Department of Defense Briefing on Impacts of the EU REACH Legislation

Department of Defense Briefing onImpacts of the EU REACH

Legislation

July 16, 2008

Tony Hilvers, Vice PresidentSahar Osman-Sypher, Project Manager

IPC The Association Connecting Electronics Industries

Agenda

• What are the impacts of REACH on DoD?

• What is the electronics industry doing to address REACH?

• What else needs to be done to protect DoD capabilities?

About IPC

Based in Bannockburn, IL

with offices in

Washington, D.C.; Taos, NM; Irvine, CA.; Shanghai and Shenzhen, China and

Stockholm, Sweden

About IPC2,700 member companies –the entire electronic interconnection supply chain•PCB manufacturers and their suppliers

•EMS Companies and their suppliers

•Original Equipment Manufacturers

•Government Agencies/Universities

About IPC

• ANSI standards setting organization

(Many military standards now converted to IPC standards)

• Training, certification and professional development

• Market research

Estimated cost

If RoHS cost the industry$1 dollar then…

Reach will cost the industry $12

Reach Impact on DoD?

What are the impacts of REACH on DoD?

• Impacts Difficult to Predict– Guidance still being written– Disagreement among member countries– Suppliers of substances and preparations

are keeping their pre-registration/ registration strategies close to their chest

What are the impacts of REACH on DoD?

• Impacts Difficult to Predict- Lots of inquiries up and down the supply chain, but no real direction

What are the impacts of REACH on DoD?

Law of Unintended Consequences… (the story of RoHS and Lead Free)

Unfortunately, we all share the same supply

chain.

RoHS: No problem we’re

exempt!

Unintended ConsequencesTechnical issues

• Are components lead free?

- Component markings

- Availability

- Use of alternative components (COTS) • Are PCBs lead free• Tin Whiskers

Unintended ConsequencesManagement/financial issues

• Cost of tin lead solder

• Cost of tin lead

components/availability

• Tin lead PCBs

(Surface Finishes)

• Materials management

What are the impacts of REACH on DoD?

• Some substances will be withdrawn from the market – Regulation under REACH– Decision by the manufacturer to withdraw

substances from the market

What are the impacts of REACH on DoD?

• Information and warning time

may be limited

• DoD will have to qualify substitutes

What is the electronics industry doing to address REACH?

1 to 10 scale with 1 being the lowestIPC Market Research Study – July 10, 2008

What is the electronics industry doing to address REACH?

• The Electronics Industry Structure Presents Compliance Challenges

• Large number of OEMS (differs from Aerospace and Automotive)

• Broad and deep supply chain• Significant shift to non-US production• Limited market power: not a major (driving)

customer for many of the substance suppliers

What is the electronics industry doing to address REACH?

• IPC Focusing on Education and Raising Awareness– Ongoing web-based compliance training– ½ day workshops scheduled for fall– Developing compliance guide

What is the electronics industry doing to address REACH?

• Standards-based activity for supply chain communication regarding chemical use

• IPC 175x Supplier Declaration standards– Supply chain data exchange standards– XML based

• IPC 1752 Addresses Substances in products– Will include SVHC substances because the presence of

these substances in products requires notification– Committee currently reviewing inclusion of proposed

Candidate List Substances– option under 1752

• IPC 1757 being developed to address process chemicals

What else needs to be done to protect DoD capabilities?

• No easy answers

• Expect the unexpected

• Continue participating

in industry standards

and other associations