Declaration of RoHS Compliance

All materials used in the construction of PENCOM components and/or assemblies, including raw stock, finishes, etc., are compliant to RoHS specifications. The European Union’s Directive 2002/95/EC on the restriction of hazardous substances in electrical and electronic equipment (RoHS) is defined as containing less than 0.1% (1000ppm) by weight at the homogenous material level for Hexavalent Chromium (CrVI); Lead (Pb); Mercury (Hg); Polybrominated Diphenyl Ethers (PBDE); Polybrominated Biphenyls (PBB): and less than 0.01% (100ppm) for Cadmium (Cd). The possible exception to this is where a non-compliant part is specifically called out for and approved by a PENCOM customer for engineering considerations.

The above mentioned Directive, with all six materials being less than the restricted maximum values, is now commonly called RoHS 6, which describes most of PENCOM products. An alternate to this standard, now referred to as RoHS 5, allows for Lead (Pb) to be used in excess of the 1000ppm restriction, for specific, controlled exemptions. Article 4(1) of Directive 2002/95/EC provides exemptions for Lead (Pb) as an alloying element in steel containing up to 0.35% by weight, aluminum containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight. PENCOM has and will continue to use these exempted, “free-cutting” materials for some of our products.

PENCOM products, unless otherwise specified, are also Halogen free and do not contain Decabromodiphenyl Ethers (deca-BDE) or Perflourooctanesulfonic Acid (PFOS). PENCOM does not use Hydrochlorofluorocarbons (HCFC) or Hydrofluorocarbons (HFC) in the manufacture of its products or those it supplies.

PENCOM asks customers to note the following provisos:

  1. PENCOM will provide reasonable documentation support for verification of part compliance with RoHS standards. Customer submitted and/or requested spreadsheets, C of C’s, SDOC’s,etc. will be completed for RoHS information and returned as soon as practical. PENCOM reserves the right to use its own forms if necessary.
  2. Agreements or pledges for universal RoHS compliance, with or without penalties, will not be entered into by PENCOM. Compliance certification will be given on a part by part basis only.
  3. PENCOM uses some current customer controlled drawings for fabrication that were not specified for RoHS compliance. In order to achieve part compliance, that customer, or its approved subcontractors, would need to submit a revised drawing mandating RoHS compliance. In lieu of that, a special authorization agreement could be discussed with PENCOM engineering.
  4. For customer controlled drawings not presently fabricated by PENCOM, a current drawing would be required, along with purchase order, indicating RoHS compliance.
  5. For any formerly non-compliant part changed to compliant, PENCOM disclaims any responsibility for suitability in application of the compliant version. The customer accepts the responsibility of the difference between compliant and non-compliant versions.

PENCOM also endeavors to continue to comply with the following changing global environmental legislation (some of these are still in the formation of specific details):

Europe – EU Directive 2002/96/EC WEEE (Waste Electrical and Electronic Equipment),

Europe – EU Directive 2006/1907/EC REACH (Regulation on Registration, Evaluation, Authorization and Restriction),

Japan – JGPSSI (Japan Green Procurement Survey Standardization Initiative),

China – RPCEP (Regulation for Pollution Control of Electronic Products) and

USA – SB20 & SB50 (Electronic Waste Recycling Act) for California.

Please contact your local PENCOM representative, or me directly, if you have any questions relating to the status of the Material Compliance Program at PENCOM.

Michael G. Whitney
Director of Material Compliance
mike@pencomsf.com
702-324-6766