GVS's RoHS Compliance
GVS is fully committed to comply with all applicable laws and regulations, including the RoHS Directive which restricts the use of certain hazardous materials in electrical and electronic products. GVS's goal is to meet and exceed compliance obligations of the RoHS Directive on a global basis. Since July 1, 2006, RoHS substances will be virtually eliminated (to levels below legal limits) for all newly marketed GVS products subject to the RoHS Directive, except where it is widely recognized that there is no technically feasible alternative (unless otherwise exempted under the RoHS directives).
Restrictions pertaining to the use of certain Hazardous Substances (RoHS) are new industry requirements for environmental protection and recycling. RoHS is changing the world-wide electronics industry. And GVS is doing its part to produce environmentally safe products.
The RoHS Directive, also known as EU Directive 2002/95/EG, went in to effect on July 1st, 2006 in Europe. The RoHS directive mandates that electrical and electronic products put into the European market within EU states shall contain restrictive levels of the following substances:
- Lead (Pb)
- Cadmium (Cd)
- Mercury (Hg)
- Hexavalent Chromium (Cr6+)
- Polybrominated Biphenyls (PBB)
- Polybrominated Diphenyl Ethers (PBDE)
California and the Americas
California has initiated its own version of the EU's RoHS Directive, the Electronic Waste Recycling Act of 2003, or SB20, that took effect in January, 2007. At least 20 other states and Canada have legislation pending for RoHS-like regulations.
China has modeled after RoHS and WEEE following a more restrictive version with requirements that are being in effect since July, 2006. These include China's Regulations for Pollution Control of Electronic Products (RPCEP).
Japan has adopted the green procurement practices of JPSSI, a more stringent mandate than RoHS.
Taiwan, Korea, Australia
In the Pacific Rim, countries around the world are initiating versions of the RoHS directive.
RoHS is equivalent to RoHS compliance with Server Exemption
RoHS is not 100% Lead Free
Certain GVS servers, storage and storage array systems, serverboards, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunications are RoHS compliant or have the appropriate exemptions. RoHS compliance does not mean RoHS restricted substances are not present but, in general, do not exist as homogeneous materials and may not be present in GVS products in quantities greater than the limit of 0.1% (1000 PPM) or where application specific exemptions exist for the following:
- Lead and its compounds
- (other than lead in solder and in component package lead / ball terminations)
- Exempted (Leaded glass used in cathode ray tubes, electronic components and fluorescent tubes)
- Exempted (Lead in Steel - 0.35% or 3500 PPM)
- Exempted (Lead in Aluminum Alloys - 0.4% or 4000 PPM)
- Exempted (Lead in Copper Alloys including bronzes, brasses, 4% or 40KPPM)
- Lead carbonates and sulfates must not be used in any paint applied to parts, components, materials or products, 0.01% 100 PPM or less.
- Lead in PVC coating for internal or external cable, wire and cords (less than 0.03% or 300 PPM)
- Exempted (Lead in high melting temperature type solders, i.e. tin-lead solder alloys containing more than 85% lead)
- Batteries (less than 0.01% or 100 PPM)
- Exempted (Lead in electronic ceramic parts, e.g. piezoelectronic devices)
- Packaging Materials (May not contain any amount of lead as an intentionally added element (0.01% or 100 PPM or less)
- Exempted (scanner bulbs, projector lamps, backlit displays or LEDs)
- Packaging Materials (May not contain any amount of mercury as an intentionally added element (0.01% or 100 PPM or less)
- Hexavalent Chromium and its compounds (no more than 0.01% or 100 PPM)
- Non-Metallic Applications (Paints, Pigments, and Plastics)
- Metallic Applications (Corrosion preventative coatings, conversion coatings)
- Packaging Materials (May not contain any amount of hexavalent chromium and its compounds as an intentionally added element (0.01% or 100 PPM or less)
- PBBs or PBDEs
- (flame-retardants must not be contained in plastic parts, components, materials and products in greater than 0.1% or 1000 PPM)
- Packaging Materials (May not contain any amount of bromine based flame retardents as an intentionally added element (0.01% or 100 PPM or less)
- Cadmium and its compounds
- (No more than 0.01% or 100 PPM)
- Packaging Materials (May not contain any amount of cadmium as an intentionally added element (0.01% or 100 PPM or less)
Q. What is RoHS?
A. SEE BELOW.
Q. Who is responsible?
A. For publicly held companies many experts believe upper management may be held personally responsible for any lost revenue, as well as failing to warn shareholders of potential looses. See Sarbanes Oxley for more details.
Q. What does RoHS compliance mean?
A. Meeting the standards set by the EU Directive for 6 hazardous substances.
Q. What are the deadlines?
A. In July 2006, RoHS takes effect in the UK, and similar legislation been enforced in California, with many others set to follow on the same day.
Q. Who is ready?
A. Recent statistics suggest 50% of the supply chain in the US is currently NOT ready!
Q. Who else has or plans for substance bans?
A. California, Japan and possibly China, Mexico, Canada and several US states.
Q. What regulations should I comply with?
A. This is a command level decision. To not comply with a given set of rules effectively removes your products from the markets in question. We suggest complying with all rules (JIG A and B lists) as the most cost effective solution for all but the most specialized OEM. An exception might apply if you do manufacture a product for a single market, and never plan to address other markets.
Q. Is it necessary to comply?
A. YES. The risk is very high for non-compliance. If you are an OEM (producer) you may face product bans, additional scrutiny of your product line as well as negative public opinion. If you are a supplier, you face loss of your customer base as well as possible legal action if you are found to have acted fraudulently.
Q. Do I really have to look at every component I use?
A. For all practical purposes, yes. Currently, there is some latitude in how products are tested. In the past, some products have been disassembled and the component materials tested. Until there is additional clear direction, we suggest you act prudently and initiate compliance at the component level.
Q. What's GVS product roadmap about RoHS compliance?
A. Our goal is for all of GVS's future products, GVS9000 VTR, Nomadic Storage, Server motherboards, components, accessories, including Xeon base VTR's, GVS9000 Render Farm AMD base Dual Core Opteron, Quad, Dual and Single CPU based products to be RoHS compliant. All new products been devloped VTR's, storage, display, chassis and server systems will be RoHS compliant.
Q. How is GVS helping customers in regard the RoHS compliance?
A. Moving forward, GVS will provide our customers with RoHS compliant products including GVS9000, Nomadic Storage, chassis, servers, systems, and components to satisfy global environmental concerns throughout the world.
The Restriction of Hazardous Substances (RoHS)
RoHS is legislation enacted by the European Union parliament to control the distribution of certain hazardous substances. It is frequently pronounced so as to rhyme with 'toss'. While RoHS specifically refers to directive 2002/95/EC (see below) it is sometimes used to refer to more general cases of restrictions of materials and substances in various markets. Thus, to be 'RoHS compliant' may mean compliance with a larger set of rules.
The RoHS (and other legislation limiting hazardous substances) is critically important to the Electronics and Electrical Equipment (EEE) supply chain because of the severe penalties that can be directed at the OEM, reseller or importer who violate these rules and regulations. Penalties may be as extreme as a complete product recall from the EU markets. Not only would the recall itself be costly, but the additional scrutiny of the violator's other product lines would be of concern, as well as the negative public opinion (a 'green' violation is frequently more serious in many European countries that it is in the US).
DIRECTIVE 2002/95/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment….
RoHS is a law (directive) that seeks to remove or greatly reduce a group of hazardous substances from electrical and electronic equipment and products. It specifically addresses the results of these hazardous substances in landfills and in the recycling process. A short list of substances is currently addressed, but one should not assume this is the end of legislation of this type.
From the Directive:
Most Electrical and Electronic Equipment (EEE) is covered by this Directive. There are few exceptions. Exclusions may include some military equipment, implanted medical devices, large factory floor equipment and some classes of computer storage devices. These are fully defined in an appendix of the Directive, using the links to the Directive itself provided on this page.
- Member States shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). National measures restricting or prohibiting the use of these substances in electrical and electronic equipment which were adopted in line with Community legislation before the adoption of this Directive may be maintained until 1 July 2006.
Again, from the Directive:
For the purposes of this Directive, the following definitions shall apply:
- 'electrical and electronic equipment' or 'EEE' means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1,000 volts alternating current and 1,500 volts for direct current;
Please note the definition of 'producer' or responsible party. In general, the brand owner is the responsible party. Responsibility for unbranded products generally falls to most recent 'seller'. The actual text is reproduced below:
- 'producer' means any person who, irrespective of the selling technique used, including by means of distance communication according to Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997 on protection of consumers in respect of distance contracts
- manufactures and sells electrical and electronic equipment under his own brand;
- resells under his own brand equipment produced other suppliers, a reseller not being regarded as 'producer' if the brand of the producer appears on equipment, as provided for in subpoint (i); or
- imports or exports electrical and electronic equipment on a professional basis into a Member State. Whoever exclusively provides financing under or pursuant any finance agreement shall not be deemed a 'producer' unless he also acts as a producer within the meaning of subpoints to (iii).
(3) OJ L 144, 4.6.1997, p. 19. Directive as amended by Directive
2002/65/EC (L 271, 9.10.2002, p. 16).
In summary, RoHS and similar legislation is changing the way EEE is designed, manufactured and distributed. The risks are high, and the cost of compliance is not insignificant.
To be compliant means to 'follow the rules'. In the case of material and substance restrictions such as RoHS, your product(s) do not exceed any of the thresholds or limits established in the markets you intend to remain in. Example: If your products were ground up and analyzed by a chemical laboratory, the results would all be below the limits specified in the laws and directives of the countries or states of concern.
Producers are solely responsible for the chemical content of product(s). This responsibility means producers must collect and analyze the chemical content of ALL components and sub-parts of their product including sheet metal, hardware and electrical connections such as cables. Not only must producers collect this information, they must have confidence in its validity. Producers are responsible for information that may have appeared in many levels of the supply chain, so an accurate audit trail is a must.
A Good Compliance Program will do the following:
"Make certain that each and every component within all of your products is 100% compliant with the laws and regulations, as they are currently written and enforced, in all the markets you intend to enter and/or remain in". This is a simple statement, and it should be clear to your whole organization, from the engineers that design in a component, to the agents that purchase the components, to the manufacturing groups that create the product to the sales and marketing groups that promote the product and sell it into your markets. These laws and regulations are currently summarized in the RoHS and WEEE directives, but are not static. A producer's goal also includes becoming and remaining aware of the global situation as the restrictions change and evolve. It should be obvious that at some point in the life cycle of your products, a full and complete disclosure of materials and substances of concern must be undertaken. The components that are not 100% compliant with the regulations as they WILL BE ON THE DAY YOUR PRODUCT ENTERS THAT MARKET must be identified and replaced with compliant parts. Note again, these regulations are expected to evolve over time, so your disclosure efforts are not a one time effort.
More Questions Regarding GVS's RoHS Compliance?
Further questions and concerns regarding RoHS Compliance should be directed to GVS's Legal Department. GVS is RoHS ready!
The RoHS Directive aims to protect human health and the environment by restricitng the use of certain hazardous substances in new electrical and electonic equipment introduced into the EU beginning in July, 2006. The directive also complements the Waste Electrical and Electronic Equipment (WEEE) Directive.
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