Ready, Set, Go…China RoHS Compliance at KLA-Tencor
By Ken Kapur, KLA-Tencor
On March 1, 2007, officially the China RoHS regulations went into effect. KLA-Tencor was ready, although we had less than six months prior to the deadline to prepare. Since the EIP list included KLA equipment and KLA tools are included under “Inspection Test Equipment”, we knew that we would have to comply. With no exemptions for large scale tools as in EU RoHS, we worked quickly to develop a four-point corporate response:
1. Apply “25 year” EFUP (Environmental Friendly Use Period) label on all tools shipping to China
2. Description of hazardous material content in product manuals
3. Identify types and label packaging
4. Meet the deadline: March 1, 2007.
EFUPs of 25 years
At Corporate EHS, we developed standard company-wide EFUP labeling strategy. After consulting with other large manufacturers in Silicon Valley, we decided to select a 25-year EFUP. Each and every module of a tool receives the “25”EPUP label. In addition, in an attempt to avoid Chinese port authorities opening the shipping cartons, we label the outside of each shipping carton with the “25” EFUP label.
“Guilty until proven innocent” approach
Corporate also developed a template for the “Hazardous Material Content Table.” This could be used in the product manual (or it could be an insert). The table was developed in both simplified Chinese and English. We took an extremely conservative approach to the table, and used an “x” when we weren’t sure that the concentration of one of the hazardous substances actually was below the limit in a particular part. We call it the “guilty until proven innocent” approach.
Aggressive implementation schedule for Divisions too
The Divisions had to identify the separate modules for all products, prepare tables in Chinese, and look at sub-systems that might impact EFUP. In addition, they had to update safety manuals, ECO all changes into the manufacturing system, and verify that all products sold to China starting on March 1, 2007 meet China RoHS requirements.
What we learned
No company can afford to be passive in this age of global growth of far-reaching EHS regulations. Companies must proactively track emerging RoHS regulations—which isn’t always easy. For instance, when China recently updated its “frequently asked questions” documents that clarify China RoHS, it did not use a revision date, so even finding the changes can be challenging. Make sure that you read SEMI’s EHS website and this newsletter for updates. We also learned that it’s important to understand the hazardous material content of your products, so that you can be ready to quickly implement regulations once standards are published. If you wait until the laws go into effect, you’re probably already in trouble.
It’s simply not enough to label hazardous substances. Companies must start thinking about how to phase out hazardous substances. I believe that it is critical to have a solid tracking mechanism for hazardous substances for all of your company’s products so that you’re ready for more stringent, requirements—to not only monitor the hazardous substances as China RoHS now requires, but to actually restrict them. And last, but not least, we know that tracking the impact of RoHS regulations to semiconductor manufacturing equipment’s supply chain is key.
For more detail, contact Ken Kapur at email@example.com. This summary is based on a presentation at the May 2, 2007 meeting of the International Compliance and Regulatory Committee (ICRC). Membership of the ICRC is open to all SEMI members, and other selected individuals may join by invitation. For further details, click here.