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Global RoHS Compliance
for Home Appliance Manufacturers
ASTM International Technical Committee A05 –
Metallic-Coated Iron and Steel Products
May 23, 2007
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Outline
Whirlpool Corporation Overview
RoHS Overview
Current and Pending RoHS Programs
Policy Implications
Compliance with RoHS
Conclusion
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Whirlpool Corporation Overview
Largest global manufacturer and marketer of major home appliances
Annual sales of more than $18 billion
73,000 employees
Over 70 manufacturing and technology research centers around the
globe
Market Whirlpool, KitchenAid, Maytag, Jenn-Air, Amana, Brastemp,
Bauknecht, Consul and other major brands to consumers in more
than 170 countries.
Additional information at www.whirlpoolcorp.com.
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Whirlpool Global Operating Platform
#1 N.America
 $12 B Sales
 24 Plants
$18 B Revenues
73,000 employees
#4 Europe
 $3.4 B Sales
 13 Plants
#1 Global Share
#1 Global Brand
#1 L.America
Asia
 $2.4 B Sales
 5 Plants
 $457 M Sales
 6 Plants
Leading an $80 Billion Global Industry
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Strategy Supports Best Cost, Best Quality Products
Engineering & Design
As
se
mb
ly
Components
Ma
nu
fa c
t ur
i ng
Components
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What is RoHS?
RoHS regulations generally restrict the following substances in
electronic and electrical equipment:






Lead
Mercury
Cadmium
Hexavalent Chromium (Cr6+)
Polybrominated biphenyls (PBBs)
Polybrominated diphenyl ether (PDE)
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Current and Pending RoHS Programs
European Union – Directive 2002/95/EC
China
Japan
Korea
United States – State of California (limited to video display devices)
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EU RoHS
Implemented July 1, 2006
Compliance is the responsibility of the company that puts the product
on the market.
In some cases, regulations are inconsistent because each member
state adopted separate implementing standards and enforcement
procedures.
Contains broad definition of “electronic and electrical equipment” and
contains specific exemptions for certain products.
Maximum concentration is 1000 ppm, except Cadmium, which is 100
ppm.
Everything identified as homogenous must meet the requirements.
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China RoHS
Phase 1 (March 1, 2007):
 Marking requirements for electronic information products
 Environment-friendly use period must be indicated inside the pollution
control symbol.
Phase 2 (timetable uncertain, likely 2008):
 Restrictions on Hazardous Substances
 Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs, PBDEs
 Indications are that major appliances will be excluded, with exception of
microwaves.
 Replacement parts for appliances will be subject to RoHS if listed on the
catalogue.
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Japan RoHS
Design for Environment (DfE) criteria (promulgated in 2000)
 Rationalize use of raw materials
 Use recycable and reusable parts
 Promote long-term use of products
The cabinet member with jurisdiction establishes basic policy and
requirements for industry
Changes effective July 1, 2006:
 Manufacturers of computers, televisions, refrigerators, washers, dryers,
microwaves and air conditioners must label products to indicate presence
of Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs and PBDEs.
 Importers of computers, copiers, televisions, refrigerators, washers,
dryers, microwaves and air conditioners must meet Design for
Environment Criteria (DfE).
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Korea RoHS
Requirements include:
 Restrictions of hazardous substances in electrical/electronic equipment
and vehicles
 Improvement of materials and structure
 Recycling requirements for manufacturers and importers
 Mandatory recycling rate
 Establishment of an Operation and Management Information System
Implementation date: January 1, 2008
 However, implementation date does not mean anything until decisions are
ordered by Presidential Decree.
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California RoHS
Currently under consideration in the California Legislature
Consistent with EU RoHS regulations, with the following exceptions:
 Applies to products manufactured on or after January 1, 2010
 Applies only to mercury, lead, cadmium and hexavalent chromium (PBBs
and PBDEs are excluded)
 Excludes fixed installations
 Twenty-four month grace period for products that lose their RoHS
exemption
 Exempts products that are refurbished or sold for reuse
 Specific exemptions for spare parts
 A process for securing exemptions or time extensions
Annual reporting to California Integrated Waste Management Board
Passage is likely in 2007.
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Compliance Challenges
Obtaining and verifying data on thousands of parts from around the
world
Vague and varying regulations
No common reporting because of various states, languages, formats,
etc.
Constantly changing parts and components
Lack of best practices for mitigating risk
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Various End Manufacturers Strategy for RoHS
No single universal approach
Can have thousands of components with multiple homogenous
materials each
Too many components for one company to feasibly deal with by itself
Most rely on reporting from supplier base
 Letters of compliance
 Test data showing compliance
 In-house testing
 3rd party testing
 Often requested from Tier 1 suppliers, which trickles down the supply
chain
Mixed strategies commonly used
 Components and suppliers are ranked into categories based on degree of
risk
 Level of documentation and testing can increase with each category
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Typical Sampling Strategies for Compliance Testing
No single universal approach
Test every lot of material
 Unusual except when lots of material commonly come from unknown
production sources (commodity buyers, resellers, etc).
Test once for each part # produced.
 Retest when any changes in material, source, or process occurs (similar to
PPAP)
Test once for each part # used to produce multiple part #’s (e.g.,
cutting a larger coil of steel into various smaller width coils).
 May apply conformance to all downstream part #’s where no RoHS
materials are added
 Retest when any changes in material, source, or process occurs.
Typically, any change that occurs that would prompt sending
production samples for engineering approval should prompt a
decision as to whether a RoHS compliance retest is needed
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Test Methods
 No single universal approach
 Many various test methods, highly dependant on the material, processing
method, and type of component
 3rd Party Testing
 Currently no official accreditation process for 3rd party labs
 Some companies have list of labs they use or accept results from
 Internal Testing
 Many large companies use internal screening tests to reduce the amount of
expensive 3rd party tests (~$200-$400/sample)
 Portable XRF testers have become very popular
 30 seconds/test
 Provides elemental analysis only (cannot tell difference between Cr6+ and Cr)
 Not very useful for certain materials
 ASTM D6492 or ISO 3613 spot tests for detecting presence of chromate conversion
coatings
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Conclusion
RoHS regulations are being implemented globally, not just in the EU
Despite having extensive global supply chains, manufacturers have
developed and are continuing to enhance compliance procedures.
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Questions or Comments?
Contact information:
Brandon Bokhart
Senior Metallurgical Engineer
Whirlpool Corporation
269-923-4210
[email protected]
23 May 2007
Luke Harms
Government Relations Specialist
Whirlpool Corporation
202-639-9420
[email protected]
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