Environmental Policy
- Introduction
- Efficient Environmental Management
- Continuous Improvement
- RoHS and WEEE Compliance
- RoHS Compliance Statement - A25
- RoHS Compliance Statement - I25
- Frequently Asked Questions
- For More information
Introduction
Adtron is committed to protecting the environment from the significant internal and external impacts of its operations and will achieve this by continuous improvement and the application of environmental management disciplines and Best Practice. Adtron's success will be measured by the level of satisfaction it achieves among all stakeholders, including employees, customers, shareholders, suppliers, local, national, and international communities.
Efficient Environmental Management
Adtron's manufacturing facility employs an efficient environmental management system that is subjected to continuous improvement measures. For all activities, we focus on the prevention of harmful impact to the environment by properly planning in advance. We use raw materials and energy sparingly while minimizing and recycling waste.
Adtron maintains open communication with our customers and associated market segment, along with region-specific regulations on environmental compliance.
Continuous Improvement
In support of our Environmental Policy, Adtron continually seeks out and investigates alternative methods of performing our services. When more environmentally sound methods are identified, we will move promptly, when economic circumstances allow, to adopt these practices. In recognition of our varied activities worldwide, our Environmental Policy provides general guidance. More detailed national, regional and local policies tailored to the specific needs of those communities and ecosystems will be established as are identified.
RoHS and WEEE Compliance
Specific compliance with existing or anticipated regulations is described below.
European Union
The European Union has established Directives for compliance with product waste management with mandated compliance dates. Adtron has committed cross-functional resources necessary for ensuring compliance with appropriate regulations and specified enforcement timeframes.
Directives 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment and 2002/96/EC on waste electrical and electronic equipment are designed to tackle the fast increasing waste stream of electrical and electronic equipment and complements European Union measures on landfill and incineration of waste. Increased recycling of electrical and electronic equipment will limit the total quantity of waste going to final disposal.
The Restriction of the use of certain Hazardous Substances (RoHS) Directive will be effective July 1, 2006. From this date, producers of certain categories of electrical and electronic equipment will not be able to place on the market products that contain six banned substances unless exemptions apply.
During this period of transition, Adtron has made significant progress in our efforts, but has not completed our discovery process sufficiently to ascertain the RoHS compliance status of all materials and components utilized in construction of our products. Adtron is not prepared at this time to provide material content disclosures, listing of products, date of compliance or anticipated compliance, or to unequivocally certify whole product classifications as RoHS compliant. Tentative compliance information is currently available to the extent that Adtron has completed material discovery and product re-design efforts. RoHS compliance information in general, and as applicable to specific part number(s), will be provided upon specific customer request and as ordered.
The WEEE Directive aims to raise the level of recycling of electrical and electronic equipment (EEE) and encourages designers to create products with recycling in mind. Potentially, a key part of this is to make manufacturers and importers ("producers") of EEE responsible for meeting the costs of the collection, treatment and recovery of WEEE. If products are designed with this in mind, there is an opportunity to reduce these costs.
RoHS supports this by reducing the amount of hazardous chemicals used in production. This reduces the risk of exposure to the recycling staff and means that less special handling is required. This leads to a further saving in recycling costs.
Responsibility for complying with WEEE remains with the integrator of Adtron storage products, with Adtron ensuring compliance with RoHS.
Frequently Asked Questions
These Frequently Asked Questions (FAQ) are intended to assist customers to interpret relative standards and activity here at Adtron to be responsive to international environmental regulatory compliance requirements. While Adtron will attempt to offer FAQs to relevant questions, reliance and familiarity with region-specific regulations remains the responsibility of the integrator of Adtron products.
What is RoHS?
The European Union (EU) Directive on the Restriction of use of certain Hazardous Substances (RoHS) restricts the use of six substances in electrical and electronic equipment placed on the market after July 1, 2006. RoHS is a "single region" directive which aims to remove disparities across member states.
What is WEEE?
The European Union (EU) Directive on the Waste from Electrical and Electronic Equipment (WEEE) aims to raise the level of recycling of electrical and electronic equipment (EEE) and encourages designers to create products with recycling in mind. Potentially, a key part of this is to make manufacturers and importers ("producers") of EEE responsible for meeting the costs of the collection, treatment and recovery of WEEE. If products are designed with this in mind, there is an opportunity to reduce these costs. Compliance with the "Wheelie Bin" marking is still required from August 13, 2005.
RoHS supports this by reducing the amount of hazardous chemicals used in production. This reduces the risk of exposure to the recycling staff and means that less special handling is required. This leads to a further saving in recycling costs.
Responsibility for complying with WEEE remains with the integrator of Adtron storage products and not with Adtron.
What are the six RoHS banned substances?
- Lead (pb)
- Hexavalent chromium (Cr(VI))
- Mercury (Hg)
- PolyBrominated Biphenyl (PBB)
- Cadmium (Cd)
- PolyBrominated Diphenyl Ether (PBDE)
Who is the producer under RoHS?
Producers of equipment are held responsible for ensuring that their products do not contain the six restricted substances. The Directive does not cover components or sub-assemblies and so the equipment producers will be required to take necessary precaution to ensure that all parts and materials used in their products do not contain restricted substances.
Does RoHS specify an acceptable maximum concentration of the banned substances?
Not at this time (June 9, 2005), except for stated product or process exemptions. Consideration is being given to identifying maximum concentration values (MCV). These have not be formally agreed upon, but are likely to be 0.1 weight percent of lead, mercury, hexavalent chromium, PBB and PBDE and 0.01 weight percent cadmium in homogeneous materials. For clarification, refer to frequently asked questions at http://europa.eu.int/comm/environment/waste/weee_index.htm.
What does "homogeneous materials" mean in relation to RoHS and WEEE?
The definition of homogeneous material has caused some confusion. You will not find any reference to "homogeneous materials" in either Directive. However, the European Commission has proposed a draft decision that defines the term as a material that is a uniform composition throughout, which can not be mechanically disjointed into different materials (i.e., plastic).
Are there RoHS compliance exemptions?
The list of exemptions and applications for exemptions continues to expand. It is important to keep you up to date with the changes as soon as they develop.
Where can RoHS and WEEE Directives and exemption information be found?
European Union Directive and related documents, including exemption information can be found at:
http://europa.eu.int
http://europa.eu.int/comm/environment/waste/weee_index.htm.
Does RoHS only refer to Lead-free (Pb-free)?
Lead is just one of several banned substances in the RoHS Directive. While the industry has adopted the terminology of "lead free", removing lead alone will not achieve RoHS compliance.
Is Adtron exempt from compliance with RoHS?
Adtron will comply with legislation and may seek allowable exemptions in some regions while the manufacturing and component industry transitions to full compliance with regulations. Should exemptions be sought, this information would be included in the respective declaration of compliance.
How will compliance with RoHS be demonstrated?
There is currently no legislation prescribing the method/means by which compliance is to be demonstrated, other than apparent acceptance of a producers "self-declaration", which may be justified by obtaining supplier assurances of compliant material and component content, or by material declarations developed by industry. There is currently no legislation that requires or defines what a material disclosure includes.
Evidence of compliance will be required if an enforcement authority asks for it, but they will expect to see evidence that the producer has taken what will be regarded as "reasonable steps" to comply with legislation.
If the "producer" imports Electrical and Electronic Equipment (EEE) into the European Union then, in theory, he would ask his supplier for a declaration that that the equipment complies.
If the producer assembles equipment within the EU, then he should obtain a declaration for all the parts, components and materials he uses and this information would be stored in a technical file.
One certificate or declaration is enough for each class or type of component, for example Adtron Flashpak™ product may be covered by one declaration as long as each product has similar composition and all are RoHS compliant.
What about RoHS compliance for spare parts/components for product placed in the market before and after July 2006?
The legislation allows for non-compliant parts to be used for maintenance, repair and / or upgrade of equipment put on the market prior to July 2006, but they will not be allowed in new products.
More Information
For more information about Adtron Corporation, contact environmental@adtron.com.
