1. Environmental Initiatives Worldwide
What they are and how they impact you

2. Training Topics The Concern The Focus The Legislation
The Primary Substances
The Products Covered
Legal Requirements vs. Customer Requirements
Brooks Current Status
Next Steps and the Roadmap to Compliance

3. The Concern - What is driving environmental change?
The number of disposable electrical and electronic equipment (EEE) is increasing very rapidly
Cell phones, PDAs, laptops, desk tops, printers, other office and mobility products
Toasters, coffee makers, sandwich machines, household appliances, televisions
End of life usually means the trash can and then the land fill
There is not enough voluntary recycling
Toxic waste material is getting into the waste stream and into natural resources – land, water, air

4. The Focus – What products are affected?
Consumer products
Products that are replaced often
Products that are disposed of easily
Office products
Office machines that are replaced due to obsolescence
Machines that are no longer needed
Industrial products
Production equipment, tools
Anything from hand tools to very large machines
Virtually any electrical or electronic
product is covered by this legislation

5. Worldwide Requirements are similar more than they differ.
The Law
All legislation is similar but there are key differences
Some are aimed at consumer products only
Some allow exemptions based on equipment type
Some allow exemptions based on equipment function
Some do not allow any exemptions
Worldwide Requirements are similar more than they differ.

6. The Primary RoHS Substances
The focus is on Heavy Metals
There are 6 basic substances:
Lead
Mercury
Cadmium
Hexavalent Chromium
PBB (used in plastics as a flame retardant)
PBDE (used in plastics as a flame retardant)
These are known health hazards

7. The Primary RoHS Substances
There is a Maximum Concentration Value (MCV) for each of the substances
MCV for all is .1%, except for Cadmium which is .01%
MCV is based on the lowest homogeneous part of the product
Homogenous level has a uniform composition and no further separation by mechanical action (such as unscrewing, cutting, brushing or grinding) can be accomplished. Chemical separation is not allowed
These limits are the same for all current requirements

8. Basic requirement is that the product use electricity
Products Covered
Varies by legislation
EU RoHS has 10 categories of electrical and electronic products based on EU WEEE Directive
EU RoHS currently exempts:
Large Scale industrial Tools (as part of Category 6 products they are exempt from WEEE and therefore also RoHS)
Medical Products – Category 8
Control & Laboratory Products – Category 9
China has a list of EIP – Electronic Information Products – that covers most of the known electrical and electrical products today
This is for Phase 1; different list will be used for Phase 2
All others are a subset of one of the above
Basic requirement is that the product use electricity

9. RoHS Comparison Chart EU CHINA JAPAN KOREA USA STATES OTHERS
Implementation Date
Currently in Effect
Phase 1 in effect
January 1, 2008
CA – in effect
Work is in progress in Australia, Canada, New Zealand and 26 US cities and States.
US will most likely follow California.
Australia will probably follow EU RoHS.
Canada is monitoring the US and EU
Legally required action at this time
LSIT – none
Cat 9 – none
Cat 6 (other than LSIT) – currently in effect
Disclosure by EPUP label and information table
No Legal Requirement at this time
Disclosure and prohibited use per Tables
None
(will be same as EU ? ? ?)
Disclosure, prohibited use and mandatory recycling
Products Covered
1 - Large household appliances
2 - Small household appliances
3 - IT and telecommunications equipment
4 - Consumer equipment
5 - Lighting equipment
6 - Electrical and electronic tools (with the exception of LSIT)
7 - Toys, leisure and sports equipment
8 – Medical Products
9 - Monitoring and control instruments
10 – Automatic Dispensers
As Listed in the EIP
(if it uses electricity assume it is covered)
Japan RoHS Consumer Products
Japan’s Green Initiatives covers all products and uses JIG-101 as the restrictive document; covers any B2B product as requested by the customer; also requires ISO Certification
Same as EU (???)
Electrical & Electronic Products including components
Vehicles including components
May only include high volume waste products – yet to be determined
California
CRT, LCD, Plasma Displays ≥ 4” diagonal display
“Not covered if they are part of industrial, commercial or medical equipment”

10. RoHS Comparison Chart EU CHINA JAPAN KOREA USA OTHERS Substances
Covered
Lead
Cadmium
Mercury
Chromium VI
PBB
PBDE
Same As EU
Same as EU plus:
JIG = JIG A + JIG B
JIG A = ( EU + 8)
JIG B = (+9)
Pending
Future
legislation
Maximum
Allowable
Level
Cadmium ≤ 0.01%
All others at ≤ 0.1%
Same as EU for
RoHS + JIG 101
values
Same As
Exemptions
Allowed
Based on application
to and approval by EU;
exemptions allowed for
substances necessary
for product function
(lead in X-rays,
mercury wetted relays,
etc.
None
If elimination of
hazardous
substance is
extremely
difficult due to
Special
Characteristic
Of products
concerned or
there is no
substitute, and
for R&D and
products for
Export
allowed
by the EU;
Also if
Substance
use is
required to
Meet
safety
standards

11. RoHS Comparison Chart EU CHINA JAPAN KOREA US Compliance Drivers
Legally required for
covered products
Competitive Position
Legally
Required
Customers who
have adopted a
“Green Procurement” program
ISO14001
Will be
legally
required
for covered
products
Competitive
Position
required for
Covered
Products
Comments and
Notes
Cat 8 and Cat 9 will
probably be included in
RoHS by
LSIT may be the topic
of a future EU
consultation report
(~2012)
Phase 2 will
require
restriction on
substance use
but in a smaller
product listing
Catalog will be
created for
product list
Customer Driven as noted above
Support
Legislation
not yet
released
Does not
affect
Business to
business

12. Environmental Timeline
anticipated date

13. Status What Brooks is currently doing
and what we will be doing next to bring our
products into compliance with legal
requirements and customer expectations

14. How are we doing this?
The Green Initiatives Steering Committee was formed to:
Analyze and document the external threats and opportunities emerging from environmental regulations
Develop and champion strategies necessary to sustain business in light of these emerging issues.
Create internal programs intended to meet or exceed our customer’s expectations for environmental compliance
Use the opportunities resulting from these initiatives to distinguish Brooks as an environmentally friendly company.
Working Groups:
This committee established Working Groups to address specific environmental topics such as China RoHS.
There are representatives from each Division on the Steering Committee and Working Groups.
These Divisional representatives then work within their Working Groups to develop and implement plans, with review and approval by the EHS Steering Committee and Senior Management.

15. How are we doing this? Green Initiatives Working Groups:
RoHS Marketing WG for all Divisions (TBD)
They will determine product status and roadmap, per the earlier slides
The Material Content WG through Global Sourcing interfaces with our suppliers to get the information we need in the form we need it.
Materials Declaration WG to work with IT to determine the tools needed to get the information from our suppliers into your ERPs
WEEE Registration WG is responsible for evaluating and implementing registration for certain products in EU member states.
ISO WG is responsible for planning and execution of ISO certification.

16. Brooks Automation Environmental Policy
Development of a Environmental Policy Statement:
“Brooks Automation recognizes that the protection of the earth's environment is one of the most important issues for all mankind.
We are committed to protecting the environment for our Customers, Partners, Employees, Friends and Neighbors in the workplace and the community.
We are committed to complying with environmental laws and regulations that affect our products worldwide.”

17. Current Compliance Status by Region – European Union
RoHS – Position papers has been issued for TAD, GCS and VPD Products.
Most products are out of scope as “Large Scale Industrial Tools”
Continue to monitor EU activity for any changes in current legal requirements.
WEEE – Working Group has been formed to complete the Registration for some VPD products (GP & CTI) in selected EU states.
GP products contain the EU WEEE symbol, indicated “not to be disposed of as trash”

18. Current Compliance Status by Region - China
Phase 1
Brooks products shipping directly to China are compliant with Phase 1 requirements: EPUP label, MCV Table and Spares Identification.
We continue to monitor status in China for problems or scope change
We will do a review in July to see if we need to change anything in our current process
Working with various industry groups (SEMI Asia RoHS WG, ASTM F40 (Materials Declaration and Testing)
Position Paper Issued (
Phase 2
Monitor progress in China

19. Current Compliance Status by Region - China
EPUP label: All EIP products to be used in China require a label indicating the ”Environmentally Protected Use Period”. This is a period in years during which the product will not degrade, causing pollution.
For products containing no RoHS materials above the Maximum Concentration Values (MCV):
For products containing one or more RoHS materials above the MCV:
These labels are applied on the product and on the packaging.
Draft Guidance Document is out for review

20. Current Compliance Status by Region - China
The Divisions make their own business based decisions for product labeling:
They can label all products they ship, or
If they know which ones go to China then can only label those
If a Brooks product is being shipped to a customer not in China it may not be labeled (depends on above decision)
If the customer then ships it to China it is now a component of their system
They have to label their end product
We will provide content information to them upon request.

21. Current Compliance Status by Region - China
Spare parts, replacement parts, or parts for upgrade are out of scope of China RoHS based on the MII’s China RoHS FAQ
Stamps or labels may be added to the shipping documentation to indicate that the shipment contains Spares, Replacements or Upgrade parts:
这些是零配件,维修用零件,更换用零件
THESE ARE SPARE PARTS, REPAIR
PARTS OR REPLACEMENT PARTS
这些零件用于设备升级
THESE PARTS ARE TO UPGRADE
AN EXISTING INSTALLATION

22. Current Compliance Status by Region - China
A table (in Mandarin) is added to the User Documentation.
Brooks declares presence of all 6 RoHS substances, unless we have sufficient evidence that these substances are not present.
The table includes the top level product and one level below.

23. Current Compliance Status by Region - Japan
We remain “legally” out of scope with current Japanese legislation
Customer driven Green Initiatives programs are requesting:
RoHS/JIG-101 product compliance or roadmap
A plan to achieve ISO certification
Demonstration of corporate social responsibility.

24. Current Compliance Status by Region - Korea
Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles Legislation released in early April, 2007
Translation available at *
Supporting legislation has not been released yet
Korea RoHS begins on January 1, 2008
Scope covers:
Electrical and Electronic Equipment - equipment or device (including components and parts thereto) operated by electric currents or electromagnetic fields.
Vehicle - means an vehicle (including components and parts thereto) as provided in Article 2, Section 1 of the Automobile Management Act.
*Courtesy of Eco-Frontier

25. Current Compliance Status by Region - Korea
Definitions:
Electrical and Electronic Equipment - equipment or device (including components and parts thereto) operated by electric currents or electromagnetic fields.
Vehicle - means an vehicle (including components and parts thereto)

26. Current Compliance Status by Region - Korea
Article 9 (Restriction on the Use of Hazardous Substances and Concentration Limits)
Among electrical and electronic equipment or vehicles which generates high volume of waste after use, any person who manufactures or imports electrical and electronic equipment prescribed by the Presidential Decree (hereinafter, producers or importers of electrical and electronic equipment) and who manufactures or imports vehicles prescribed by the Presidential Decree (hereinafter, manufacturers or importers of vehicles) shall comply with the concentration limits of such hazardous substances as heavy metals and flame retardants, which are stipulated by the Presidential Decree and have high potential of environmental pollution, so as to promote recycling of electrical and electronic equipment and vehicles. Provided that this shall not be applicable in cases that the elimination of hazardous substance is extremely difficult due to special characteristic of products concerned or there is no substitute, as prescribed by the Presidential Decree, and in cases of research and development or export of products.

27. Current Compliance Status by Region – United States
State legislation is aimed at the consumer market, not at business to business – for now
Primary focus is on lead and mercury
Some states limit use of certain substances, but most US State legislation is concerned with recycling
One information source for US State legislation is the Northwest Product Stewardship Council (

28. US Legislation by State – Enacted and/or Pending
California
Connecticut
Hawaii
Illinois
Iowa
Louisiana
Maine
Maryland
Massachusetts
Minnesota
Nebraska
New Hampshire
New Jersey
New York State
New York City
North Carolina
Pennsylvania
South Carolina
Rhode Island
Utah
Vermont
Washington

29. Next Steps Let’s talk about what needs to be done
to achieve legal compliance
and customer satisfaction

30. Legacy Products
Marketing must determine the future status of legacy products
Will or are they being sold in Japan, China, etc.?
Will they be become EOL in a reasonable time?
Is there a product to replace them?
Question to ask before determining material content
For specific products or for specific customers?
Do you charge a NRE?
Need to provide the customer with a plan and milestones
We will or will not get the information for the specific product
Do you only report it or do you bring the product into compliance?
Who will pay for it?

31. New Product Development
RoHS compliance must be in the product specification for all new products
Redesigned products should fall into this category as well
Do you include JIG-101 information as part of the requirements?

32. What do you need to know and when do you need to know it?
Material Content & Declarations
For JIG-101, China Phase 2, possibly EU RoHS, and other pending legislation you will need to determine the material content in your products
Expect to get only one chance with your suppliers
You need to determine what information you need and what format you want it in. i.e
Only RoHS substances?
Should you include JIG-101 Table A and Table B?
Some other combination?
IPC format or other
Time line for this information

33. Everyone has a role
Operations need to evaluate RoHS compliant tools (solder, coatings, etc.) and processes
Sourcing will be asked to find RoHS compliant alternate components
Engineering will evaluate the alternate components and test the form, fit, function
Quality will assure the reliability, safety, and product performance are maintained and verify processes.
Documentation Control needs to decide how to identify compliant components.
Marketing, when confronted with the cost of bringing legacy products into compliance, has to consider end of life vs. redesign options.

34. It will take planning and a few years to get it all done.
And then…
If you do your homework and implement correctly you will be ready for new environmental legislation.
It will take planning and a few years to get it all done.
Create, Implement and Maintain processes and prepare for the next environmental opportunities.

35. Summary RoHS is NOT going away
RoHS will impact all more and more products
We all have a role in obtaining and maintaining
RoHS Compliance.

36. Thanks for your attention.
And now it’s your turn
Questions?
Thanks for your attention.