News Release from: MDSMap - Tetra Tech Industrial Division
Edited by the Electronicstalk Editorial Team on 3 November 2004
Directives provide challenges for EMSs
The RoHS and Weee directives present interesting challenges for electronic manufacturing service providers (EMSs), also known as contract electronic manufacturers or assemblers.
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The RoHS and WEEE directives present interesting challenges for electronic manufacturing service providers (EMSs), also known as contract electronic manufacturers or assemblers. The Directives place clear responsibility for end-of-life collection, dissemination of reuse and treatment information, recycling objectives, toxics elimination, etc, on equipment producers. Because many electronic and electrical original equipment manufacturers (OEMs) contract to EMSs, compliance relies heavily on a partnership between manufacturer and supplier.
The first step toward compliance is the collection of data from the supply base regarding the material and chemical content of the component parts of products placed on the European market.
OEMs will likely look to their EMSs to be fully responsible for this element.
EMSs will have to develop communications and reporting processes through their supply chains and aggregate data for OEM consumption, along with implementing sufficient controls to ensure data quality and completeness.
The EMSs will likely be responsible to ensure the marking requirements of the Weee Directive are met.
EMSs supporting these processes with robust systems, audit procedures, and certifications will develop a distinct competitive advantage over those that do not.
As time progresses, it is likely that some EMSs will find themselves excluded from contracts due to their inability to provide the necessary assurance of compliance.
In order to satisfy the unavoidable producer responsibility and material content requirements that EMSs will soon find placed on them by the OEMs, EMSs need to implement a robust compliance plan.
While the plan specifics vary based on the product type being manufactured and the markets in which the products are sold, a basic EMS compliance plan would have the following elements; personnel, supplier (and supply chain) management, collection, aggregation, and manipulation of material and chemical content data, compliance assurance program, customer reporting program personnel internal personnel structure must be established such that an individual, or more likely a team, is properly educated on the issues, granted sufficient authority, and given sufficient time to fulfill their duties.
Supplier (and Supply Chain) Management EMSs will have to identify responsible individuals for compliance within each supplier company and maintain accurate contact details.
Lines of communication should be opened with both management and technical staff.
Relationships may also change because these environmental product requirements will impose additional responsibilities on the supply chain.
Contractual agreements between the parties may have to be modified as expectations and liabilities change.
Notably, suppliers will be expected to eliminate certain restricted substances from their products (Cd, Pb, Hg, Cr(VI) and Brominated Flame Retardants).
Non-performing suppliers will have to be eliminated.
Collection, aggregation, and manipulation of material and chemical content data to assure compliance, material and chemical data will have to be gathered from the supply chain as well as for any in-house parts.
Reporting guidance and a reporting mechanism will have to be established.
Some internal means of aggregating and manipulating data must be built along with suitable quality control measures to review and process received data.
Compliance Assurance Program EMSs should implement a program to manage identified non-compliance issues and work with the supplier in a non-punitive fashion to identify suitable alternatives.
Customer Reporting Program EMSs will be hit with numerous requests to provide information on the chemical makeup of the products they manufacture or certifications that their products are complaint.
A reporting process that considers legal issues, confidential concerns, and data audit/control should be established.
The more refined and proactive this process, the more favourably it will be viewed by customers.
In short, EMSs need to be aware that a large portion of the responsibility for RoHS/Wee compliance will fall on their shoulders.
While it is the OEMs on the frontline of responsibility for compliance with the RoHS and Weee Directives, without the support of the EMSs, assurance of compliant products will be impossible.
OEMs may quickly view an EMS without a compliance program as a liability they can not afford
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