Roadmap and Control for the Implementation of the
European RoHS Directive
Revision, December 2008
NeoPhotonics Corporation
Copyright Reserved
1. EU RoHS(2002/95/EC) Requirements and Applications:
Directive 2002/95/EC of the European parliament and of the council of 27 January 2003,on the
restriction of the use of certain hazardous substances in electrical and electronic equipment;
Starting From 1 July 2006, new electrical and electronic equipment put on the market must not contain
lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated
diphenyl ethers (PBDE) above specified levels.
2005/618/EC,The maximum concentration values (MCV) for certain hazardous substances in
electrical and electronic equipment:
a maximum concentration value of 0.1 % by weight in homogeneous materials for lead, mercury,
hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) and
of 0.01 % by weight in homogeneous materials for cadmium is allowed.’
 Certain applicable specific RoHS exemptions may apply to NeoPhotonics products:
5. Lead in glass of electronic components.
6. Lead as an alloying element in steel containing up to 0.35 % lead by weight, aluminum containing up to
0.4 % lead by weight and as a copper alloy containing up to 4 % lead by weight.
7a. Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or
more lead),
7b. lead in solders for servers, storage and storage array systems, network infrastructure equipment for
switching, signaling, transmission as well as network management for telecommunications,
7c. lead in electronic ceramic parts (e.g. piezoelectronic devices).
…
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2. RoHS 5/6 and RoHS 6/6 definitions
RoHS 5/6 —— Indicates that 2nd Level Interconnect materials contained lead (Pb) in solders, other
homogenous materials are RoHS compliant.
Note: here, all general exemption clauses are applicable, including No.7b of exemption clauses coming
from RoHS(2002/95/EC) Directive: exempted Pb in solders of telecommunication network products.
RoHS 6/6 —— Indicates 2nd Level Interconnect materials are lead-free and all homogenous materials are
RoHS compliant.
Note: here, excluded No.7b of RoHS exemption clauses, other general exemption clauses are applicable.
Pb-free (lead-free): Indicate there is no lead (Pb) or the concentration of lead (Pb) is less than or equal
to 0.1% by weight in 2nd Level Interconnect material and that the product is otherwise RoHS compliant
2nd Level Interconnect material —— Indicates those materials are used to connect electronic
and electrical components to the printed circuit board, such as, the solder paste, lead-finish
(see the below figure)
Pb
RoHS 5/6
products
Contained Lead
in solder
Pb
Lead-free
solder
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RoHS 6/6
products
3. NeoPhotonics RoHS Implementation Roadmap:
Products
status
RoHS 5/6
product
(containing
lead in
solder)
RoHS 6/6
product
(lead free
solder)
Mar04
…
Jul05
Aug05
Control
documents
preparing
Sep05
Oct05
Nov05
Low
volume
supply
Dec05
Jan06
Feb06
…
Jan07
High volume supply
Start to
implement
RoHS/leadfree project
R&D…
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Control documents
preparing
Low volume
supply
High volume supply
…
Jan08
Feb08
…
4. RoHS Compliant Control for Product:

A) Raw Material RoHS Control:

Vendors are required to submit RoHS/Environmental compliance declarations for raw materials.

Vendors must supply a third-party hazardous/banned substances concentration report for raw
materials.

NeoPhotonics will use XRF to inspect incoming materials or submit incoming materials to thirdparty organization to have chemical analysis for RoHS banned substances concentration if the
XRF method can't be used on certain materials or substances.

B) Audit suppliers RoHS system:

NeoPhotonics will define RoHS assessment requirements for materials vendors and audit and
assess suppliers periodically.

C) RoHS Control in the process:

NeoPhotonics will implement environment-friendly processes with no use of banned substances
products in the course of manufacturing.

NeoPhotonics will promote the use of RoHS compliant and environmentally-friendly materials,
including the use of RoHS compliant adhesives, soldering materials and environmentally-friendly
liquids.
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5. RoHS Control System and Organization:
•NeoPhotonics incorporates RoHS control requirements into the system of TL9000, ISO9001 and ISO14001;
•NeoPhotonics has established a RoHS Environmental Committee Organization to oversee compliance
and operational improvements
RoHS
Environmental
Committee
Purchase
Control
ISO14001
ISO9001
TL9000
Process
control
WW Director of Environmental
Compliance
Technology Management Dept.
Raw materials, Components,
Device, semi-manufactured goods
and finished products control
R&D Dept.
Products Engineering Dept.
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Environment
Manager
Management Engineering Dept.
Team
consists of
related dept.
members
Quality Dept.
Supplier Control Management Dept.