A Review of the Impact of European Union
Environmental Directives
Stuart Sleeman
Principal
Sleeman Hanley & DiNitto, Inc
Sensata Technologies

Comprised of three major
business units:

Sensors

Controls

More than 6,000 employees
around the globe

Technology Development and
Manufacturing in nine locations
in the Americas, Asia and
Europe
Product Content Management
Decisions & Strategy
Requirements
•
Customer
Requirements:
– Contracts and
specifications
•
Business-Wide
Strategy
•
Planning and
Roadmaps
•
TI Ban List Content
Decisions
– Surveys/
Declarations
– Influence
•
Current and Horizon
•
Legislation/ Industry
Standards
– Discover and
Understand
– Influence
•
Science and R&D
•
Strategy for
Customers
Strategy for Suppliers
Execution
•
Internal Manufacturing
•
External Manufacturing
•
•
R&D
Market Management
•
•
•
•
Specifications
Chemicals & Materials
Equipment
Change Control
•
•
•
Specifications
Subcons/Foundries
Change Control
•
Internal Communication of
Decisions
External Communication and
Customer Management
•
•
•
Supplier Management
Ban List Management
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)
Sony swaps PlayStation One cables
Last 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.
EU Material Content Directives
Vehicle End of Life Directive
Automotive Sensors
Air
Conditioning
Oil
Pressure

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
Coolant
Level
Low G
Accel.
Transmission
ABS
Power
Steering
Angular
Rate
Sensor
Occupant
Weight
Tire
Pressure
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 Directive

Requirements:
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
End-of-Life Vehicles
Treatment:
85 % re-use / recovery
Targets to be
80 % re-use / recycling
achieved
Type
Approval
95 % re-use / recovery
85 % re-use / recycling
95 % re-useable / recoverable
85 % re-useable / recyclable
free from lead, mercury, cadmium and chromium VI
(exemptions listed in Annex II)
provision of dismantling information
New Vehicles
Year 2000
delivery to treatment facility with no cost for last holder and/or owner
7/2002 7/2003
2005
2006
1/2007
2010
2015
Vehicle Population
delivery to treatment facility with no cost for last
holder and/or owner
End of Life Vehicles Directive
IMDS: One Certification
Procedure for the Industry
2000
2002
2006
Collect Material Account Data
Tier 3
Tier 2
IMDS provides a common method for identifying
materials, substances and attributes
Suppliers proactively send material composition
information
Gather Info
Supplier
Supplier
Material
Composition
Information
Gather Info
Supplier
Tier 1
OEM
Supplier
Material
Composition
Information
Supplier
Product
Supplier
Owner
Supplier
Gather Info
Supplier
Supplier
Supplier
Supplier
Material
Composition
Information
Product
Supplier
Owner
IMDS manages aggregated data
sent forward through the supply
chain.
Product
Owner
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 facilities
– Financially responsible for treatment, recovery and
disposal
– Households/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
manufacturing
• Lead, mercury, cadmium, hexavalent
chromium, PBBs and PBDEs banned
by July 2006
Categories of Electrical and
Electronic Equipment Covered by
WEEE Directive
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Large household appliances
Small household appliances
IT and telecommunications equipment
Consumer equipment
Lighting equipment
Electrical and electronic tools (with the exception of largescale stationary industrial tools)
Toys, leisure and sports equipment
Medical devices (with the exception of all implanted and
infected products)
Monitoring and control instruments
Automatic dispensers
WEEE Directive - requirements
1.
Register with each EU country
2.
Finance for your obliged allocation of WEEE:
–
Separate collection
–
Recycling
–
Treatment / Recovery
3.
Provide information to recycling/treatment facilities
4.
Report evidence of proper management
5.
Report evidence that targets have been met
6.
Ensure marking of equipment
MUST have been ready
by August 13, 2005
Sensata 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 Statements
EIA/EICTA/JGPSSI Tool
Web-based tools (such as IMDS in auto industry)
Collect Material Account Data
7AM
Product
Component
76118-2
76199-1
Description
base cap
cap seal
28924-1
disc seat
28780-1
28714-2
converter
washer
37660-1
28817-2
28925-1
28814-1
46705-3
76144-1
formed disc
Hexport
insulator
diaphragm
bonded
USCAR Base
o-ring
28931-1
76096-1
gasket
silicone seal
Product Material Breakdown
Base Material
Supplier
Cap Material
Supplier
Disc Material
Supplier
Converter/Washer
Supplier
Hexport
Supplier
Insulator
Supplier
Diaphragm
Supplier
O-ring, Gasket
Supplier
Silicone Seal
Supplier
Query Suppliers
Reporting Requirements

Product Information



Bill of Materials defines the parts that need to be
included in Material Content Breakdown
For each part:
 Weights to 0.05 grams
 Surface Areas to 0.1 cm2
 Identification 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 Full Material Content Breakdown
Hexavalent Chromium
Material Content Breakdown

7AM
Cadmium
Material Content Breakdown

7AM
Monovalent Chromium
Material Content Breakdown

7AM applicable directive: RoHS



7AM contains no Mercury or Lead
Polyester 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: RoHS
 Hexavalent 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
Sensata will not exceed this limit. Hard or decorative
chromium plates will likely exceed.


Material Content Breakdown

7AM applicable directive: RoHS
 Cadmium:


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
Supplier Management

Individual Material
Content Declarations
Supplier Management Program
• Customers 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 Sensata Technolgies
WEEE/RoHS Compliance Officer
Supplier Management Program
Supplier Management Program
Supplier Management Program
• 1,921 IMDS Entries Since Inception
– 3.8 – 7.6 Man Years of Effort
– Small 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 letters
– Complete 99 IMDS Entries YTD
• 1142 Sensata Suppliers
– 636 Control’s Suppliers
– 506 Sensor’s Suppliers
Final Words

The Automotive Manufacturers response to the Endof-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.
Regulatory Drivers
Global View
Piecemeal state laws
(California SB 20/50,
Maine, Ontario)
Current EU Directives:
WEEE, RoHS, ELV, EuP
Battery, Packaging
Pending EU Directives:
REACH, IPP, Battery
Revision
China has RoHS and is
preparing WEEE legislation
Japan Pb standards have
been in place and
electronics manufacturers
have already responded
Valuable Links
European Environmental Agency
http://www.eea.eu.int/
The EU on-line
http://europa.eu.int/index_en.htm
EU Directives – Legislative Summaries
http://europa.eu.int/scadplus/leg/en/s15000.htm