Electro/Telecom Industry Trends
June 2005
The Reality of RoHS: Q&A with IHS
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IHS Project Manager Anne Brinkman is responsible for helping IHS customers ensure compliance with the European Union’s Restriction of Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) and Waste Electrical and Electronic Equipment (WEEE) directives by managing parts data collection activities.
Q: What is the typical process for gathering parts information for RoHS and WEEE compliance?
We usually have two data collection methodologies. The first one is for a very large parts list. We parse it out into the different suppliers and then try and see if those suppliers have posted any of their data on their websites. If so, we harvest that information, and if it equals what attributes are needed, we’re done. If it’s a more difficult list of attributes, we harvest what we can and then send the incomplete template to the supplier requesting that it be completed. We usually send it via email with a letter of authorization and an introduction and maybe a list of frequently asked questions. If we hadn’t heard from the supplier in five days, we send another follow-up email. Then, if another five days passes and we haven’t heard from them, we call and email them, and then they’re added to an escalation list. At that point, we also notify the client.
We use the second methodology if a company, such as a contract manufacturer who supports a number of customers, contracts with us for different bills of materials—BOMs. In those cases, instead of one huge BOM, we get a bunch of little BOMs. We treat each one of those as an individual project, because the end customer may have different attributes to be gathered. One customer may ask for five attributes while another may ask for 10.
Q: How long does it take to gather the information?
We try to make weekly deliveries, but the first delivery usually isn’t for the first three to four weeks. Our shortest time period is typically eight weeks, though it can be shorter if the list of attributes is very small. A lot of customers, however, figure that since they’re already gathering the data, they should get as much information as possible. They’ll ask questions that have nothing to do with RoHS or WEEE, but have to do with an internal mandate or have something else to do with recycling or hazardous materials. The time it takes to complete a project depends on factors such as the attributes being collected and the number of suppliers.
Q: How does a company determine what information they need?
The RoHS and WEEE directives are ever-changing, and unfortunately, the directives didn’t provide any templates. Also, other countries are coming out with their own directives, so some companies are afraid that if they don’t ask for everything right now, they’ll have to go back and gather it later. They have a really hard time determining what information they need to get and whether they need to do it internally or contract it out. It’s kind of a build or buy type decision.
Q: Why do you think your customers have decided to outsource rather than do the work internally?
They’ve probably analyzed their return on investment and determined what it would cost for one of their engineers to try to do the work. Also, they may or may not have their own offshore data team. If they have that, sometimes they can use it and then use us for the hard to find information. But if they don’t have a data team and they have limited resources or a very tight timeframe, then they call on us.
Q: What are some of the challenges you’ve faced?
Supplier responsiveness. The manufacturers and suppliers really weren’t prepared for the huge request for data. Really large suppliers, for example, obviously have a lot of customers and therefore can have a queue of eight to 12 weeks for information requests. At the same time, they’re trying to implement internal initiatives to post data on their websites, but even then there will be customers who ask for something unique that isn’t on their website. So they still have to process their request.
Q: What would you say to a company just starting this process?
I was on a conference call with such a company, and they were saying they couldn’t decide whether to ask for everything or just the basic RoHS and WEEE data. I recommended asking for the basics. With that information, their engineers could go about redesigning products if they had to, and they could decide if they needed to make some last-time buys on non-compliant parts. Then, if the WEEE directive, for example, starts asking for more information, they will know which parts have that substance and can go back and get more data.
For more information on IHS’ RoHS and WEEE solutions, visit http://solutions.ihs.com/solutions/enterprise/hazmat.jsp.