»COMPLIANCE PLAN & POLICY FOR RoHS/WEEE DIRECTIVES


Envirotronics, Inc. is committed to RoHS compliance and will make every effort to assist our customers by making available as much information as possible.  This information will continue to change as additional data becomes available.

The Restriction on Hazardous Substances (RoHS) 2002/95/EC and Waste Electrical and Electronic Equipment (WEEE) 2002/96/EC directives are aimed at reducing the hazardous materials content in electronic products as well as increasing the recycling efforts for these products and take effect July 1, 2006.  RoHS specifically bans or restricts the use of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated biphenyl ethers (PBDE).

To the best of our knowledge and belief Envirotronics, Inc. products, with the exception of lead, do not contain the above mentioned substances as either intentionally added ingredients or as unintended impurities in concentrations exceeding EU regulatory limits.  This statement is based upon information provided by our raw material suppliers. Please be advised that Envirotronics, Inc. does not analyze its products for substances not purposely added. 

EXCLUSIONS:  Lead has been used widely in the electronics industry, both in electronic and electrical components and also, in lead-based solder.  The RoHS Directive requires that the use of lead be phased out by the electronic industry and substituted with alternative materials.  Some lead-free components have already been integrated into Envirotronics, Inc. products, but reliable alternatives to lead-based solders, in particular, have proven difficult to find.  The EU has recognized this issue and a limited number of exemptions for specific applications in certain product categories are listed in the Annex to the RoHS Directive.  Envirotronics Inc. is relying on the exemptions for lead in servers, controllers, storage array systems, network infrastructure equipment for switching, signaling, when applicable.  For example, the use of non-RoHS spare parts to repair non-RoHS equipment placed on the market prior to July 1, 2006 is permitted.  In addition, Envirotronics, Inc. will exercise the server infrastructure exemption until lead-free alternatives are identified that meet the performance requirements of its products.  Envirotronics, Inc.  continues to work with its suppliers to find reliable lead-free alternatives.  It is the intention of Envirotronics, Inc. as research and advances in product development allow to transition our products to all be lead-free over time.

PLEASE NOTE:
The majority of applications for our products are not within the scope of the RoHS and WEEE Directives Per WEEE, Category 6, Annex 1B:  “Machines or systems consisting of a combination of equipment, systems, finished products and/or components, each of which is designed to be used in industry only, permanently fixed and installed by professionals at a given place in an industrial machinery or in an industrial building to perform a specific task.  Not intended to be placed on the market as single functional unit.”

Directive 2002/96/EC (WEEE), talks about equipment containing gases that are ozone depleting or have a global warming potential (GWP) above 15,such as those contained in foams and refrigeration circuits:  the gases must be properly extracted and properly treated.  Ref: (EC)2037/2000.  Envirotronics Inc. uses only refrigerants believed to be Environmentally friendly, such “SUVA” 404A (R-404A), “SUVA” 95 (R-508B) and ISCEON ®(R) M089.  However, these substances, are controlled, recovered, recycled, reclaimed or destroyed as required by (EC) 2037/2000 Directive.  This information is true only for Envirotronics, Inc., products as shipped from our facility, and may become invalid if the product is mixed with other materials.

At this moment all Envirotronics products are conforming or exempt under the RoHS/WEEE Directives.  This statement may be modified in the future as the regulations change.  In addition, Envirotronics, Inc. electronic products will be transitioned to lead-free solders as the technology and reliability of the available alloys improves.

If assistance is required in determining RoHS compliancy or if you have any additional questions regarding an Envirotronics, Inc. product, please contact us at (616-554-5020).

TK
02/2007