© 2015 ibm corporation -...
TRANSCRIPT
© 2015 IBM Corporation1
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
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
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
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
� 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.
rev: 01/12/15
Exemption timelines
© 2013 IBM Corporation7
rev: 01/12/15
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."
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."
rev: 01/12/15
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
rev: 01/12/15
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?__________________
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.
rev: 01/12/15
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
rev: 01/12/15
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
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
rev: 01/12/15
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
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
Agenda
� Table of Additions and Updates
�17 Oct 2014 Release
�16 May 2014 Release
� Description of Updates
� Removed Contents
© 2015 IBM Corporation21
� Removed Contents
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.
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.
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
Description of Updates
© 2015 IBM Corporation25
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]
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
Requirements added for labeling batteries for Ecuador. 1
Section 2.4. 2
© 2015 IBM Corporation28
Instructions for battery removal2
Section 2.8. 2
© 2015 IBM Corporation29
Requirement added to send information about reading a coded DOM.1
Section 2.9.2.1
© 2015 IBM Corporation30
China Standard reference updated. 1
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
Section 2.10
© 2015 IBM Corporation32
Further clarification for switches and routers that require an IBM ENUG.1
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
Section 2.12.1
© 2015 IBM Corporation34
Definition of computer monitor altered for Australia requirements
by covering any type of display input.1
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
Scope of EU ERP regulation for motors altered.1
Section 2.12. 7
© 2015 IBM Corporation36
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
Requirement added to place IBM SPOC on products where IBM
is listed as manufacturer1
Section 2.14.3
© 2015 IBM Corporation38
Section 2.15
© 2015 IBM Corporation39
Additional languages required for labels.1
Multiple Substances added for Annex K.1
Annexes
© 2015 IBM Corporation40
Updated with additional synonyms. 2
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
Additional examples added for perchlorates – Barium, Lead, Magnesium and Nickel.1
Annexes Added
New SVHCs listed.2
© 2015 IBM Corporation42
Annex RR added3
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
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
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.
46
�IBM’s PCD Form & Recent Updates
�RoHS Exemptions Changes
�Common PCD Errors and Their Resolution
Agenda
�Support Services
�Summary
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
48In
str
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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
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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
49PCD Form Overview (cont.)In
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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
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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
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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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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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
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.
54
Common PCD Errors
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.
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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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)
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.
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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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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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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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
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
64
Supplier Support Portal
Site Link: http://pcd-supplier-support.com/index/Supplier/Home
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.
• 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.
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
68
Leslie Mae De Leon
Team Lead – IBM Project
Manila, Philippines
+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
+63 (917) 859-0146
Amy Couch Schultz, PMP
Vice President/QA Officer
Pennsylvania, USA
+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
Thank you
ANY QUESTIONS?
Thank you
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