What is RoHS?
It is an acronym for the “Restriction of the use of certain Hazardous Substances” in EEE (Electrical and Electronic Equipment) that restricts the use of ten substances that exceed certain levels in EEE placed on the EU market after 1st July 2006.
Which substances are restricted under RoHS?
Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent Chromium (Cr(VI+)), Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE), Bis (2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP) and Diisobutyl phthalate (DIBP).
What category of EEE applies to Harmonic products?
Harmonic manufactures products under two categories:
IT and telecommunications equipment
Monitoring and control instruments
What are the various standards and organizations that address the Pb-free issue?
There are many standards and organizations that address the Pb-free issue. Here are some of the key organizations:
What are RoHS Exemptions?
Exemptions are given for defined applications for which the elimination of the prohibited substance is technically or scientifically impracticable or when the available substitution produces negative benefits to the environment, health, or consumer safety.
Do any of the RoHS exemptions apply to Harmonic products?
There are number of RoHS exemptions applicable to Harmonic products, details of which can be obtained by contacting Harmonic Compliance Team.
What is REACH?
REACH is an acronym for “Registration, Evaluation, Authorization and Restriction of Chemicals”. It is a legislation from the EU that applies to suppliers (inside and outside EU member states) who want to sell, import and manufacture certain chemicals in EU.
Do Harmonic products contain REACH SVHC?
To date, we have not found a single occurrence of SVHC in our product >0.1% by weight. However, for up-to-date information on specific product, we request you to contact Harmonic Compliance Team.
What should I do if SVHC is present in Harmonic product?
If you are notified that there is an SVHC present in the product that is provided to you, you should also receive safe use instructions. Follow the safe use instructions to ensure that handling of product does not cause unnecessary harm.
Where can I find more information on REACH and Substances of Very High Concern?
What minerals are considered “conflict minerals”?
“Conflict Minerals” currently include gold, tin, tantalum and tungsten, the derivatives of cassiterite, columbite-tantalite and wolframite, respectively. These conflict minerals are referred to as “3TG”.
What is section 1502 of the Dodd-Frank Act?
Effective July 21, 2010, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires companies regulated by Securities and Exchange Commission (SEC) to inquire into the origin of the conflict minerals in their supply chain and report on the due diligence or reasonable inquiries to determine whether conflict minerals contained in their products are sourced from the DRC (Democratic Republic of Congo) or adjoining country or if they are from recycled or scrap sources.
Does the Dodd-Frank Act make it illegal to use conflict minerals if they originate in the DRC or from the other covered countries?
No. The Dodd-Frank Act rule relates to disclosure only, and they do not prohibit the use of conflict minerals in products at this moment.
Are there any standards being developed for electronically passing this data between tools (like the IPC1752A for hazardous substance information)?
The EICC/GeSI template is the essential form. It provides the ability to make one declaration for an entire company, division, product, or part.
What are the expected fines and penalties for non-compliance?
SEC files only apply for false disclosures. Customers will have various responses, the most serious of which will be the loss of business and removal from the customers' approved vendor/supplier list.
Where can I find conflict mineral legislative information and technical guidance?
You can find additional information about conflict mineral legislative and technical guidance from the below sources.
Global e-Sustainability Initiative (GeSI)
Organization for Economic Co-operation and Development (OECD)
U.S. Securities and Exchange Commission (SEC)
Electronic Industry Citizenship Coalition (EICC)
Conflict-Free Smelters Program
Are Tin, Tantalum, Tungsten and Gold present in Harmonic products?
All Harmonic products contain one or more of the 3TG minerals.
Does Harmonic purchase any conflict minerals directly from suppliers or refiners or smelters?
Harmonic does not purchase conflict minerals or their derivatives, in any form, directly from any supplier, refiner, or smelter.
Has Harmonic completed a Reasonable Country of Origin Inquiry (RCOI)?
Harmonic Inc. has completed an RCOI for its products. This inquiry was reasonably designed and was conducted in good faith with an effort to obtain reliable representations indicating all smelter or refiner facilities at which its conflict minerals were processed and that those conflict minerals did not originate in the DRC or an adjoining country or come from recycler or scrap suppliers.
Whom do I contact if I have additional technical questions about Harmonic’s conflict mineral issues?
What is WEEE?
It is an acronym for “Waste Electrical and Electronic Equipment” directive of the EU member states that impose obligations on producers of EEE on the reuse, collection (or “take-back”), recycling, and disposal of WEEE.
How does Harmonic know for which products in the EU it has “take-back” obligations?
In accordance with the WEEE Directive, Harmonic places a “crossed-out wheeled bin” symbol on its products that are shipped into the EU.
How can a Harmonic EU customer contact Harmonic to request “take-back” of EEE?
What quality certifications does Harmonic have?
Does Harmonic have Environmental Management System or ISO 14001 certification?
Harmonic products are manufactured using full turnkey Electronic Manufacturing Services (EMS). Harmonic does not manufacture any products at any of its sites. The EMS used by Harmonic is ISO 9001, ISO 14001 and OHSAS 18001 certified. Please contact Harmonic Compliance Team for more details.
How can I obtain additional regulatory compliance information about Harmonic products that are not covered in FAQs?
Regulatory compliance information and/or documents regarding Harmonic products can be obtained by contacting the Harmonic Compliance Team.
These FAQs are intended for basic informational purpose and they shall not be construed as legal advice.