REACH already applies to all identified
consumer goods imported to Europe.
RoHS currently allows an exemption for
engine powered equipment, but Kohler
Engines is driving compliance to meet
customer specific requirements and to
anticipate future regulatory development.
RoHS will formally apply to engine powered
equipment beginning July 2019.
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REACH - Registration, Evaluation,
Authorization and Restriction of Chemicals
REACH restricts substances which are carcinogenic,
mutagenic, toxic for reproduction or bioaccumulative.
REACH is organized in articles, annexes, appendices
and the SVHC list.
Z-404 specifies compliance with Annex XVII
concentration limits and absence of SVHC candidates.
Overview:
http://echa.europa.eu/web/guest/regulations/reach/und
erstanding-reach
Legislation: http://eur-lex.europa.eu/legalcontent/EN/TXT/PDF/?uri=CELEX:02006R190720130701&qid=1395826642786
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REACH ANNEX XVII
Annex XVII identifies currently regulated substances and
restriction conditions/applications. Conditions of
Restriction may include concentration limits
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SVHC Candidate List
Substances of Very High Concern List or SVHC
list announces proposed substances for
future, formal inclusion in Annex XVII. In
many cases, SVHCs candidates are
subsequently regulated.
– Industry and consumers may comment and
approve or oppose (if no commercially viable
alternative exists) the nomination. If approved,
SVHC candidates are added to Annex XVII.
– http://echa.europa.eu/web/guest/candidate-listtable
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REACH Effect
REACH imposes registration and reduction
requirements for substance and article
importers to the EU.
OEMs are potentially subject to registration
and Kohler Engines should not contribute
to their totals. Therefore, Z-404 specifies
that the REACH concentration limits apply.
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RoHS – Restriction of
Hazardous Substances
RoHS limits concentrations of 6 substances:
1. Lead (0.1 %)
2. Mercury (0.1 %)
3. Cadmium (0.01 %)
4. Hexavalent chromium (0.1 %)
5. Polybrominated biphenyls (PBB) (0.1 %)
6. Polybrominated diphenyl ethers (PBDE) (0.1 %)
Legislation: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:
2011:174:0088:0110:EN:PDF
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RoHS Exemptions/Exclusions
Some components and products may
contain regulated substances in excess of
the standard concentration limits.
Notable: Lead as an alloying element in
aluminum containing up to 0,4 % lead by
weight; lead solders. Please see Annex III.
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RoHS through Z-404
Z-404 specifies RoHS compliance although
Spark ignition engines and equipment are
currently exempt.
However, the RoHS “Recast,” commonly
referred to as RoHS II, applies to spark
ignition engines and equipment made
available on the European market effective
July 2019.
This includes pre-July 2019 manufactured
engines imported for sale to Europe after July
2019.
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RoHS II
RoHS II offers a professional use exemption, but there is no professional
use definition.
RoHS II directly applies to all Kohler engines other than Command and
Trident.
OEMs demand compliance based on internal policies and Kohler Engines is
working towards complete product line compliance.
The EU commission may expand RoHS II to encompass several priority
substances including:
• Hexabromocyclododecane (HBCDD),
• Bis (2Aethylhexyl) phthalate (DEHP),
• Butyl benzyl phthalate (BBP),
• Dibutylphthalate (DBP).
Z-404 does not require Supplier to investigate or declare their presence, but
Supplier should be aware and actively minimize their inclusion.
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Kohler Engines Declarations
Kohler Engines will track, analyze and rely
on Supplier’s Actio declaration to make
downstream declarations to customers
and government agencies.
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Actio Process - Login
• Supplier will receive an email with a link to the Actio login site.
• In the first login instance, select Forgot pwd. Actio will then prompt
Supplier to create a password.
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Actio Process - Verification
Once logged in, Supplier will confirm/verify company information
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Actio Process – Supplier Portal
Supplier presented with list of components requiring declaration.
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Actio Supplier Questionnaire
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Full Material Disclosure Option
The Actio questionnaire allows (but does not
require) Supplier to provide Full Material
Declaration ("FMD“)
In an FMD, supplier would identify all
substances and materials included in the
component.
Future inquiries may therefore be avoided if
unidentified substances comprise less than
the regulated thresholds.
FMD is NOT required to comply with Z404 but
may simplify future reporting.
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Actio Declaration Processing
Kohler will receive Supplier’s Actio
declaration and automatically assign
compliance status.
Supplier can view existing declarations
through his portal.
Supplier should maintain current contact
information and may assign additional
users through Actio.
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