HiTek POWER LTD POSITION REGARDING ROHS AND WEEE DIRECTIVES

Introduction
HiTek Power Ltd is committed to implementation of the RoHS Directive.

Our objectives are:

• To comply with regulatory requirements.
• Meet customer expectations for the RoHS compliance status of our products.
• Develop products that have minimum environmental impact.

This overview provides a road map of our route to compliance and explains key points within the Directive with their implications for HiTek Power.

Key points of the RoHS Directive

• Restriction of Hazardous substances: the aim of the RoHS Directive is to restrict the use of certain substances commonly used in electrical and electronic equipment. Studies have shown that these substances are harmful to the environment and in turn cause harmful effects to humans. Increasingly much electrical and electronic equipment has either very short life cycles (new models frequently introduced rendering the replaced equipment with little or no value) or the purchase price has dropped so much that it is cheaper to replace a faulty item rather than have it repaired. Either way equipment is discarded into the household waste stream ending up in landfill sites leading to pollution of the ground water. A secondary effect is that significant quantities of material are disposed of rather than recycled, further depleting the earth’s resources.
• The RoHS Directive is a single market directive. This means that it is implemented identically by each Member State – no Member State can amend it.
• The RoHS Directive came into force on 1st July 2006.
• The RoHS Directive is part of a package of environmental directives. In particular the RoHS Directive complements the WEEE Directive. The WEEE Directive is concerned with the environmentally sound disposal of electrical and electronic equipment, encouraging reuse and recycling of equipment where possible.
• The RoHS Directive restricts the use of the following substances:
• Lead
• Mercury
• Hexavalent Chromium
• Cadmium
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE)

Typically these substances are found in:

• Lead: coatings on components leadouts, PCB soldering points, in cable as a flame retardant
• Mercury: on contacts for switches
• Hexavalent Chromium: as a coating on metals for corrosion protection
• Cadmium: as a pigment for coloring
• PBB and PBDE: as a flame retardant in plastics.
• The maximum permitted levels are: i) 0.1% by weight in homogeneous materials for all except Cadmium ii) 0.01% by weight in homogeneous material for Cadmium
• Homogeneous material – a material that cannot be mechanically disjointed into other materials. This means that components have to be split into component parts e.g. plastic package, leadouts, semiconductor material etc.
• The RoHS Directive applies to products within the scope of the following categories:
• Large household goods
• Small household goods
• IT and telecoms equipment
• Consumer equipment
• Lighting equipment
• Electrical and electronic tools
• Toys, leisure and sports equipment
• Automatic dispensers

Medical equipment and control and monitoring equipment are currently exempt from the RoHS Directive, but included within the WEEE Directive. The European Commission is currently considering whether these two product categories should be included within the scope of the RoHS Directive.

• There are exemptions detailed in the RoHS Directive. Key ones that impact some of our customers being military equipment and large scale industrial tools. Although HiTek Power is working towards RoHS compliant product as the standard, many of our customers fall within the RoHS exemption category and have indicated that they have a strong preference for receiving non RoHS compliant product (they are change adverse as they consider it a risk to product performance continuity), where this is the case HiTek Power shall of course respond and limit changes to their product type. 
                                                                                 
• RoHS implementation by HiTek Power
  It is HiTek Power’s intention to move towards RoHS compliance with timescales consistent with customer requirements and availability of components. We are currently able to accept orders for some RoHS compliant product with further unit RoHS approval being completed on an ongoing basis; we are of course working with our customers to ensure our RoHS product rollout program meets their requirements.
• A team has been set up within HiTek Power, led by Engineering, but encompassing all functions within HiTek Power. Internal presentations have been given to key staff highlighting the importance of the RoHS Directive and how we propose to comply with it. It is the intention to give further presentations to all staff on a rolling program. New procedures have been introduced within the manufacturing process to identify RoHS compliant components, ensure new parts used are RoHS compliant and identify RoHS compliant material received at Goods Inwards.
• New RoHS compliant processes and materials are being tested and approved on an ongoing basis, key areas of change such as lead free soldering have (after an extensive selection process) been rigorously tested prior to approval.
• Working in partnership with suppliers, HiTek Power is progressing well with ensuring its supply chain is on track for meeting its RoHS implementation plan.
• Components are being assessed for RoHS compliance. Details of RoHS compliant components from major manufacturers are obtained from their websites. C of Cs will be requested from manufacturers. Manufacturers of specialist components are further required to provide information to support RoHS compliance. Companies providing process support are required to sign a Declaration stating that the materials used in the process are RoHS compliant. As part of the company’s ‘due diligence’ RoHS process HiTek Power has purchased a X-MET3000 XRF scanner; with key members of the compliance team now having successfully completed their training in the detailed spectral interpretation and operational setting of this instrument. With this XRF scanner QC verification RoHS testing is now being carried by HiTek Power to validate supplier RoHS compliance declarations and finished product RoHS status; ensuring that HiTek Power RoHS compliance declarations are backed by hard objective test data.
• Once approved HiTek Power will sign a Declaration to confirm that products comply with the RoHS Directive.
• A "RoHS compliance file" is created for each RoHS compliant product. This file gives evidence to support the RoHS Declaration. It includes Declarations from our suppliers stating that materials used in their processes are RoHS compliant, declarations from component manufacturers of specific components and generalized statements or data sheets from component manufacturers appearing on their websites. Where appropriate third party material declarations will be included. Data Resulting from XRF testing carried out by HiTek Power is also included in product RoHS compliance files.
• Products complying with the RoHS Directive will normally carry a label to indicate RoHS compliance, shown below. HiTek Power part numbers will not usually change.

For further information:

High Voltage Customers, please contact:

Jeff Edwards, Director of Quality
Telephone: 01903 712420

E-mail: (jeff.edwards@hitekpower.com)

Low Voltage Customers, please contact:

Matt Martis, US Sales

Telephone: 619 258 7700

Email (martis@hitekpower.com)

Links for further information
UK DTI website:
http://www.dti.gov.uk/sustainability/
This website provides the latest information from the UK Government. Also included are copies of the RoHS and WEEE Directives along with copies of the UK draft guidance notes for the RoHS and WEEE Directives

EU website: http://europa.eu.int/comm/environment/waste/weee_index.htm