Every home…Everywhere Every home…Everywhere Every home…Everywhere Every home…Everywhere Every home…Everywhere Every home…Everywhere Every home…Everywhere 1 Global RoHS Compliance for Home Appliance Manufacturers ASTM International Technical Committee A05 – Metallic-Coated Iron and Steel Products May 23, 2007

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Outline zWhirlpool Corporation Overview zRoHS Overview zCurrent and Pending RoHS Programs zPolicy Implications zCompliance with RoHS zConclusion

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Whirlpool Corporation Overview zLargest global manufacturer and marketer of major home appliances zAnnual sales of more than $18 billion z73,000 employees zOver 70 manufacturing and technology research centers around the globe zMarket Whirlpool, KitchenAid, Maytag, Jenn-Air, Amana, Brastemp, Bauknecht, Consul and other major brands to consumers in more than 170 countries. zAdditional information at

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Whirlpool Global Operating Platform Leading an $80 Billion Global Industry $18 B Revenues 73,000 employees #1 Global Share #1 Global Brand #1 N.America $12 B Sales 24 Plants #1 L.America $2.4 B Sales 5 Plants #4 Europe $3.4 B Sales 13 Plants Asia $457 M Sales 6 Plants

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Strategy Supports Best Cost, Best Quality Products

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May What is RoHS? zRoHS regulations generally restrict the following substances in electronic and electrical equipment: Lead Mercury Cadmium Hexavalent Chromium (Cr 6+ ) Polybrominated biphenyls (PBBs) Polybrominated diphenyl ether (PDE)

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Current and Pending RoHS Programs zEuropean Union – Directive 2002/95/EC zChina zJapan zKorea zUnited States – State of California (limited to video display devices)

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May EU RoHS zImplemented July 1, 2006 zCompliance is the responsibility of the company that puts the product on the market. zIn some cases, regulations are inconsistent because each member state adopted separate implementing standards and enforcement procedures. zContains broad definition of electronic and electrical equipment and contains specific exemptions for certain products. zMaximum concentration is 1000 ppm, except Cadmium, which is 100 ppm. zEverything identified as homogenous must meet the requirements.

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May China RoHS zPhase 1 (March 1, 2007): Marking requirements for electronic information products Environment-friendly use period must be indicated inside the pollution control symbol. zPhase 2 (timetable uncertain, likely 2008): Restrictions on Hazardous Substances Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs, PBDEs Indications are that major appliances will be excluded, with exception of microwaves. Replacement parts for appliances will be subject to RoHS if listed on the catalogue.

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Japan RoHS zDesign for Environment (DfE) criteria (promulgated in 2000) Rationalize use of raw materials Use recycable and reusable parts Promote long-term use of products zThe cabinet member with jurisdiction establishes basic policy and requirements for industry zChanges effective July 1, 2006: Manufacturers of computers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must label products to indicate presence of Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs and PBDEs. Importers of computers, copiers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must meet Design for Environment Criteria (DfE).

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Korea RoHS zRequirements include: Restrictions of hazardous substances in electrical/electronic equipment and vehicles Improvement of materials and structure Recycling requirements for manufacturers and importers Mandatory recycling rate Establishment of an Operation and Management Information System zImplementation date: January 1, 2008 However, implementation date does not mean anything until decisions are ordered by Presidential Decree.

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May California RoHS zCurrently under consideration in the California Legislature zConsistent with EU RoHS regulations, with the following exceptions: Applies to products manufactured on or after January 1, 2010 Applies only to mercury, lead, cadmium and hexavalent chromium (PBBs and PBDEs are excluded) Excludes fixed installations Twenty-four month grace period for products that lose their RoHS exemption Exempts products that are refurbished or sold for reuse Specific exemptions for spare parts A process for securing exemptions or time extensions zAnnual reporting to California Integrated Waste Management Board zPassage is likely in 2007.

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Compliance Challenges zObtaining and verifying data on thousands of parts from around the world zVague and varying regulations zNo common reporting because of various states, languages, formats, etc. zConstantly changing parts and components zLack of best practices for mitigating risk

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Various End Manufacturers Strategy for RoHS zNo single universal approach zCan have thousands of components with multiple homogenous materials each zToo many components for one company to feasibly deal with by itself zMost rely on reporting from supplier base Letters of compliance Test data showing compliance In-house testing 3 rd party testing Often requested from Tier 1 suppliers, which trickles down the supply chain zMixed strategies commonly used Components and suppliers are ranked into categories based on degree of risk Level of documentation and testing can increase with each category

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Typical Sampling Strategies for Compliance Testing zNo single universal approach zTest every lot of material Unusual except when lots of material commonly come from unknown production sources (commodity buyers, resellers, etc). zTest once for each part # produced. Retest when any changes in material, source, or process occurs (similar to PPAP) zTest once for each part # used to produce multiple part #s (e.g., cutting a larger coil of steel into various smaller width coils). May apply conformance to all downstream part #s where no RoHS materials are added Retest when any changes in material, source, or process occurs. zTypically, any change that occurs that would prompt sending production samples for engineering approval should prompt a decision as to whether a RoHS compliance retest is needed

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Test Methods zNo single universal approach zMany various test methods, highly dependant on the material, processing method, and type of component z3 rd Party Testing Currently no official accreditation process for 3 rd party labs Some companies have list of labs they use or accept results from zInternal Testing Many large companies use internal screening tests to reduce the amount of expensive 3 rd party tests (~$200-$400/sample) Portable XRF testers have become very popular 30 seconds/test Provides elemental analysis only (cannot tell difference between Cr 6+ and Cr) Not very useful for certain materials ASTM D6492 or ISO 3613 spot tests for detecting presence of chromate conversion coatings

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Conclusion zRoHS regulations are being implemented globally, not just in the EU zDespite having extensive global supply chains, manufacturers have developed and are continuing to enhance compliance procedures.

Every home…Everywhere Every home…Everywhere Every home…Everywhere 23 May Questions or Comments? Contact information: Brandon BokhartLuke Harms Senior Metallurgical EngineerGovernment Relations SpecialistWhirlpool Corporation