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Page 1: © 2015 IBM Corporation - pcd-supplier-support.compcd-supplier-support.com/index/Content/EventDocuments/IBM Global... · European Union Directive 2011/65/EU on the “Restriction

© 2015 IBM Corporation1

Page 2: © 2015 IBM Corporation - pcd-supplier-support.compcd-supplier-support.com/index/Content/EventDocuments/IBM Global... · European Union Directive 2011/65/EU on the “Restriction

IBM Global Webinar

CoE Product Environmental Compliance in Collaboration with WSP

© 2015 IBM Corporation

This presentation is intended to provide general information about the subject matter covered and is not meant to provide legal opinions, offer legal advice, or serve as a substitute for advice by licensed, legal professionals. Although IBM made best efforts to ensure that the information herein is complete and accurate, we do not warrant or guarantee that the information is either. IBM hereby disclaims any liability to any person for any loss or damage caused by reliance on this presentation.

IBM Confidential – Do Not Reproduce Without Permission From IBM

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Topics and Speakers

� EU RoHS Exemption Expiry Jeff Lagler, IBM RoHS Program Manager

© 2015 IBM Corporation3

� 46G3772 Updates Goh Wei Hong, IBM Project Manager

� PCD Changes Amy Couch Schultz, WSP Vice President

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IBM Product Environmental Compliance Webinar

RoHS Exemptions and IBM Strategy

© 2013 IBM Corporation

This presentation is intended to provide general information about the subject matter covered and is not meant to provide legal opinions, offer legal advice, or serve as a substitute for advice by licensed, legal professionals. Although IBM made best efforts to ensure that the information herein is complete and accurate, we do not warrant or guarantee that the information is either. IBM hereby disclaims any liability to any person for any loss or damage caused by reliance on this presentation.

IBM Confidential – Do Not Reproduce Without Permission From IBM

CoE Product Environmental Compliance

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RoHS Agenda

� RoHS Overview

� Exemption Timeline

� RoHS Strategy

� IBM Exemption removal: 7b, 8b, & 15

� Lessons Learned in 2012

� Summary

© 2013 IBM Corporation5

� Summary

� Back-up: Supplier Letter / RoHS Exemptions

This presentation is intended to provide general information about the subject matter covered and is not meant to provide legal opinions, offer legal

advice, or serve as a substitute for advice by licensed, legal professionals. Although IBM made best efforts to ensure that the information herein is

complete and accurate, we do not warrant or guarantee that the information is either. IBM hereby disclaims any liability to any person for any loss or

damage caused by reliance on this presentation.

rev: 01/12/15

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� European Union Directive 2011/65/EU on the “Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment,” also referred to as RoHS Recast, entered into force on July 21, 2011. The RoHS Recast repeals the original RoHS Directive 2002/95/EC and its amendments and became effective Jan. 3, 2013. In accordance with the current RoHS requirements, ALL exemptions will expire July 21, 2016 unless industry successfully petitions that they be extended.

� IBM by way of a Supplier Letter, asked you to note the exemptions that are currently used by

IBM are likely to be affected by the next exemption expiration cycle in 2016. If your company

2016 RoHS Overview

© 2013 IBM Corporation6

IBM are likely to be affected by the next exemption expiration cycle in 2016. If your company

requires the use of these exemptions past 2016, IBM strongly recommended that your

company became active in industry consortia activities so as to generate the necessary

technical data for successful extension petitions by year end 2014.

� As of January 2015, IBM is asking you to remove from your products those materials and components that require the use of an exemption that IBM deems as likely to expire. To ensure compliance of IBM's products, these exemptions will be removed from our purchased hardware by July 2015, to enable inventory to be purged and be fully compliant by December 2015.

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Exemption timelines

© 2013 IBM Corporation7

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RoHS Phase III Strategy Update

Phase II Phase III Phase IV

All 18 remaining exemptions used by IBM are subject to expiration during this period.

Only those that have an approved application may be extended. The exemptions expiring during this phase are unknown

EOL systems identified … 2Q2014

ALL systems compliant by YE2015

© 2013 IBM Corporation8

Phase II Phase III Phase IV

- 1/2/2013 1/2/2013 – 7/21/2016 7/21/2016 +

Exemption Phase Approach

• Phase I - Exemptions Expired 12/31/2010

• Phase II - Exemptions expired 12/31/2012…7cIII & 11b

• Phase III - Remove PNs with Exemptions 7b, 8b, & 15 from existing systems by YE2015

• Phase IV - Exemptions in late 2016 or 2017 that need to be removed based on EU final decision.

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Exemptions 7b, & 8b, identified by IBM as end-of-life in our product sets …

Exemption 7b & 8b - Technical information

© 2013 IBM Corporation9

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Exemption 15 - Technical information

Exemptions 15 identified as now likely to split into four unique applications based on final Consortia dossier submission to EU…

Industry submitted petition …

requesting that a subset of the current exemption 15

extension for another 5 years.

Proposed Wording:

"Lead in solders to complete a viable electrical connection between

active component(s) and the carrier within integrated circuit flip

© 2013 IBM Corporation10

rev: 01/12/15

active component(s) and the carrier within integrated circuit flip

chip packages with at least one of the following characteristics:

- Greater Than or Equal to 90nm semiconductor technology node

- Die size greater than or equal to 300mm2 in any semiconductor

technology / node (including stacked die)

- Stacked Die Packages using interposers greater than or equal to

300mm2

- High current products (Rated at greater than or equal to 3amps)

that use smaller package designs (With die sizes less than 300mm2)

incorporating the flip chip on lead-frame (FCOL) interconnect."

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Exemption 15 - Technical information

Dear Supplier,

Based on information that you have provided IBM in the past via our PCD (Product Content Declaration) form, one or more of the products that IBM

procures from your company requires the use of a RoHS exemption (per the EU's RoHS directive), in this particular case exemption 15. Here is a

summary of what is being requested:

Existing Wording (for exemption 15):

“Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages”

Proposed Wording:

"Lead in solders to complete a viable electrical connection between active component(s) and the carrier within integrated circuit flip chip packages

with at least one of the following characteristics:

© 2013 IBM Corporation11

with at least one of the following characteristics:

- Greater Than or Equal to 90nm semiconductor technology node

- Die size greater than or equal to 300mm2 in any semiconductor technology / node (including stacked die)

- Stacked Die Packages using interposers greater than or equal to 300mm2

- High current products (Rated at greater than or equal to 3amps) that use smaller package designs (With die sizes less than 300mm2) incorporating

the flip chip on lead-frame (FCOL) interconnect."

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Exemption 15 - Technical informationIn analyzing this petition, there are several application spaces that are not being petitioned for extension, most notably:

- single die devices with a die size less than 300mm2 and manufactured in a semiconductor technology node of less than 90 nm (e.g., 65nm,

45nm, 40 nm 32nm, 28nm, 22nm, etc. ) Based on this, IBM would expect that many of the devices currently requiring exemption 15 will not be

extended, and those devices must be replaced with a product that does comply with updated RoHS requirements.

Therefore, for the attached product p/ns provided, IBM is requesting the following information for each product p/n:

1. Please confirm that the exemption 15 claim for the product is still valid. (Yes or No).

1a. If no, please state whether the product never required the exemption or if the need for the exemption was recently removed. (Never

required or recently removed)

1b. If recently removed please state when it was removed (assembly date code), and if the product p/n has been changed since it was removed.

(assembly date code? ________, p/n change Y/N?)

2. If the exemption 15 claim is still valid, please state which of the 5 options applies: (A, B, C, D, or E)

A - Greater Than or Equal to 90nm semiconductor technology node

B - Die size greater than or equal to 300mm2 in any semiconductor technology / node (including stacked die)

© 2013 IBM Corporation12

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B - Die size greater than or equal to 300mm2 in any semiconductor technology / node (including stacked die)

C- Stacked Die Packages using interposers greater than or equal to 300mm2

D - High current products (Rated at greater than or equal to 3 amps) that use smaller package designs (With die sizes less than

300mm2) incorporating the flip chip on lead-frame (FCOL) interconnect.

E - Not covered by any of the above 4 applications in the petition

2a, If the product in question is an assembly and contains more than one device that requires exemption 15, please list out each device in the

assembly that currently requires exemption 15, and state which of the above 5 options applies to each.

3. If one or more devices within the product needs to be replaced (option E), please answer the following question regarding the replacement

product:

3a. date when the replacement product will be qualified by your company?___________

3b. date when samples of the replacement product will be available?_____________

3c. date when replacement product will be available for shipment to IBM?______________

3d. what is the new orderable p/n for the replacement product?__________________

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Exemption timelines

© 2013 IBM Corporation13

Consortia

Exemption discussions

(bold text identifies accepted IBM

PCD exemptions after July 16,

2015)

End of Life 3a, 3b, 5a, 7b, 8b, 24, & 38

Expected Extend 5b, 7cI, 7cII, 13a/b, 29

Expected Extend with scope change 6a, 6b, 6c, 7a, 7cIV, 15

r: 1-12-2015 Bold text acceptable in PCD after 1/16/2015.

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2012 Lessons Learned

� Early Transitioning plan is vital

- Strong communication & committed resources:

across organization, Business Partners, as-well-as sub-contractors

- Well-defined schedule, broad and continuous communication

- New orderable PN Mandatory for replacement products from a supplier

- IBM part number will be changing for your replacement products.

© 2013 IBM Corporation14

- IBM part number will be changing for your replacement products.

� On-time release of RoHS Compliant part numbers

� Accurate PCD information

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� If your products contain a RoHS exemption that IBM deems will likely expire, IBM will require you to:

a) ensure that the replacement product is qualified and has equivalent reliability;

b) assign a new supplier p/n to the replacement product, and that the new p/n is

communicated to IBM procurement personnel; and

c) submit a Product Content Declaration (PCD) to IBM or an IBM Material

2016 RoHS … Summary

© 2013 IBM Corporation15

c) submit a Product Content Declaration (PCD) to IBM or an IBM Material

Declaration for Microelectronics Division Suppliers, for the replacement product.

� IBM appreciates your cooperation and support with the recent elimination of exemptions. IBM will continue to work with its suppliers on this current phase out.

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RoHS Back-up charts

© 2013 IBM Corporation16

EU RoHS Directive: http://ec.europa.eu/environment/waste/rohs_eee/http://eur-lex.Europa.eu/LexUriServ/LexUriServ.do?OJ:2011:174:0088:0110:en:pdfhttp://ec.Europa.eu/environment/waste/rohs_eee/adaptation_en.htmhttp://ec.Europa.eu/environment/waste/rohs_eee/pdf/renewal_exemptions_oct14-jan15.pdf

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Reference: RoHS Recast Supplier Update Document

To: @COMPANY

Dear @CONTACT,

Please review this “RoHS Supplier Update" letter and then take a moment to click on the link below to acknowledge your receipt of this e-mail. Your acknowledgement to this correspondence is

requested by 4 week out date or before. Note that you must have live internet access in order to acknowledge your receipt. Reminder emails will be sent every two weeks until this link is selected.

@ACKURL

European Union Directive 2011/65/EU on the “Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment,” also referred to as RoHS Recast, entered into force on July

21, 2011. The RoHS Recast repeals the original RoHS Directive 2002/95/EC and its amendments and became effective Jan. 3, 2013. In accordance with the current RoHS requirements, ALL exemptions will

expire July 21, 2016 unless industry successfully petitions that they be extended.

IBM asks you to note these exemptions (please see attached table) that are currently used by IBM are likely to be affected by the next exemption expiration cycle in 2016. If your company requires the

use of these exemptions past 2016, IBM strongly recommends that your company becomes active in industry consortia activities now, to generate by year end 2014 the necessary technical data for

successful extension petitions.

By January 2015, IBM will be asking you to remove from your products those materials and components that require the use of an exemption that IBM deems as likely to expire. To ensure compliance of

IBM's products, these exemptions will be removed from our purchased hardware by July 2015, to enable inventory to be purged and be fully compliant by December 2015.

If your products contain a RoHS exemption that IBM deems will likely expire, IBM will require you to:

a) ensure that the replacement product is qualified and has equivalent reliability;

Supplier Letter mailed 12-2013

© 2013 IBM Corporation17

April 2009

@CHAIR Thomas Jagielski Jackie Adams

STG Environmental Affairs

Focal Point

IBM Global Chair for Product

Environmental Compliance

a) ensure that the replacement product is qualified and has equivalent reliability;

b) assign a new supplier p/n to the replacement product, and that the new p/n is communicated to IBM procurement personnel; and

c) submit a Product Content Declaration (PCD) to IBM or an IBM Material Declaration for Microelectronics Division Suppliers, for the replacement product.

IBM appreciates your cooperation and support with the recent elimination of exemptions. IBM will continue to work with its suppliers on this current phase out.

RoHS Compliance Standard Update:

For your awareness, the 2013 version of the RoHS compliance test standards, IEC 62321: ‘Determination of Certain Substances in Electrotechnical Products’, has been released, replacing the original

version released in 2008. If you perform sample testing to verify compliance to RoHS requirements, you must use IEC 62321. Please note that this standard has been split into a family of standards with

the following subsections:

In the last revision of IBM Engineering Specification 46G3772, “Baseline Environmental Requirements for Supplier Deliverables to IBM”, Section 2.14, “Requirements for RoHS”, was updated to include

reference to IEC 62321.

In addition, IBM Product specifications 53P6233 and 97P3864 contain updates and details regarding material restrictions, allowable finishes and exemptions.

IBM continues its long-standing commitment to doing business with environmentally responsible suppliers and requires its suppliers to conform to all laws and IBM specifications.

Sincerely,

Regards,

rev: 01/12/15

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Exemptions…

Exemptions that IBM is expecting to go end-of-life; to be removed by December 2015:

3(a) Mercury Short length (≤ 500 mm)

3(b) Mercury Medium length (> 500 mm and ≤ 1 500 mm)

5(a) Lead in glass of cathode ray tubes

7(b) Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network

management for telecommunications

8(b) Cadmium and its compounds in electrical contacts

24 Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors

38 Cadmium and cadmium oxide in thick film pastes used on aluminum bonded beryllium oxide (IBM specific)

Exemptions that IBM is expecting to be extended as is:

5(b) Lead in glass of fluorescent tubes not exceeding 0,2 % by weight

7(c)-I Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or

© 2013 IBM Corporation18

7(c)-I Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or

in a glass or ceramic matrix compound

7(c)-II Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher

13(a) Lead in white glasses used for optical applications

29 Lead (Pb) bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC

Exemptions that IBM is expecting to be extended with changed scope:

6(a) Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35% lead by weight

6(b) Lead as an alloying element in aluminum containing up to 0.4% lead by weight

6(c) Copper alloy containing up to 4% lead by weight

7(a) Lead in high melting temperature type solders (i.e. lead- based alloys containing 85 % by weight or more lead)

7(c)-IV Lead in PZT based dielectric ceramic materials for capacitors being part of integrated circuits or discrete semiconductors

15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages

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Questions?

We welcome your questions. To submit a question, please use the questions section of your webinar navigation tool. Your question will be answered at the end of the webinar.

© 2013 IBM Corporation19

Answers are provided for informational purposes only and cannot be relied upon as a legal opinion or business advice

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IBM Global Webinar – 46G3772 Updates

© 2015 IBM Corporation

This presentation is intended to provide general information about the subject matter covered and is not meant to provide legal opinions, offer legal advice, or serve as a substitute for advice by licensed, legal professionals. Although IBM made best efforts to ensure that the information herein is complete and accurate, we do not warrant or guarantee that the information is either. IBM hereby disclaims any liability to any person for any loss or damage caused by reliance on this presentation.

IBM Confidential – Do Not Reproduce Without Permission From IBM

CoE Product Environmental Compliance

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Agenda

� Table of Additions and Updates

�17 Oct 2014 Release

�16 May 2014 Release

� Description of Updates

� Removed Contents

© 2015 IBM Corporation21

� Removed Contents

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Table of Additions and Updates – 17 Oct 2014 Release

Date EC Level Change Summary

17 Oct 2014 N46883 Section 1.2 – Added definitions for Agglomerate, Aggregate, and Particle.Table 1 – Mercury use in lamps prohibited. Additional lead restriction for paints, enamels, varnishes, inks and lacquers. Additional restrictions added for HFCs. Fluorinated and perfluorinated compounds added. Exemption for rubber added for BNST.Table 4 - HFCs removed. 2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320) and 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328) added.Table 5 – New SVHCs added- 1, 2-Benzenedicarboxylic acid, dihexyl ester, branched and linear and cadmium chloride.Section 2.9.1 – Updated as applicable due to the transition from Standard SJ/T 11363-2006 to Standard GB/T 26572-2011 per the China marking standard SJ/T 1164-2014.Section 2.9.2.1 – China Standard reference updated. Allowance to have the Mark 1 logo in product instructions only removed. DOM marking requirement updated.

Will be updated in upcoming PCD

release in Q2

© 2015 IBM Corporation22

product instructions only removed. DOM marking requirement updated.Section 2.9.2.2 – Reference to China HST table now in ENUG. HST table requirements updated.Section 2.12.1 – Definition of computer monitor altered for Australia requirements.Section 2.12.7 – US requirements for single phase motors updated. Requirements for 3 phase motors removed.Section 2.14.3 – Requirement added to place IBM SPOC on products where IBM is listed as manufacturerSection 2.15 – Additional languages required for labels.Annex K – Substances added.Annex L – Updated with additional synonyms.Annex JJ – Additional substances added.Annex NN – Authorized substances removed. New SVHCs added.Annex SS – Added.Annex TT – Added.

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Table of Additions and Updates (1) – 16 May 2014 Release

Date EC Level Change Summary

16 May 2014 N33076A Table 1 – Annex changed for Benzidine and compounds to QQ. “Articles containing leather parts” added in entry for hexavalent chromium.Table 2 – Entry for Carcinogens, Mutagens, and Reproductive toxicants deleted as they were duplications for another entry. Entry for 2-butoxyethanol updated.Table 4 – Added - cobalt dichloride, cobalt metal, cobalt sulfate, 2, 3-Dibromo-1-propanol (was in brominated flame retardant category before), dibromoneopentyl glycol (was in brominatedflame retardant category before), indium phosphide, nanomaterials, nickel sulfamate, nickel sulphate, nonylphenols and refractory ceramic fibres. Diethyl phthalate was given a separate entry from the general phthalate category, and beryllium (CAS 7440-41-7) was given a separate entry from the general beryllium/beryllium compounds entry. Arsenic pentaoxide and arsenic trioxide each given a separate entry from the general arsenic/arsenic compounds entry. Reporting level for HBCDD changed from 1000 ppm to 50 ppm.

Covered as part of PCD updates

© 2015 IBM Corporation23

Reporting level for HBCDD changed from 1000 ppm to 50 ppm.Table 5 - Lead titanium trioxide now specifically listed here rather than just in Annex NN. Cadmium sulphide and DNHP added.Section 2.3.1 – Reference in Section “California Safe Drinking Water and Toxic Enforcement Act” ISN-CAP54 changed to ISN-CAP65. Clarification added that only the CE mark may be used to demonstrate conformity to an EU CE mark legislation.Section 2.4.2 – Requirements added for labeling batteries for Ecuador. Instructions for battery removal now refers to removal by a qualified professional. The removal instructions must accompany the product or refer to the location of the removal instructions.Section 2.8.2 – Requirement added to send information about reading a coded DOM.Section 2.10 – Further clarification for switches and routers that require an IBM ENUG.Section 2.12 – Multiple sections updated with reference and requirements for energy regulations in Jordan.Section 2.12.2 – Reference to Oregon rule added. Scope of EPSs altered with publication of EU Regulation 617/2013 for computer and computer servers.Section 2.12.7 – Scope of EU ERP regulation for motors altered.

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Table of Additions and Updates (2) – 16 May 2014 Release

Date EC Level Change Summary

16 May 2014 N33076A Annex MM – Additional examples added for perchlorates.Annex NN – New SVHCs listed.Annex RR – Added.

© 2015 IBM Corporation24

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Description of Updates

© 2015 IBM Corporation25

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Agglomerate - a collection of weakly bound particles or aggregates where

the resulting external surface area is similar to the sum of the surface areas of the individual components. [Source: EU Commission Recommendation

2011/696/EU on the definition of nanomaterial]

Aggregate - a particle comprising of strongly bound or fused particles.

[Source: EU Commission Recommendation 2011/696/EU on the definition of

Added definitions for Agglomerate, Aggregate, and Particle.1

Section 1.2

© 2015 IBM Corporation26

nanomaterial]

Particle - a minute piece of matter with defined physical boundaries.

[Source: EU Commission Recommendation 2011/696/EU on the definition of nanomaterial]

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Section 2.3.1

ISN-CAP54 updated to ISN-CAP65 in IBM’s ‘Information for Suppliers’ website 1

© 2015 IBM Corporation27

Clarification added that only the CE mark may be used to

demonstrate conformity to an EU CE mark legislation.2

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Requirements added for labeling batteries for Ecuador. 1

Section 2.4. 2

© 2015 IBM Corporation28

Instructions for battery removal2

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Section 2.8. 2

© 2015 IBM Corporation29

Requirement added to send information about reading a coded DOM.1

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Section 2.9.2.1

© 2015 IBM Corporation30

China Standard reference updated. 1

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Reference to China HST table now in ENUG. HST table

requirements updated.1

Section 2.9.2.2

New naming convention for table 2

© 2015 IBM Corporation31

HST table requirements update to reference new standards SJ/T

11364.and GB/T 26572 standards.3

New naming convention for table 2

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Section 2.10

© 2015 IBM Corporation32

Further clarification for switches and routers that require an IBM ENUG.1

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Section 2.12

© 2015 IBM Corporation33

Multiple sections updated with reference and requirements for energy regulations in Jordan as part of the countries requiring EU legislation

requirements.1

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Section 2.12.1

© 2015 IBM Corporation34

Definition of computer monitor altered for Australia requirements

by covering any type of display input.1

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Reference to Oregon rule added. 1

Section 2.12. 2

© 2015 IBM Corporation35

Definition Scope of EPSs altered with publication of EU Regulation 617/20132

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Scope of EU ERP regulation for motors altered.1

Section 2.12. 7

© 2015 IBM Corporation36

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US requirements for single phase motors updated. Requirements for 3 phase motors

removed for EU, Norway, Jordan, Turkey, Australia, New Zealand, Canada and Israel1

Section 2.12.7, cont.

© 2015 IBM Corporation37

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Requirement added to place IBM SPOC on products where IBM

is listed as manufacturer1

Section 2.14.3

© 2015 IBM Corporation38

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Section 2.15

© 2015 IBM Corporation39

Additional languages required for labels.1

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Multiple Substances added for Annex K.1

Annexes

© 2015 IBM Corporation40

Updated with additional synonyms. 2

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Annexes

Substances removed and moved to Authorized Substance list. New SVHCs added.4

Additional substances added to Annex JJ3

© 2015 IBM Corporation41

Added Annex SS5

Added Annex TT6

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Additional examples added for perchlorates – Barium, Lead, Magnesium and Nickel.1

Annexes Added

New SVHCs listed.2

© 2015 IBM Corporation42

Annex RR added3

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Removed Contents

Date EC Level Change Summary

17 Oct 2014 N46883 Table 12 – MFD, Printers and POS products removed.

16 May 2014 N33076A Table 8 – Exemptions for mercury level for button cell batteries removed.Annex U – Arsenic trioxide and arsenic pentoxide removed as these substances now have specific entries on Table 4.Annex V- Title changed to Beryllium Compounds. Beryllium removed since it now has its own entry on Table 4. Additional CAS number added for beryllium carbonate.

© 2015 IBM Corporation43

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Questions?

We welcome your questions. To submit a question, please use the questions section of your webinar navigation tool. Your question will be answered at the end of the webinar.

© 2015 IBM Corporation44

Answers are provided for informational purposes only and cannot be relied upon as a legal opinion or business advice

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PCD Process: - Updates,

Amy Couch Schultz

Vice President

- Updates,

- RoHS Exemptions, - Common Errors, and - Support Services

This presentation is intended to provide general information about the subject matter covered and is not meant to provide legal opinions, offer legal advice, or serve as a substitute for advice by licensed, legal professionals. Although the author made best efforts to ensure that the information herein is complete and accurate, we do not warrant or guarantee that the information is either. IBM hereby disclaims any liability to any person for any loss or damage caused by reliance on this presentation.

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46

�IBM’s PCD Form & Recent Updates

�RoHS Exemptions Changes

�Common PCD Errors and Their Resolution

Agenda

�Support Services

�Summary

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47

IBM ES 46G3772 and Product Content Declaration (PCD)

IBM

**Current IBM PCD Version 5/16/14 Rev 001 can be downloaded here:

http://www.ibm.com/ibm/environment/products/ecpquest.shtml

Global Environmental Legislations

IBM ES 46G3772Baseline Environmental Requirements for Supplier Deliverables to IBM

PCD• Declaration of compliance with IBM 46G3772 and

reporting of certain chemicals• Parametric form• Format for loading into IBM internal systems• Required from all suppliers

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48In

str

ucti

on

s T

ab

Material, Part or Product Description

2. Prohibited Substances (Y/N)

PCD Form OverviewPart Numbers Tab

•IBM EC Number, IBM PN and Supplier PN

•Weight of part (grams) required

•Single or multiple parts

•IBM EC Number, IBM PN and Supplier PN

•Weight of part (grams) required

•Single or multiple parts

Continue

Continue

RoHS TabExemptions Tab

1. 46G3772 Compliance (Y/N)Contact your IBM Procurement Representative

Contact your IBM Procurement Representative

Y

N

Y

N

Instr

ucti

on

s T

ab

5. SVHC Substances (Y/N)

4. Reportable Substances (Y/N)

•RoHS substance, CAS Number

•Total substance weight

•Location of RoHS substance in part

RoHS TabExemptions Tab

•RoHS exemptions

•Check applicable exemptions

•Reportable substance per IBM 46G3772 Table 4: Other Reportables

•CAS No., amount of substance (grams), location

Reportable Tab

3. RoHS Substances (Y/N)

SVHC Reportable Tab

•SVHC reportable substance per IBM 46G3772 Table 5 or Annex NN

•IBM PN and Supplier PN

•CAS No., weight and concentration (ppm)

Continue

Continue

Continue

Y

N

Y

N

Y

N

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49PCD Form Overview (cont.)In

str

ucti

on

s T

ab

7. Cable Assembly (Y/N) Continue

6. Battery (Y/N)

Y

N

Battery Tab

•Battery technical and supplier specific information

Assembly Battery Tab

•Assembly battery details

Continue

N•Bill of Materials for cable assemblies

•Weight of all cable assemblies reported should be within 15% Weight of Part (grams) required

•Single or multiple parts

Cable Assembly Tab

•Declare 3TG present in the product

Conflict Minerals Tab

Y

Y

Data Summary Tab

• Check for errors that would prevent form processing

Supplier Questions Tab

Optional - use to provide comments or

clarification for responses in the PCD form.

Instr

ucti

on

s T

ab

9. Vendor Logo Product (Y/N)

8. Conflict Minerals (Y/N)

ContinueN

N

• Answer questions regarding VLP conformity,

compliance.

Vendor Logo Product Tab

Y

Y

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50

Scope and Instructions Section Changed instructions to remind suppliers to check the current version of

the PCD and provided the link to the form.

Prohibited Substances Modified• Hexavalent Chromium/Hexavalent Chromium Compounds (in paint or plastic)

to• Hexavalent Chromium/Hexavalent Chromium Compounds (in paint, plastic, or

articles containing leather parts)

Cable Assembly QuestionAdded "IBM-designed" to the cable assembly question.

Instructions Tab

Added substances:• Cobalt dichloride (CAS 7646-79-9)• Cobalt metal (CAS 7440-48-4)• Cobalt sulfate (CAS 10124-43-3, 13455-64-0, 10026-24-1)• Indium phosphide (CAS 22398-80-7)• Nickel sulfamate (CAS 13770-89-3)• Nickel sulphate (CAS 7786-81-4, 10101-97-0, 10101-98-1)• Nonylphenols• Nanomaterials intended to be released• Refractory ceramic fibres

• 2,3-dibromo-1-propanol (CAS 96-13-9) was in brominated flame retardant category, now moved to its own entry.

• Arsenic pentoxide (CAS 1303-28-2)was in the arsenic and compounds category, now moved to its own entry.

Reportable Tab

Summary of Changes – 4Q2014 IBM PCD Release

Only exemptions in black text are allowed for IBM Deliverables All other exemptions are grayed out and will generate the error :

“An exemption that may not be used was selected. Please contact your IBM Procurement Representative.”

The PCD will also include an error on the data summary tab and will not auto-load into IBM systems.

Exemptions Tab

was in the arsenic and compounds category, now moved to its own entry.

• Arsenic trioxide (CAS 1327-53-3)was in the arsenic and compounds category, now moved to its own entry.

• Beryllium metal (CAS 7440-41-7)was in the beryllium compounds category, now moved to its own entry.

• Beryllium Compoundsremoved Beryllium/Beryllium Compounds category from PCD since Beryllium metal was given its own category.

• Dibromoneopentyl-glycol (CAS 3296-90-0)was in brominated flame retardant category, now moved to its own entry.

• Diethyl phthalate (CAS 84-66-2)was in the Phthalate category, now moved to its own entry.

Removed substance:• Beryllium/Beryllium Compounds

Added logic to validate engineering change number (ECN) format**ECN is required to be filled in for ECAT and Mechanical PCDs.

Part Numbers Tab

The 4Q2014 IBM PCD Release (Version 5/16/14 Rev 001) is based on the May 2014 release of

IBM ES 46G3772.

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51

Battery Tab Assembly Battery Tab

Clarified and added new instructions:

• For IBM-designed cable assemblies, each component or material such as bulk cable, cable connectors, over mold material, terminals,

PCB, solder, housing, shrink tubing, flex braid, tapes, adhesives,

ferrite cores, labels, brackets, screws, etc., must be listed and reported.

• Multiple cable assembly part numbers may be reported on this PCD only when the cable assemblies are identical in material composition and when the weights of these cable assemblies are within 15% from minimum weight to maximum weight. When multiple cable assembly part numbers are reported on the Part Numbers worksheet, the

Cable Assembly Tab

Added 3 new substances to SVHC reportable tab:• Cadmium sulphide (CAS 1306-23-6)• Di-n-hexyl phthalate (DNHP) (CAS 84-75-3)• Lead titanium trioxide (CAS 12060-00-3)

Data validationAdded logic to check when “Other” SVHC is reported. If the CAS

number matches the CAS number of an SVHC on the pick list it will instruct the user to select the SVHC from the pick list instead of using “Other” SVHC.

SVHC Tab

Summary of Changes – 4Q2014 IBM PCD Release (cont.)

Changed input message for the battery weight question

Changed Battery Chemistry Name: • Sealed Lead Acid (Pb/PbO2) gel to Non spillable , Sealed Lead Acid

(Pb/PbO2) • Lithium Nickel Manganese Cobalt Oxide (LiNiMnCoO2) to

LiNiMnCoO2

Added 4 new selections to the Assembly Battery pick list:Battery Model/Name:

CSB GP1272CSB HR1234WGS Yuasa NPW45-12BB HR5.5-12

maximum substance weight must be reported on the RoHS and Reportable worksheets. The maximum substance weight would generally be associated with the longest cable.

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52

Only exemptions in black text are

allowed for IBM Deliverables.

Prohibited exemptions were grayed out and will show the error “An exemption that may not be used

was selected. Please contact your

IBM Procurement Representative.”

when selected.

Exemptions

RoHS Exemptions Changes

• Mercury/Mercury Compounds: 1(a), 1(b), 1(c), 1(d), 1(e), 1(f), 1(g), 2(a)(1), 2(a)(2), 2(a)(3), 2(a)(4), 2(a)(5), 2(b)(1), 2(b)(2), 2(b)(3), 2(b)(4), 3(a), 3(b), 3(c), 4(a), 4(b)-I, 4(b)-II, 4(b)-III, 4(c)-I, 4(c)-II, 4(c)-III, 4(d), 4(e), 4(f), 4(g), 36

• Lead/Lead Compounds: 5(a), 5(b), 7(b), 7(c)-III, 7(c)-IV, 9(b), 11a, 11b, 12, 14, 16, 17, 18a, 18b, 19, 20, 21, 22, 23, 24, 25, 26, 27, 31, 32, 33, 34, 37, 41

• Cadmium/Cadmium Compounds: 8a, 8b, 21, 30, 35, 38, 39, 40• Hexavalent Chromium/ Hexavalent Chromium Compounds: 9• Polybrominated Diphenylethers (PBDEs): 9a

Prohibited Exemptions

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Exemptions

53

If a prohibited exemption is

claimed, an error message will

show in the PCD.

RoHS Exemptions Changes (cont.)

Data Summary

Error was reflected on

the Data Summary Tab.

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54

Common PCD Errors

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55

Instructions

Submission Date was not provided as required

If the error reflected on the Data Summary tab is not corrected, the Supplier PCD will fail to load into IBM system.

Instructions Tab: Submission date not filled-in

Data Summary

The submission date entered on the PCD form should reflect the date the supplier submits the PCD to WSP.

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56

Part Number

PCD will validate the format of the IBM EC

Number that was entered.

*EC Number is only required for ECAT and

Mechanicals.

ECN Format Check

Part Numbers Tab: ECN Format

Positions Characteristics

1 – 510000 (is usually omitted and may not

be required)

6 - 10All alphabetic characters except B, I,

O, Q, S, and Z are valid, and all numeric characters are valid

11 Numeric only

12Alphabetic or blank (Any alphabetic

characters should be upper case but

will allow lower case as well)

10000B77594

10000I77594

10000O77594

10000Q77594

10000S77594

10000Z77594

10000B77594

10000I77594

10000O77594

10000Q77594

10000S77594

10000Z77594

D7759AD7759A

Part Number

Correct ECN format

Incorrect ECN format:

used B, I, O, Q, S and Z on 6th digit

Incorrect ECN format:

used alphabetic character on 11th digit

An incorrect ECN will exhibit a warning.

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57

IBM Part Number (IBM PN) having the same Supplier Part Number (SPN), but with different

part weight declarations

Part Numbers Tab: Mismatch on declared part weights

Part weights should match for IBM Part Number (IBM PN) with same Supplier Part Number

(SPN)

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58

Part Numbers

The request email includes both the IBM PN and SPN from the

PCD Request submitted to WSP.

Part Numbers Tab: IBM PN and SPN declaration

The supplier is required to input both the IBM PN and SPN on the Part Numbers tab.

If this information is missing, an error will show on the Part Numbers and Data

Summary tab of the PCD.

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59

Instructions

Cable Assembly

Old

New

Added “IBM-designed" to the

Cable Assembly Question on

the Instruction sheet.

NewOld

Cable Assembly – New Instructions

Cable Assembly New

Added instructions for “IBM

designed” cables and multiple

cable assembly PNs.

Old

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60

IBM ES 46G3772

Reportable

A category for reporting of

Radioactive Substances is

available in the Reportable Tab

Reporting of Radioactive Substances

Only a radioactive substance that is intentionally added should be

reported on the Reportable tab.

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61

Reportable

It is recommended that the CAS Number of the declared substance be

provided whenever available.

Completion of Reportable Tab

All rows should be completed, otherwise an error

will be shown

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62

Always check if a substance was reported under the correct chemical

category. You may refer to IBM ES 46G3772 to verify the correct category.Reportable

Reporting of Substances in Correct Chemical Categories

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63

Use of Data Summary Tab

InstructionsAnswers selected from the Instruction Tab and other Tabs are

reflected in the Data Summary Tab

Reportable

Data Summary with Errors Data Summary without Errors

Any tab that has an error will be identified, thus the PCD is expected to fail the system. You

will need to work out these errors before submitting the PCD to WSP.

If a PCD was successfully

completed, no error will be

shown in the Data Summary

Tab

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64

Supplier Support Portal

Site Link: http://pcd-supplier-support.com/index/Supplier/Home

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65

Help Desk Support � Currently available for IBM users only

� Available for suppliers in 2Q 2015

Chat with a WSP representative for real time response/support.

Report an issue and WSP will respond though email.

Leave your contact number and WSP will call you.

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• Carefully read the instructions provided in each tab to understand how to correctly fill out a PCD.

• Double check each tab for any errors as indicated by the warnings provided.

• Review the “Data Summary Tab” for errors before submitting the PCD to reduce the turn-around time for the request.

• Attend IBM-WSP training sessions to learn about the latest PCD

66

Summary

• Attend IBM-WSP training sessions to learn about the latest PCD updates. Training sessions are designed to help both suppliers and IBM users. Recordings of the training sessions are available.

• Visit, explore and utilize the Supplier Support Portal for any questions related to IBM’s product environmental compliance requirements for supplier deliverables.

• Contact WSP support personnel for assistance in completing the PCD.

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67

PCD Training Materials:http://pcd-supplier-support.com/index/Supplier/EventPlayback

Information for Suppliers:http://www-

03.ibm.com/procurement/proweb.nsf/ContentDocsByTitle/United+States~Information

+for+suppliers

IBM Product Stewardship:http://www.ibm.com/ibm/environment/products/

More Information

http://www.ibm.com/ibm/environment/products/

Baseline Environmental Requirements for Supplier Deliverables to IBM:http://www.ibm.com/ibm/environment/products/especs.shtml

Product Content Declaration for IBM Suppliers:http://www.ibm.com/ibm/environment/products/ecpquest.shtml

PCD Supplier Support Portal:http://pcd-supplier-support.com/index

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68

Leslie Mae De Leon

Team Lead – IBM Project

Manila, Philippines

[email protected]

+63 (917) 858-9377

Teresa Visto

Contacts

Mary Beth FletcherProject Manager – IBM WSP [email protected]+1-845-433-5648

Jeff Lagler

WSP IBM

Teresa Visto

Projects Team Lead

Manila, Philippines

[email protected]

+63 (917) 859-0146

Amy Couch Schultz, PMP

Vice President/QA Officer

Pennsylvania, USA

[email protected]

+1 (412) 352-5714

Jeff LaglerProject Manager – IBM WSP Project (Back-up)[email protected]+1-240-912-4947

Jackie AdamsCoE Senior Technical Staff Member and [email protected]+1-919-254-1237

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Thank you

ANY QUESTIONS?

Thank you

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Questions?

We welcome your questions. To submit a question, please use the questions section of your webinar navigation tool. Your question will be answered at the end of the webinar.

Answers are provided for informational purposes only and cannot be relied upon as a legal opinion or business advice