RoHS and REACH Update 19 July 2011 Technology & Engineering

What is RoHS? Restriction of the use of certain Hazardous Substances in electrical and electronic equipment Directives of the European Parliament and of the Council 2002/95/EC, 2005/618/EC, 2011/65/EU Certain exemptions, including some medical and some military equipment

Definition – European Directive A LAW of and within the European Union! Rules of a government that must be obeyed upon threat of penalties.

RoHS Controlled Substances Lead (0.1%, 1000 ppm) Mercury (0.1%, 1000 ppm) Cadmium (0.01%, 100 ppm) Hexavalent chromium (0.1%, 1000 ppm) Polybrominated biphenyls (PBB) (0.1%) Polybrominated diphenyl ethers (PBDE) (0.1%) Loss of the DecaBDE exclusion forced OCC product redesigns in 2008! The Commission must consider amendments to the list before July 22, 2014, so additions should be expected in the future.

News! RoHS Recast ! RoHS was replaced with a new directive: RoHS Recast (08 June) Possible effects of this new directive are being determined - may impose new compliance data declaration of conformity CE marking of product labeling requirements importer requirements

What is REACH? REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) “This Regulation should ensure A high level of protection of human health and the environment Free movement of substances, preparations and, articles ...while enhancing competitiveness and innovation” Establishes a European Chemicals Agency (ECHA) The Agency, located in Helsinki, maintains a database of registered chemicals http://echa.europa.eu/home_en.asp Far more chemicals than RoHS

REACH vs. RoHS Chemicals Lists

Substances, Preparations, Articles REACH Definitions Substance: Chemical element and its compounds including additives necessary to preserve its stability and any impurity deriving from the process used Preparation: Mixture or solution composed of two or more substances Article: An object which during production is given a specific shape, surface or design, which determines its function to a greater degree than its chemical composition

REACH Registration Requirements Manufacturers and importers of substances are required to register information in the ECHA central database ECHA registration requires a legal entity in the EU familiar with the safe handling of the substances As a manufacturer of “articles” OCC is required to register substances under the normal rules if any substances are intended to be released from articles during normal and reasonably foreseeable conditions of use, and are present in the articles above 1 tonne per year No OCC articles meet these criteria.

Substances of Very High Concern In addition, all substances of very high concern (SVHC) must be identified Category 1 or 2 carcinogens, mutagens, toxic for reproduction, and other substances of equivalent concern SVHC must be notified if present in articles above a concentration limit of 0.1% by weight, and In such case safety instructions should be provided

ECHA Candidate List of SVHCs (p.1) Candidate List of SVHCs as of 20 June 2011 Number of Substances = 53 1,2,3-Trichloropropane Anthracene 1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich Anthracene oil 1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters Anthracene oil, anthracene paste 1-Methyl-2-pyrrolidone Anthracene oil, anthracene paste, anthracene fraction 2,4-Dinitrotoluene Anthracene oil, anthracene paste,distn. lights 2-Ethoxyethanol Anthracene oil, anthracene-low 2-Ethoxyethyl acetate Benzyl butyl phthalate (BBP) 2-Methoxyethanol Bis (2-ethylhexyl)phthalate (DEHP) 4,4'- Diaminodiphenylmethane (MDA) Bis(tributyltin)oxide (TBTO) 5-tert-butyl-2,4,6-trinitro-m-xylene (musk xylene) Boric acid Acrylamide Chromic acid, Oligomers of chromic acid and dichromic acid, Dichromic acid Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins) Chromium trioxide Aluminosilicate Refractory Ceramic Fibres Cobalt dichloride Ammonium dichromate Cobalt(II) carbonate

ECHA Candidate List of SVHCs (p. 2) Candidate List of SVHCs as of 20 June 2011 Number of Substances = 53 Cobalt(II) diacetate Lead sulfochromate yellow (C.I. Pigment Yellow 34) Cobalt(II) dinitrate Pitch, coal tar, high temp. Cobalt(II) sulphate Potassium chromate Diarsenic pentaoxide Potassium dichromate Diarsenic trioxide Sodium chromate Dibutyl phthalate (DBP) Sodium dichromate Diisobutyl phthalate Strontium chromate Disodium tetraborate, anhydrous Tetraboron disodium heptaoxide, hydrate Hexabromocyclododecane (HBCDD) and Alpha, Beta, Gamma diastereoisomers Trichloroethylene Hydrazine Triethyl arsenate Lead chromate Tris(2-chloroethyl)phosphate Lead chromate molybdate sulphate red (C.I. Pigment Red 104) Zirconia Aluminosilicate Refractory Ceramic Fibres Lead hydrogen arsenate  

REACH - We’ve only just begun. Original SVHC list (15) released on 28 October 2008 14 added on 13 January 2010 1 added on 30 March 2010 8 added on 18 June 2010 8 added on 15 December 2010 7 added on 20 June 2011 ECHA plans to address 106 “priority” SVHC’s by 2012. There are hundreds more substances with lesser priority.

SVHC Status - 19 July 2011 REACH requires notification to EU customers if SVHCs are present We have contacted OCC Roanoke and Asheville materials suppliers (including packaging) to request SVHC status Most Roanoke and Asheville suppliers have responded Of hundreds of Substances requested, we have received no reported SVHC Asheville survey includes supplier articles, so is more complex Dallas SVHC survey needs to be done

Beyond REACH Requirements Several customers have persistently requested complete chemical breakdown of all substances contained in OCC articles (Rosenberger OSI, Amphenol, Emerson Stratos) “It is our expectation to receive a materials declaration to assess present and future substances of very high concern” “Without material declaration, we will be required to perform quarterly inquires. A materials declaration will eliminate this requirement“ “In order to comply with our obligations under REACH, we need and expect your cooperation” “You have to fill out the form with following information: which parts do you use to produce that cable what is the weight of each material which is in the cable the name of the materials the substance of the materials the article numbers of that material “We need it for our customer and when we couldn’t deliver that sheet we aren’t able to deliver him our products”

Materials Declaration Test Case Because of strong customer demands, we decided to try a test case of three B-Series cables No proprietary information would be revealed, but we need to know how our suppliers are responding to these requests Requests were sent to 10 suppliers explaining our customer requests and that we were not asking for any proprietary information Our suppliers validated our approach Supplying SVHC information is all that REACH requires for articles which do not emit substances Our suppliers will not reveal detailed Materials Declarations

Materials Declaration Worksheet Example: OC-0001035 BH002ZALS9KRG5-MSY Breakdown of part Material/substance name CAS No. / Int. Identifier Weight in grams Color Concentrate PE   0.0934038 0.1227581 Optical Fiber 0.158 Fiber Buffer PVC 4.7429432 Subunit Jacket TPR 9.3403803 Subunit yarn Aramid Yarn 1.4527273 Filler yarn Polyester Yarn 0.2845455 Cable Jacket Polyolefin 37.437152 Ripcord 0.1490909 Water Block Aramid 5.3454545

Supplier Position on Material Declaration Example: DuPont “DuPont is a science based company and the technology we develop is related to the composition of our polymer compounds and the technology to produce them We agree to share proprietary information in case this is needed, e.g. in case of medical incidences. We are not able to share confidential information. We provide the information related to substances of concern as required by regulations or certain industry agreements. Neither the regulations nor these industry agreements have as an objective to transfer confidential know how to the broad public.”

Future Effects on OCC? Customers continue to demand Materials Declarations No good satisfying solution SVHC list will grow Plasticizers used in PVC, TPR, and packaging might be affected Possible materials impairment similar to previous RoHS issues New RoHS Recast may impose new compliance data, declaration of conformity, CE marks, labeling, and importer requirements Dallas needs to complete REACH and RoHS supplier surveys Cannot rely on military exemption for general export