Tim Bannon Product Manager, EMEA RoHS & WEEE Compliance Programme Update.
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Tim BannonProduct Manager, EMEA
RoHS & WEEECompliance Programme
Update
2
Agenda
VeriFone Environmental Compliance Programme
RoHS
Part Numbers
Product Release
“Put on market”
WEEE
Timeline Summary
Current activities
3
VeriFone Environmental Compliance Programme
As a trusted global leader in the secure electronic payment industry, VeriFone is committed to address the RoHS Directive as part of its corporate Environment Compliance Programme (ECP)
Under the ECP, VeriFone has been actively working with industrial partners, suppliers and service providers to comply with all applicable substance legislation worldwide
The use of environmentally friendly substances will not affect VeriFone’s commitment to delivering high quality products. We will continue to work diligently with our customers to ensure a smooth transition to RoHS compliant products
4
RoHS (Restriction of the use of certain Hazardous Substances)
EU directive effective 1 July 2006 – adopted as law in EU member states
Defines the prohibited substances (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) in terms of maximum concentration value
All product imported and deployed into the EU from 1 July 2006 must be RoHS compliant
SC5000, PP100SE, Vx510, Vx610, Vx570, Vx670, MX870 product families will be RoHS compliant
RoHS product will begin shipping to ALL of EMEA from1 July 2006
5
RoHS Part Numbers
RoHS compliant part numbers end in an alpha characters:
Vx510, M251-xxx-xx-xx(a)Vx570, M257-xxx-xx-xx(a)Vx610, M256-xxx-xx-xx(a)Vx670, M267-xxx-xx-xx(a)SC 5000, M108-xxx-xx-R or M108-xxx-xx-RxxPP1000SE, P003-xxx-xx-R or P003-xxx-xx-RxxMx870, M090-xxx-xx-R
Accessories xxxxx-xx-R
Terminals
Consumer Facing
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RoHS Part Numbers continued
Items NOT requiring RoHS Part Numbers Intangible items such as firmware, services, on-line
manuals etc Plastic Parts Paper products such as Certs and Regs, Quick install
guides, labels, boxes
Spares Spare parts are not required to be RoHS compliant Most product lines will move to RoHS spares which will be
backward compatible to non RoHS variants
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RoHS Product
RoHS product does NOT require different OS or software
Currently sent out limited units for functional testing• SC 5000, PP1000SE and Vx610 GPRS sleds sent out on 2 May• 610 WiFi sleds/terminals, 510 and 570 terminals to be sent out around
25 May)
Target is to begin shipping RoHS compliant product for deliveries scheduled after 1 Jul 2006
VeriFone can only ship Non-ROHS compliant product to non EU countries
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“Put on market”
Non-RoHS goods can be resold in EU countries after 1 Jul 2006 if the goods have been “put on the market” before 1 Jul 2006
The Guide to the implementation of directives based on the New Approach and the Global Approach defines “put on the market” as follows: • Ownership – Must of exchanged between VF and another legal entity • Delivery - Goods have been physically delivered and cleared EU
customs• Packaging - Goods are packaged in their final working condition
without requiring further measures (e.g. OS has already been loaded)• Shipping - Goods must be shipped with the intent of being sold into
that country. “In-transit” goods are not considered to be “put on the market”
• “The market” can be considered to be the EU market or the local market. This varies by the domestic laws.
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“Put on market” is defined as…
Austria
Belgium
Cyprus
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxembourg
Malta
Poland
Portugal
Slovakia
Slovenia
Spain
Sweden
The Netherlands
United Kingdom
BLUE EU market
GREEN Local market
LIGHT BLUE Not yet defined so use EU market
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Importing Non-RoHS Product Implications
Non ROHS goods are imported into an EU country and “put on market” before 1 Jul 2006
VIP wants to export goods to Country Y
Country Y’s interpretation of “the market” must be the EU market for the goods to be imported
From confidential sources we have learned that the European Commission has taken the issue of whether the relevant "market" is the EU market versus the local market seriously by issuing warning letters to certain Member States.
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EU Member State
RoHS Domestic legislation
in force by Jul 1-
06 RoHS Violation Max
Penalty
RoHS Violation
Max prison
sentence EU Member State
RoHS Domestic legislation in force by
Jul 1-06 RoHS Violation Max
Penalty
RoHS Violation
Max prison
sentence
UK Unlimited Ireland Not specified
Austria € 7,270 Italy € 100,000
Belgium € 10,000,000 8 yrs Latvia Not specified
Cyprus $42,530 3 yrs Lithuania In
Progress 10,000 LTL
Czech € 35,000 Luxembourg € 125,000 ½ yr
Denmark Not specified 2 yrs Malta N/A Not specified
Estonia € 1,597,780 2 yrs Netherlands € 45,000 2 yrs
Finland € 850,000 Poland Not specified
France In
Progress € 7,500 Portugal € 44,800
Germany € 50,000 Slovakia Not specified
Greece Not available Slovenia € 83,529
Hungary $1,750 Spain € 1,200,000
Sweden Not specified 6yrs
RoHS readiness, max fine & prison sentence
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WEEE Directive
Waste Electrical & Electronic Equipment (WEEE)
EU directive effective 13th August 2005 – adopted as law in EU member states
Requires that the importer (producer) of the product “put on market” after 13 Aug 2005 registers for WEEE and provides for take-back and destruction at end of life
Producers are responsible (by individual financial guarantee) for financing waste management costs for “new” products “put on market”
Noncompliance with WEEE may result in penalties beginning from August, 2005
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WEEE registry, max- fine & prison sentence
EU Member State
Deadline for WEEE
registration
Fine for failing WEEE
registration
Prison sentence for failing WEEE
registration EU Member State
Deadline for WEEE
registration
Fine for failing WEEE
registration
Prison sentence for failing WEEE
registration
UK N/A N/A Ireland Jul 20, 2005 Forthcoming
Austria 1-m before
placing EEE € 2,910 Italy 90-d prior
placing EEE € 100,000
Belgium Aug 1, 2005 N/A Latvia 1-mo prior
placing EEE $603
Cyprus Oct 31, 2005 $42,530 3 yrs Lithuania Mar 31, 2006 5,000 LTL
Czech Oct 12, 2005 € 35,000 Luxembourg Apr 1, 2006 € 125,000 6 months
Denmark Jan 1, 2006 Forthcoming Malta N/A N/A
Estonia No registration
required Forthcoming Netherlands 13-wk prior placing EEE € 45,000 2 yrs
Finland May 15, 2005 Forthcoming Poland Oct 1, 2006 € 1,281
France Dec 1, 2006 € 2,250 Portugal Aug 13, 2005 Forthcoming
Germany Nov 23, 2005 € 50,000 Slovakia 1-mo prior to placing EEE $16,000
Greece N/A N/A Slovenia Dec 31, 2005 € 375,852
Hungary Dec 31, 2004 Forthcoming Spain Jan 31, 2006 Forthcoming
Sweden April 1, 06 N/A
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WEEE - Summary
Waste mgmt costs shared by all producers for “historical” products on the market
WEEE Registration laws require VIPs to register for WEEE, including a WEEE take-back program
Where VeriFone is registered as a legal company such as UK, France and Poland, VeriFone will be responsible for the WEEE take-back
Failure to register may result in (but not limited to) • Maximum fine• Prison sentence• Confiscation• Closure of premises• Revocation of trade licenses
Our legal consultants have advised us that the Scandinavian countries and especially The Netherlands are very stringent
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VeriFone’s Environmental Leadership
http://www.verifone.com/industry/environmental/index.html
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Current Activities
Part Numbers – Only RoHS product can be ordered after 1 July. Speak with your Sales Manager / Sales Support Consultant if you require help with RoHS part numbers.
Functional testing feedback
610 WiFi sleds, 610 terminals, 510 and 570 terminals due to be sent out around 25 May for functional testing
Send out information update• Updated position statement• Certification marketing / operations information sheet• Update RoHS product spares lists
Distribute WEEE letter for signature
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RoHS / WEEE Timeline
WEEE
Pre Aug 2005
Waste mgmt costs shared by all producers for “historical” products on the market
WEEE
Producer has responsibility to finance recycling of marked products
13 Aug 2005
WEEE
Collection, treatment and financial system must be in place
Sep 2005
RoHS
All products sold in EU must be RoHS compliant
1 July 2006
WEEE
1st collection and treatment targets attained
31 Dec 2006
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Closing
Laws are “self-policing” but if a product is challenged we must be able to show due diligence was followed in our processes
Failure to comply with RoHS and/or WEEE may result in significant penalties
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Questions
Thank you
Any Questions
Tim Bannontim_bannon@verifone.com
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