WEEE and ROHS UPDATE – July 2006

Wolfgang Josenhans US Robotics July 24, 2006

WEEE Effective August 13, 2005 (Not all Countries Implemented)

EEE = Electronic and Electrical Equipment • Concern: Increased use of environmentally unfriendly materials reducing landfill in Europe. WEEE = Waste Electronic and Electrical Equipment • The directive: Control the disposal of Equipment and the percentage going to landfill. CONSEQUENCES = Banned from sale N

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in the EU countries adopting the Directive.

What does USR need to do? “Producers” of EEE (Can be Distributors) are obliged to: • register with each EU nation’s governmental registers • report quantities (typically by net weight) of products placed on the market and quantities taken back • at least finance take back, recycling, and treatment of WEEE & ROHS • provide guarantees for financing these obligations to local authorities • provide product information for adequate disposal, e.g. product elements and substances • label products with respective symbol (crossed-out wheelie bin, standard logo)

What has USR done so far? Product Identification: Added WEEE Symbol (Crossed Out Wheelie Bin) on product labels on all product’s destined for sale in the EU. Customer Instructions: Created instructions (multi-language) to inform end-user customers as to proper disposal of our products to be included in product literature (paper insert) and the USR website. Take-Back Process: Defined a return methodology for end-users to facilitate one-off collection and disposal of USR products in the hands of end-user customers via our recycling partner Innovate. Record Keeping : All WEEE returns will be recorded by serial number and all units recycled via the recycling agent will be documented by a Certificate of Destruction to meet reporting requirements for each member state.

Product Identification - Unit and Over-pack Label

Customer Instructions

USR WEEE Take-Back Options Self-Managed Take Back - USR may elect to manage WEEE take-back on an independent basis where possible, precluding the expense and administration associated with joining a consortium in each country. • End-users will be given the option of returning their product to USR at no cost to be recycled by Innovate utilizing our WEEE recognized recycling firm in Eindhoven, The Netherlands. • The end user will be directed to the USR website to obtain step-by-step instructions to arrange for return of their product to avoid the cost of a call to the call center.

USR WEEE Liability-How big? USR currently captures and recycles USR product via European Reverse Logistics Partner. • Returns from end users are sent into Amsterdam, identified by unit serial number & recycled via a WEEE compliant recycling firm. • Returns from distributors and retailers are handled in a similar process and captured by unit serial number. The remaining WEEE liability is product in the hands of end users who might elect to recycle via USR take-back process (could be very few units annually). Country-by-Country registration ƒ Currently working with European colleagues to define registration requirements & whether we can use Distributors as WEEE take-back agents in certain countries. Currently have applied in Germany. Other states are waiting for process to be finalized.

ROHS – Effective July 1, 2006 Banned Materials – All products sold in the EU must meet these restrictions on materials: • Less than 0.1 % (1000ppm) = Lead, Mercury, Hexavalent Chromium, PBB and PBDE in homogeneous materials. • Less than 0.01 % (100ppm) = Cadmium in homogeneous materials. Exemptions - Except as indicated below, USR is not using any of the listed Exemptions: • Lead used as an alloying element in Steel (0.35%) and Copper (4.0 %). • Lead used in High Melting Temperature solders (containing more than 85 % Lead.)

USR ROHS PROCESS

New Part & Assembly Numbers – USR has changed all BOM assembly and Component No's to illustrate compliance. The New No's used are: • 64-245630-02 changed to 64-245630-02R • R15.0024.00 changed to ROHS15.0024.00

Required new product revisions for all heritage products. USR had to up the revision and implement new product approvals on over 120 separate assemblies in a 90 day cycle time. This included: • Verifying all components in current AML (Approved Manuf. List) list are ROHS compliant. • Creating new ROHS AML for production. • Creating new product BOM. • Scheduling production with manufacturing partners.

USR ROHS Process Cont. Challenges USR Observed • Obtaining ROHS compliant and ROHS Process capable components. Some suppliers took very long in delivering components (June, ’06). • Ensuring parts can be soldered in the Lead free process. Typically this is 25-30 degrees C hotter than Lead based solders, and can be as much as 260 degrees C. • Ensuring there is no mix up of lead based and Lead free plated components. This is driving the new P/N issue.

Product verifications included: • Prototyping Lead free manufacturing process. • Verifying product reliability with Environmental Stress Testing and Visual Inspections. • Verifying and updating Regulatory Approvals.

ROHS Product Documentation •RoHS Compliance follows the Self Declaration route. No Product Markings are used for Compliance. •Declarations of Conformity are used to show compliance. •USR has put voluntary labels on packaging as follows:

Documenting & Maintaining ROHS Compliance Creating Due Diligence – Producers are required to maintain documents that show proof of compliance with the ROHS directive for all materials used in production. Additionally, producers need to illustrate a process that illustrates that the documentation is current and meaningful. (i.e. supplier audits).

Product Analysis - EDXRF analysis tools are available that can report a material’s basic elements (Pb, Cd, Cr, Hg or Br). However, it cannot accurately determine whether or not a specific composition such as PBB is present. This requires further chemical analysis.

Auditing – USR’s position to maintain ROHS compliance will be to perform quarterly audits with our manufacturing partners to ensure compliance documentation and the AML are maintained. Compliance folders have been created electronically (PDF) and the AML is maintained in a SAP db.

Links for more information http://www.pb-free.info/lead_free_consultation_process.htm http://www.dti.gov.uk/innovation/sustainability/rohs/page29048.html http://www.designchainassociates.com/ http://ec.europa.eu/environment/waste/weee_index.htm http://www.newark.com/services/rohs/index.html http://nepp.nasa.gov/whisker/