Welcome to the March 2018 Design Chain Associates E-mail Newsletter!
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Sixteen years ago I wrote and published the first major DCA opinion piece to kick off electronics industry procurement magazine EBN's "Thought Leadership Series". The article, entitled Aligning the Design and Supply Chains, described best practices for managing suppliers, product development and components/materials. By following the described approach, manufacturers will minimize the number of "surprises" they might otherwise experience during development and production, as well as save time and reduce product cost.
I have received many comments and kudos over the years from, mainly, component engineers who use this as a roadmap to improve performance of their companies. And the manufacturers we've implemented this approach at no longer have the types of problems the article describes.
Interestingly, it doesn't mention environmental regulatory requirements - it was written pre-RoHS! But the framework defined is the right one to ensure most environmental regulatory and market requirements are also properly managed and handled. As those can usually be reduced to component or material parameters, they simply must be identified and defined as information required to be obtained at the right stage of the supplier and/or component approval process, and used to define the "safe design space" for product development.
Read the article here and let me know your thoughts.
On March 15, to no fanfare whatsoever, the Ministry of Industry and Information Technology released the first "Compliance Management Catalog" of EEPs that will be subject to restrictions. In addition a list of exemptions that are allowed is included. Little has changed from the previous drafts, but we learned that the implementation date will be a year from the announcement date, 15 March 2019. Products include:
The page includes a file with this list (and more details) as well as a file with a list of allowable exemptions.
Surprisingly, the conformity assessment system required by Article 18 of the China RoHS regulation has not been released for public review yet. Given that there is less than a year provided to comply, we expect it to be solely administrative (for products already EU RoHS compliant, anyway). Any requirement for 3rd party certification or approval will result in bottlenecks and delays. This, in turn, could produce extreme resistance, similar to what they received back in 2009 when MII tried to enforce a 100% testing regimen on electronics manufacturers. So far we haven't seen evidence of good institutional memory at MIIT, so my expectations are not positive at the moment.
Visit our China RoHS Documents Page for links to all the documents and information you need for China RoHS.
Over the past couple months DG Environment at the European Commission has released three sets of Draft Delegated Directives, intended to update specific exemptions in Annex III of the RoHS Directive (2011/65/EU), per their decisions to renew them. Some remain the same; others are narrower in scope or split into several distinct exemptions. We've summarized them in a single convenient document you can review. Each existing exemption includes a link to the draft page; more recent drafts are still open for comment.
And as mentioned in last month's DCA Newsletter, the process for restriction of 7 additional substances, many of which are in very common use (diantimony trioxide, TBBPA, indium phosphide, MCCPs, beryllium and its compounds, nickel sulphate and nickel sulfamate, cobalt dichloride and cobalt sulphate) under EU RoHS has begun with a meeting of the RoHS Expert Group on Tuesday, March 27. Several stakeholder comment periods appear to be scheduled various topics this year and next, and the electronics industry is circling the wagons (or herding cats, depending on your perspective and favorite metaphor) in preparation.
To learn more about this process, how it could affect you and your products, or how to participate, contact us.
March 13, 2018 ChemicalWatch Manufacturing CEOs: closing the product safety gap. What can happen when manufacturers fail to incorporate chemical human health and environmental impact into their safety-related engineering function. [behind the Chemical Watch paywall]
May 14-16, 2018: San Jose, CA. 2018 IEEE Symposium on Product Safety Engineering. Mike will discuss the relationship between Product Safety Engineering and Product Environmental/Human Health Safety and Compliance.
June 18-20, 2018: Portland, OR. ACS Green Chemistry & Engineering Conference. Mike co-chairs a session on the semiconductor and electronics industries. Find out what is "forward-thinking" in the electronics industry and be a part of the discussion. This will be an extremely interesting session - make plans to come to Portland now!!
More to come! Stay tuned.
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