RoHS Frequently Asked Questions
1. Legislation
1.1. What is the Restriction of Hazardous Substances (RoHS) Directive?
It is the European Parliament and Council Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (2002/95/EC) ("the RoHS Directive") The hazardous substances affected are lead, hexavalent chromium, mercury, cadmium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).The following are a number of applications in which these hazardous substances are used. It is not an exhaustive list.
- lead: used in virtually all solders, components and many PCBs
- hexavalent chromium: used in dyes, pigments, plating solutions, alloys
- mercury: used in some electrical components, batteries, pigments
- cadmium: used in batteries, plastic stabilizers, platings
- polybrominated biphenyls (PBB): flame retardant in plastics, insulation
- polybrominated diphenyl ethers (PBDE): flame retardant in plastics, insulation
1.2. What is Foundry's position regarding this legislation?
Foundry is committed to compliance with all applicable laws and regulations, including the RoHS Directive. Foundry's goal is meet the restricted substances requirements of the RoHS Directive on a worldwide basis.
1.3. Is your company aware of the EU Legislation that bans certain hazardous substances from electronics by 1 July, 2006?
YES, Foundry is aware of EU legislation (the RoHS Directive) that restricts the presence of 6 specified substances in electronics products put on the market in the EU as of July 1 2006 (the European Parliament and Council Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (2002/95/EC) ("the RoHS Directive")). See Foundry's web site for more information.
1.4. What is your company doing about "RoHS-like" legislation from China and California?
Recognizing that other countries are adopting requirements similar to or mirroring those of the RoHS Directive, Foundry's goal is to meet the restricted substances requirements of the RoHS Directive on a worldwide basis.
1.5. Is there any difference between the EU RoHS Directive, China ROHS, or other requirements worldwide? How will Foundry comply with these different laws?
Yes, we expected that there would be differences between the RoHS-like regulations being developed and implemented in various geographies. Although the restricted substances requirements appear to be converging, it is expected that China and Japan will require unique schedules, labeling, reporting, and certification requirements. Foundry's goal is to meet the most stringent material content requirements on a worldwide basis.
1.6. What is Foundry's understanding of "put on the market"?
Consistent with the view of the European Commission, who have published non-binding guidance (see below), Foundry understands that the phrase "put on the market" or "placed on the market" means the initial action of making a specific product available for the first time on the [European] community market, with a view to distribution or use in the community. This does not refer to the launch of a new product or product line.
1.7. Will my company be legally allowed to buy Foundry non-compliant products outside the EU (either before or after 1 July 2006 date) and resell them in the EU after 30 June 2006?
Foundry cannot provide legal advice to you. In general terms, a Foundry customer planning to purchase Foundry products outside the EU and then put them on the EU market after 1 July 2006 needs to ensure that the products are RoHS compliant. However, you must obtain your own legal advice.
1.8. Will my company be able to resell new non-compliant products in the EU after 1 July 2006 if they were shipped to us in the EU by Foundry before 1 July 2006?
You should seek your own legal advice but we believe YES since the RoHS Directive does not prohibit the sale of non-RoHS compliant product that were "put on the market" in the EU prior to 1 July 2006.
1.9. What if I have purchased equipment prior to 1 July, 2006 and want to transfer that equipment from North America to the EU – does the equipment already purchased before 1 July 2006 fall under this law as well?
Foundry cannot advise customers regarding the transfer of non-RoHS product legally purchased outside the EU prior to 30 June 2006 that is then transferred to the EU after 30 June 2006.
1.10. How long can customers in the European Union keep their existing products – are they required to replace all non-compliant technology already in hand?
Customers can keep their products as long as they wish. Customers will not be required to replace Electrical Electronic Equipment that was already put on the market prior to 1 July 2006 because it contains any of the hazardous substances restricted under the RoHS Directive.
2.1. Foundry's RoHS Program: Policy & Strategy
2.1.1. Have you developed or are you developing a strategy or approach to addressing the concerns discussed above?
Yes, Foundry has a company-wide core team to address the RoHS Directive. The core team includes a representative from each of Foundry's business units and from key corporate wide functional areas.
2.1.2. What kind of considerations is your strategy attempting to address?
Areas that Foundry sees as key to its RoHS strategy are:
- Delivering compliant products and solutions on time to our customers
- Addressing specific customer support requirements
- Maintaining the performance of our products
- Ensuring the quality and reliability of our products
- Ensuring legal compliance
- Ensuring the quality and reliability of our product
- Ensuring Foundry meets its environmental responsibilities
2.1.3. Does your company have phase out programs for material subject to the RoHS Directive?
In general, Foundry will meet the product content requirements of the RoHS Directive on a product by product basis.
2.1.4. If I own a functional Foundry product that is not RoHS compliant can I get it replaced with a compliant unit?
NO, the RoHS Directive does not require the replacement of existing functional, non-compliant units which are already on the EU market with compliant units. The Directive's intent is not to create extra electronic waste by accelerating the disposal of existing products. If you would like to purchase a new RoHS compliant unit contact your Foundry Sale Representative, visit our website at http://www.foundrynet.com/buy/sales/index.html to find your nearest Foundry sales representative.
2.2. FOUNDRY's RoHS Program: Technical
2.2.1. Are you having conversations about the RoHS Directive with your suppliers (including sub tiers)?
Yes, Foundry has been working with our suppliers since 2004 to ensure that Foundry products will comply with the RoHS Directive and to determine if the suppliers will meet Foundry's internal requirements.
2.2.2. Have acceptable alternate materials and/or processes been chosen?
Yes, Foundry has set its specifications for materials and processes required to manufacture RoHS compliant products. We will continue to refine these as a normal part of process improvement.
2.2.3. What has Foundry identified as a hexavalent chromium (Cr-6) alternative?
There are several alternatives to Cr-6, including trivalent chromium chromate coatings for sheet metals. Metallic nickel (Ni) or chromium (Cr-0) platings may be suitable for a small number of applications, such as for use on some fasteners. The exact alternative chosen for any specific component depends on performance requirements, cost, and availability.
2.2.4. Has Foundry identified issues in the transition from non-compliant to compliant components, like non-backward compatibility, that might impact your compliance with the RoHS Directive?
Although there are technology issues associated with backward compatibility for certain components, Foundry has been working to develop solutions and so meet its obligations under the RoHS Directive.
2.2.5. What are the "detailed" uses (e.g. IC lead plating, metal finishes, etc) of restricted substances in your products?
Foundry products will comply with 5 of the 6 requirements of the RoHS Directive for all substances and applications. Foundry products will continue to use lead solder as allowed by the EU Exemption for Telecommunications Devices.
2.2.6. Are you willing to discuss technical questions concerning the reliability of particular RoHS-compliant products?
YES. Ask your sales contact to arrange a technical meeting with Foundry.
2.3. FOUNDRY's RoHS Program: Active Supplier Compliance Verification
2.3.1. Does Foundry have a process in place to ensure compliance of its products?
YES Foundry developed an Active Verification program to ensure compliance of our products with the RoHS Directive. This is particularly important during the current RoHS transition period, when the supply chain will include both unrestricted and restricted materials.
2.3.2. How do you communicate your RoHS compliance requirements?
We communicate materials restrictions to our design teams and suppliers through design guidelines, restrictions, and approval of component bills of material.
2.3.3. What are the key steps in your compliance verification process?
The four key steps in the compliance verification process are:
- Compliance declaration and tracking.
- Foundry communicates compliance requirements to suppliers.
- Suppliers declare that all materials shipped to Foundry are compliant.
- Foundry tracks and documents supplier compliance information.
- Supplier process verification. Foundry verifies supplier compliance management processes and corrects any deficiencies.
- Supplier data validation. Supplier compliance declarations are validated by sampling the supporting data, as needed.
- Analytical testing. Chemical analysis of actual components or materials is performed, as needed, to validate supplier compliance declarations or on a random sampling spot-check basis.
2.3.4. Do you perform analytical testing in your verification process on a standard basis?
NO. This is done both when Foundry determines analytical testing is needed to validate a supplier's compliance declaration and on a random sampling spot-check basis.
2.3.5. How do you deal with non compliance in your supply chain e.g. as a result of a spot check?
Foundry has a Supplier Corrective Action Request process to correct failures to meet specifications, deficiencies in process, or non-compliance with the RoHS Directive.
3.1. Products: RoHS transition
3.1.1. When will Foundry products be ROHS compliant?
Foundry products will comply with the RoHS Directive substance restrictions by July, 2006. Foundry views product transition plans as confidential. Ask your sales contact for particular product compliance information if you are interested in specific timing.
3.1.2. What is Foundry's roadmap or timetable for moving to RoHS compliance?
Product roadmaps for migration of Foundry products have been set and Foundry intends to ensure its products comply with the RoHS Directive as of July, 2006. Foundry views product transition plans as confidential.
3.1.3. Do you have plans for early (between 2006 and 2010) transition to lead-free?
YES. Once a reliable solution for each sub-class of products has been validated, Foundry plans to move forward with that solution as it transitions to the next generation of that product. Foundry will make the transition to lead-free solder when Foundry's reliability requirements are met.
3.1.4. Will Foundry products adhere to current specifications / requirements?
When Foundry releases a new RoHS-compliant product, that product will have its own new set of specifications. For products that will transition "mid-life" to RoHS-compliance, other than as required for compliance with RoHS, Foundry plans to adhere to that product's current specifications.
3.1.5. Will the warranty change for RoHS compliant products?
Foundry has no plans to change its warranty policies for its RoHS compliant products.
3.1.6. If I purchase older, pre-owned (refurbished) product from Foundry after 1 July 2006, will it be RoHS compliant?
It may or may not be RoHS compliant. Refurbished non-RoHS compliant products can be sold within the EU if the product was put on the market in the EU prior to 1 July 2006 and is not being sold as ‘new'.
3.2. Products: Labeling & identifying compliance
3.2.1. Will Foundry product numbers change to reflect RoHS compliance?
Foundry will be applying controls over product inventory to ensure its compliance with the requirements of the RoHS Directive. All Foundry products will have some form of identifier to distinguish RoHS compliant and non-compliant products. Most Foundry RoHS compliant products will not have a new product number. Most Foundry products will have a new internal Foundry part number. For some of our products, we will use the product serial number as the identifier.
3.2.2. Will Foundry label products to reflect RoHS compliance?
Foundry will label its products and its packaging to indicate RoHS compliance status. See question [3.2.1] above on how Foundry will identify compliant products.
3.2.3. Does Foundry plan to use the JEDEC standard labeling for RoHS compliant product?
Currently there is no standard for RoHS compliance labeling. The JEDEC standard labels the type of alloy used on component terminations, PCBs, and solders. It is not intended to identify a product as RoHS compliant.
3.2.4. How will I know if a Foundry product is RoHS compliant?
All Foundry products will have a clear identifier to distinguish RoHS compliant products. In most cases the identifier will be a Foundry "Gear" label indicating the level of RoHS compliance.
3.2.5. Will Foundry sign a "Supplier Compliance Confirmation" letter to verify that the products it is shipping are in compliance with the RoHS Directive?
YES, Foundry will sign a letter for specific products
3.2.6. How do you differentiate between a compliant and non-compliant part with the same functionality?
A new Foundry part number is issued to any RoHS-compliant assembly that differs from a functionally equivalent non-compliant assembly for technical or legal reasons.
3.2.7. Are you able to supply detailed breakdown of materials content for the product? E.g. Which components, ppm, percentage etc?
No.
3.3. Products: Exemptions
3.3.1. The EU has granted an exemption for the application of lead in solder for servers, storage array systems, and network infrastructure equipment. Does Foundry's use of this exemption mean that reliability issues related to lead-free solder have been identified?
Foundry supports the industry request for a Pb in solder exemption for servers, storage and network infrastructure equipment because our research shows that their unique design characteristics makes manufacturing reliable lead-free assemblies a much more complex process and at the same time these products have very high reliability requirements. Foundry has done extensive testing of the new technologies and processes. It takes time to prove the reliability of new Pb-free solder solutions. Any company transitioning to Pb-free soldering technology is dealing with the same technical challenges. As always, Foundry is committed to meeting and exceeding our customers' expectations for product reliability. Once a reliable solution for this class of products has been validated, Foundry plans to move forward with that solution.
3.3.2. For those products to which the lead (Pb) in solder material application exemption currently applies, does Foundry have a uniform policy about the transition to Pb-free?
YES. Once a reliable solution for each sub-class of products has been validated, Foundry will move forward with that solution as it transitions to the next generation of that product includes Deca-BDE, has been restricted from use in Foundry's products since 1996.
4. Service & Support
4.1. Are Service Spares exempted from complying with the RoHS Directive?
The RoHS Directive does not apply to "spare parts for the repair" or to the reuse, of electrical and electronic equipment put on the market before 1 July 2006."
4.2. How will Foundry control the repair of RoHS compliant products?
Each unique product number has its specific Recommended Spares Listing (RSL). RoHS compliant products will list only compliant service-spares and material. For non-compliant products put on the market before 1 July 2006, its RSL may continue to list non-compliant Service spares and backward compatible compliant spares authorized by Engineering and Services for that product.
4.3. Will Foundry provide non-compliant spare parts?
YES, as permitted by the RoHS Directive Foundry will provide these spares for use in the repair of Electrical Electronic Equipment put on the market in the EU before 1 July 2006 only.
4.4. Can a non-RoHS compliant spare part be used in a RoHS compliant system put on the market in the EU after 1 July 2006?
No, the RoHS Directive permits the use of non-compliant spare parts for the repair of electrical and electronic equipment put on the market before 1 July 2006.
4.5. Can a RoHS compliant spare part be used in a non-RoHS compliant system?
Yes, If Engineering and Services have determined the RoHS compliant assembly or Service spare is compatible in the non-compliant product or system.
5. OEM Customer Specific
5.1. Why should I be concerned about the RoHS legislation?
If you are a customer who ships product into the EU or you have offices that are based in the EU, then you need to be aware of the RoHS Directive and determine if you will be affected by this legislation. You should seek your own legal advice on how the RoHS Directive affects your operations.
5.2. When will products (servers, storage array systems, network infrastructure equipment) be available for system integration testing?
Servers, storage array systems, network infrastructure equipment availability will be dependent on their standard roadmap transition and should follow a "normal" testing process. The use of lead (Pb) in solders for these types of products is exempt from the RoHS Directive. Many of Foundry's products fall under this exemption and will not undergo any substantial change as they transition to RoHS compliance. Therefore, from a software standpoint, no changes will be apparent and existing products can be used for system integration testing. Ask your sales contact for particular product availability.
6. Channel Partner Specific
6.1. I am concerned about selling non-RoHS-compliant product after 1 July 2006. Does Foundry allow channel returns?
NO. The RoHS Directive does not prohibit the sale of non-RoHS compliant product that were "put on the market" in the EU prior to 1 July 2006. See FAQ 6.2 for Foundry's Policy.
6.2. What is Foundry's policy regarding Channel Returns of products that are NOT RoHS compliant?
Foundry will NOT accept product returns from customers or partners where the product:
- meets existing compliance requirement in effect before 1 July 2006, AND
- was "put on the market" in the EU prior to July 1, 2006, as Foundry believes that these products can be sold
7. WEEE questions
7.1. Does your company have plans or programs in place to meet the requirements of the WEEE Directive?
YES, Foundry is actively working with others in our industry and competent authorities in the European Union to prepare for the implementation of the WEEE Directive. For information, please see Computer Hardware Recycling.
7.2. Are Foundry products WEEE labeled?
All Foundry products that are subject to the WEEE Directive from 13 August 2005 are compliant with the WEEE Directive marking requirements. Such products will be marked with the "crossed out wheelie bin" WEEE symbol in accordance with European Standard EN 50419. The majority of Foundry's products shipped outside of the European Union are labeled according to WEEE Directive. Customers who are based outside of the European Union and would like to ship Foundry products with their own products into the European Union and are concerned about WEEE labeling should contact their account representative.
7.3. Can you provide end-of-life data (e.g. Annex II substances)?
As required by the WEEE Directive, Foundry will provide reuse and treatment information addressing Annex II for each type of new EEE put on the market within one year after the equipment is put on the market. Foundry will make required information available to reuse centers by the date specified in member state legislation, typically within one year after the new products have been put on the market or sold after 13th August 2005.