lmost once a week or more, the phone rings or an email arrives, usually from a top name brand company or on behalf of one, asking about our product's compliance with environmental and hazardous materials regulations. I [Kevin] work for a semiconductor manufacturer, so the requests concern components we're supplying to a customer. But anyone supplying any components, subassemblies or finished electronic instruments or equipment could be subject to such inquiries. The request comes from a far-off land, because it's been outsourced to someone to get a form filled out. It seems this is more fun and monkey motion from our friends in corporate finance and legal departments. 

The good news is that people are paying attention to restricted materials regulations. However, the bad news is that these OEM customers are unwilling to subscribe to a supply-chain service such as SiliconExpert, which would allow them to have all the necessary materials information at their fingertips. They probably figure it is less money to get their suppliers to do it for free, using telemarketers to ask us to fill out an extensive check list that someone dreamed up as the standard for the Mr. Big company. The intention was to get every supplier to fill out this form with the same info on it.

The problem is compounded by the fact that different individuals working for the same company will contact us at different times asking us to fill out forms for different parts. As a supplier we have even asked them, "Can you send us a list of all the parts you use at one time so we can work on a complete list for you?" The response has been, "No, all I have here is part ABC123. Please fill out the form." Next week they call back with another part and don't even know their company asked us for something else last week. The process is usually not very organized.

Naturally, as suppliers we balk at these requests. After all, the information the customer is requesting has already been published on our company's website. So, we try to point the customer there. However, almost every attempt at telling them "here are the links which list all the information you are requesting," results in them responding, "yes but you must fill out our form in our format". What they don't say is why they insist we fill out their form. If they did, the answer would be "because I have no idea what any of this means and I will be calling people next week asking them for compliance information relating to health insurance."

Then too, we can't help fill out everyone's form because each one is different. But wouldn't it be nice if we had a standard form everyone could agree on? Maybe EICA (the Electrical Industry Certifications Association) or some other organization could establish a standardized form to simplify our lives a bit? While we wait for such a form to be developed, in the spirit of helping (without the ability to fill out every possible form that might cross your desk), we offer the following list of materials resources (see the table). These are the websites for the various global regulations that your customers may ask you about and these sites provide the information you'll need to help you fill out the RoHS, prop 65 Reach, and plethora of other requirements concerning restricted materials.

As noted previously, these regulations are not just for semiconductors. They apply to all components including passive electromechanical devices, cable assemblies, connectors and any parts going into an assembly. That includes hardware, plastic cases, rubber feet, purchased assemblies, batteries, power supplies and anything that goes into the box that you ship your product in. And they also mean the box, plus line cord and packaging materials—even the user's manual!

If you supply any of these items to a company that makes a product, then your product must be cleared for compliance with the targeted regulations, and you are required to fill out the tick box check list that company needs. This activity may not be fun, but visiting the regulatory websites and getting familiar with the requirements may take some of the pain out of the process.

Kevin Parmenter Director of Applications Engineering Taiwan Semiconductor America

Jim Spangler President Spangler Prototype Inc. (SPI)

Editor's Note: This article was first published in the July 2019 issue of How2Power Today (http://www.how2power.com/newsletters/index.php).

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