Material Compliance

Material Compliance basically encompasses the statutory and customer-specific regulation of all materials and products.

All relevant provisions have been summarized in our “Guideline for the Ban and Declaration of Ingredients”.

This guideline supports Zollner Elektronik AG and its vendors/suppliers in the responsible and environmentally responsible handling of substances/materials in development, manufacture, use and waste disposal.

This guideline contributes to a high level of protection for human health and the environment with the goal of ensuring sustainable development.
This applies especially to all vendors/suppliers to Zollner Elektronik AG, regardless of their supplying country.
The following regulations are the focus point of Zollner Elektronik AG as an EMS and its customers:

 

 

RoHS (2011/65/EU)

The RoHS Directive regulates the use of substances/materials in electric and electronic devices that have been classified as hazardous/dangerous. The following 6 substances/materials have been affected since its taking effect in 2006:

Starting on Jul 22, 2019, DEHP, BBP, DBP and DIBP will also become banned by RoHS in an Annex (2015/863/EU “RoHSIII”). Because these were already banned under REACH on Feb 21, 2015, no relevant impact is expected here.

 

At the final product level, practically all customers are affected by this regulation. Exempt from this are only customers from the Transportation, Aerospace and Military, as well as devices for permanent, large-scale installations. The End of Live Vehicle directive (ELV), which is comparable to the RoHS applies to the Automotive sector.

There are also exemptions at the component level, including the use of lead, which basically applies to all customers. RoHS exemptions 6 and 7 are the main relevant ones. These exemptions are claimed mostly for resistors, discrete semiconductors (diodes, transistors) with higher currents and brass plug connectors. In the mechanical area the focus is on brass parts, machining steel and aluminum with a lead content > 0.1 %. These exemptions were tentatively extended in 2018 to Jul 21, 2021. Renewed requests for extension are expected by Jan 21, 2020.

Due to the restriction of the use of lead, soldering processes at Zollner were already converted to lead-free soldering back in 2006. A large part of our soldering systems needed to be replaced or retrofit.

China RoHS

Basically, the same 6 original substances/materials in the European RoHS are also restricted here. However, because there is no exemption at the component level, one can typically assume that, for electronic devices, the lead content in the homogeneous materials of many components lies above limit values. Zollner Elektronik AG plans for an environmentally friendly expected useful life of at least 25 years.

REACH (EG)1907/2006

REACH (EG)1907/2006

Ordinance (EU) 1907/2006 Registration, Evaluation, Authorization and Restriction of Chemicals (“REACH”)

“REACH” stands for Registration, Evaluation, Authorisation and Restriction of Chemicals.

On the 1st of June, ordinance (EU) No. 1907/2006 for the Registration, Evaluation, Authorization and Restriction of Chemicals (“REACH”) went into effect. That means the following:

 

- Registration obligation for manufacturers and importers of chemicals in/into the EU

- Provision of safety data sheets

- Reporting obligation of SVHCs (according to the candidate list), if the component contains greater than 0.1%

- Ban of substances/materials after their addition to Annex XIV and expiration of the “Sunset date” (e.g.: CrVI. CAS 1333-82-0: Sep 21, 2017).

 

The list of affected SVHCs is updated 2x annually and can be accessed using this link:

https://echa.europa.eu/candidate-list-table

 

Since the going into effect of this legislation, Zollner Elektronik AG makes all suppliers aware of the information obligation in accordance with Article 33 and takes the legislation into consideration in its supplier contracts.

All notifications about SVHCs have been recorded centrally, the affected components marked in SAP and the customer notified via the PCN.

The focus of individual SVHC notifications was on plastic and rubber parts up to the middle of 2018, like insulating tape, foils, o-rings and hoses.

Additionally, all lithium batteries are always affected by SVHC EDGME (CAS: 110-71-4) as well as relays with CdO contacts of SVHC CADMIUMOXIDE (CAS 1306-19-0).

On June 27, 2018, lead was added to the SCHV list as a new substance.

All products with lead soldering that are not RoHS - compliant components typically contain lead above the thresholds.

Also, all components that are taking advantage of the RoHS excemption– except for glass and ceramic components– are always affected by the obligation to provide notification in accordance with REACH - Article 33. A focus in the area of electronic components is in discrete semiconductors (diodes, transistors) with high currents and plug connectors with brass. In the mechanical area the focus is on brass parts, machining steel and aluminum with a lead content > 0.1 %.

Because this affects 1,000s of components at Zollner, recording individual supplier notifications is not possible. Determination is made for electronic components using external databases, based on the RoHS exemption mark. For mechanical components, the recording of the material is typically necessary in order to be able to detect 0.1 % lead content.

The 4 substances DEHP, BBP, DBP and DIPB, whose use is restricted under RoHS as of Jul. 21, 2019, were recorded in REACH as SVHC as of 2008 and were forbidden on the 21st of February, 2015. Residual risk exists in this case only with stock parts or production abroad.

The material bans that went into effect due to the REACH Ordinance, in contrast to RoHS, apply to all sectors.

ELV (2000/53/EG) End of Life Vehicle directive

With declaration of ingredients, the recovery rate should be increased for end-of-life vehicles.

 

Zollner has been creating IMDS entries for customers in the Automotive sector for over 10 years. In this system Zollner and the vendors/suppliers of all relevant purchased parts declare the ingredients of their components. The residual lead content has also been taken into consideration for individual components for more than 5 years. With IMDS entries, compliance with GADSL (specific list of bans on materials for the Automotive sector) is secured.