|RoHS||WEEE||REACH||Conflict Materials Policy||Counterfeit Components Policy|
Acromag Inc. is a company that is very sensitive to the environment. We strive everyday to improve our world and leave it better for future generations. We are interested in the initiatives lead by the European Union (EU) and plan to be an active participant in supporting their programs.
The European Union RoHS2 directive restricts the use of specific hazardous or restricted substances in new electrical and electronic equipment put on the market in the European Union after July 1, 2006. On July 1, 2011, the European Union Published the RoHS2 (Recast Directive)
The restricted substances are:
1. Lead (0.1%)
2. Mercury (0.1%)
3. Cadmium (0.01%)
4. Hexavalent chromium (0.1%)
5. Polybrominated biphenyls (0.1%)
6. Polybrominated diphenyl ethers (PBDE) (0.1%)
The RoHS2 directive uses the product categorization scheme from the WEEE directive which aims to define standards for recycling electronic equipment and defines 10 product categories. Of those 10 categories of electrical and electronic equipment (EEE), the RoHS2 directive applies to eight categories but delays the inclusion of products in category 9, “Monitoring and Control Instruments” which includes the category “Industrial Monitoring and Control Instruments,” under which all Acromag products fall.
Key Implementation dates Required by the EU.
Monitoring and Control Instruments July 22, 2014
Industrial Monitoring and Control Instruments July 22, 2017
Acromag is committed to releasing environmentally friendly products as part of the Acromag Hazardous Substance Reduction initiative. This initiative is a voluntary program modeled after the European Union Restriction of the Use of Certain Hazardous Substances (RoHS2) directive.
The RoHS2 directive applies to eight categories of electrical and electronic equipment but excludes products in Category 9, Industrial Monitoring and Control Instruments, under which Acromag products fall. Although it is possible to use Acromag equipment in other applications, the principle usage, as well as the intended usage, is for “Industrial Monitoring and Control.”
Even with this delayed inclusion, Acromag is voluntarily moving on a time-line toward Full RoHS2 compliance. The target is to be fully RoHS2 compliant before the expiration of the exemption.
1. Components: Every component Acromag uses is fully evaluated and classified for RoHS2 compliance. Acromag gets RoHS2 data from the actual manufactures that produce the components. Nearly all components used are fully RoHS2 compliant. (Where possible, only RoHS2 components are used.).
2. Soldering: Today, Leaded solder is standard for all products except a few that may be ordered as “Lead-Free.” Acromag has on-going testing of Lead-Free solder materials. Once a proven history of reliability exists and our customers agree with this assessment, Acromag is prepared to move toward full “Lead-Free” solder processes.
3. Testing: Acromag has produced a select few products soldered Lead-Free to determine the reliability.
By moving toward full compliance with the directive, Acromag demonstrates a commitment to the environment, its employees, and its customers, who can use ACROMAG components to design and develop their own environmentally friendly products.
Acromag has customers that voluntarily are moving toward RoHS2 compliance with their systems. They do this even though they have a full exemption. Acromag is fully compliant with all of the materials except for Lead used in solder. Some products may be ordered Lead Free upon special request.
Other customers needing the highest long-term proven reliability request only products with leaded solder.
"Waste of Electrical and Electronic Equipment" (WEEE) is an initiative to control the disposal of electronic equipment sold in the European Union.
All Acromag equipment shipped to the EU member states since the date of the directive is marked with the Wheeled Bin mark.
Acromag has a new no-charge “take-back” service that gives customers the option to return used Acromag hardware products to be recycled. Products covered by the WEEE directive shipped to EU member states may be returned to Acromag at no charge. Acromag ensures that the products are properly recycled. This service helps reduce the impact on landfills and other disposal sites and provides an environmentally safe end-of-life solution.
To send hardware products to be recycled, customers can contact Acromag to obtain an RMA number and Acromag staff will reply with information on how to ship the product. There is no charge for the disposal but the customer must pay for shipping. After the product is returned, Acromag also can provide a Certificate of Custody change upon customer request.
Product “take-back” regulations are constantly evolving. Current regulations do not require Acromag to take back its products. However, by launching a WEEE take-back program, Acromag demonstrates a commitment to the environment and its customers by helping them dispose of Acromag products responsibly.
The Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) is a European Community Regulation related to the safe use and identification of chemicals (Regulation (EC) Number 1907/2006). REACH entered into force on June 1, 2007 with the aim of improving the protection of human health and the environment through better and earlier identification of the intrinsic properties of chemical substances. REACH was aimed at streamlining and improving former European Union chemical legislation by replacing approximately 40 individual pieces of legislation and harmonizing with the remaining legislation. The new legislative framework under REACH shifts responsibility for the control and safety of chemicals from government authorities to industry and created the European Chemicals Agency to act as a central coordinator.
Acromag is an importer of articles as defined in the Regulation. However, registration requirements under Article 7 of REACH do not currently apply to articles imported by Acromag into the European Union because:
Substances are not present in the articles in quantities totaling over one ton per year
Substances are not intended to be released under normal or reasonably foreseeable conditions of use.
Acromag is not categorized as a downstream user under REACH because it does not use the substances in the course of its professional activities and therefore has no applicable requirements under Article 37 of REACH. Acromag will continue to monitor REACH developments and will comply with any applicable requirements.
As Substances of Very High Concern (SVHCs) are added to Annex XIV of the Regulation (Authorization List), Acromag will assess whether both of the following conditions are met:
The substance is present in the articles in quantities over one (1) ton per year
The substances are present in Acromag devices above a concentration level of 0.1% w/w
Acromag shall comply with the requirements of Article 7(2) and Article 33 of the Regulation, as necessary. For informational purposes, Acromag has contacted its material and manufacturing vendors to verify that Acromag devices do not contain SVHCs. (Note that several vendors have not established a REACH compliance statement yet. Acromag is surveying vendors to determine their status and will continue to do so.)
Conflict Materials Policy
Acromag Conflict Material Policy
There has been increased awareness of violence and human rights violations in the mining of certain minerals from a location described as the “Conflict Region”, which is situated in the eastern portion of the Democratic Republic of the Congo (DRC) and surrounding countries. Companies around the globe have been requested to practice reasonable due diligence with their supply chain to assure that specified metals are not being sourced from mines in the Conflict Region, which is controlled by non-government military groups, or unlawful military factions.
Acromag supports this initiative and has either obtained, or is in the process of obtaining, information from our current metal suppliers concerning the origin of the metals that are used in the manufacture of Acromag products. Based upon information provided by our suppliers, Acromag does not knowingly use metals derived from the Conflict Region in our products.
Suppliers of metals used in the manufacture of Acromag products (specifically gold, tin, tantalum, and tungsten) must demonstrate that they understand the conflict minerals laws and will not knowingly procure specified metals that originate from the Conflict Region.
All Acromag suppliers of any fabricated materials such as Printed Circuit Boards, Metalwork, and Transformers have been surveyed and reported to not be sourcing materials from these regions.
Supplier Guidelines: Suppliers must review and agree in writing to the following conflict minerals contractual language:
• Supplier represents and warrants that it is in full compliance with conflict minerals laws, including, without limitation, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 as it may be amended from time to time and any regulations, rules, decisions or orders relating thereto adopted by the Securities and Exchange Commission or successor governmental agency responsible for adopting regulations relating thereto (collectively, (“Dodd-Frank Section 1502”).
• Supplier must cooperate with Acromag to make available to Acromag and/or its agents, full material declarations that identify the sources of and amount of all substances contained in the Products. Unless Acromag specifically agrees in writing that a particular Product may contain a particular material, Supplier will also provide a statement that the Products do not contain various materials at issue in applicable laws and regulations.
• Supplier must declare each Product’s compliance to all applicable hazardous material legislation and identify any substances that are banned or must be declared under applicable laws. In addition, Supplier will make available any documentation that supports the declaration. Without limiting the generality of the foregoing, Supplier agrees to disclose to Acromag, upon Acromag’s request, to the extent known or discoverable by Supplier following inquiry, the original source of all minerals contained in the Product.
• If Supplier does not know the original source of the minerals, Supplier agrees to cooperate with Acromag, including disclosing from whom Supplier purchased the minerals and urging others to disclose such information, so that the original source of minerals can be accurately determined and reported. Supplier shall comply with all laws regarding the sourcing of minerals, including, without limitation, laws prohibiting the sourcing of minerals from mines controlled by combatants and Dodd-Frank Section 1502.
• Without any further consideration, Supplier shall provide such further cooperation as Acromag may reasonably require in order to meet any obligations it may have under conflict minerals laws, including, without limitation, under Dodd-Frank Section 1502.
As a leading global company in the development of instrumentation, Acromag is committed to ensuring the safety, health and protection of people and the environment worldwide. We promote these principles in our global business practices and our code of conduct.
Acromag Counterfeit Component Control Policy
Acromag Incorporated understands the worldwide concerns of counterfeit components entering the electronic supply chain. In an effort to alleviate counterfeit components only suppliers following these requirements shall provide Acromag Inc. with components:
Original component/equipment manufacturers
In addition, Acromag shall only use independent distributors that comply with one of the following requirements:
An authorized distributor that purchases components from original component/equipment manufacturers with traceability to the component source or,
Distributors who maintain a third party quality management system and are a member of one or more of the following trade organizations and have implemented one of the control programs:
AFDEC-Association of Franchised Distribution of Electronic Components
CEDA-China Electronics Distributor Alliance
COG-Components Obsolescence Group
ECIA-Electronic Component Industry Associates
ECSN-Electronic Component Supply Network
ERAI-Electronic Resellers Association International
GIDEP-Government Industry Data Exchange Program
IDEA-Independent Distributors of Electronics Association
SIA-Semiconductor Industries Associates
TECS-Chinese Reliability Electronic Components Supplier
IDEA-STD-1010-acceptability of electronic components distributed in the open market
CCAP-101-counterfeit component avoidance program
AS5553-counterfeit electronic parts: avoidance, detection, mitigation, & disposition