Our semiconductor industry uses many different materials and chemicals in the production of chips, boards and electronic systems. But what should we do if the minerals like tantalum, tin, tungsten and gold are coming from the eastern provinces of the Democratic Republic of the Congo where armed bandits are forcing workers against their will? In the United States there’s a law called Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires companies to identify where the minerals used in their products came from. Our semiconductor companies need to have a Materials Declaration (MD) and a Conflict Minerals Report (CMR) to be in compliance with directives and industry data reporting standards like:
- RoHS (Restriction of Hazardous Substances)
- REACH (Registration, Evaluation, Authorisation and restriction of CHemicals)
- ELV (automotive End of Live Vehicle requirements)
- WEEE (Wasted Electrical and Electronic Equipment)
- Dodd-Frank Conflict Minerals
- Aerospace & Defense DSL
Mike Zepp from Dassault Systemes spoke with me by phone to share his background in plastics R&D, then the automotive industry where he has first-hand experience with what it takes to be compliant and produce a CMR. In 2005 Mike joined Dassault because they had a vision and software to help companies be compliant with these types of regulations and laws.
The specific software from Dassault is called Material Compliance Manager and it lets you assess product materials compliance during product design through integration with engineering BOM management. You can even integrate Material Compliance Manager with your favorite PLM and ERP systems. The basic process follows this sequence for your supply chain of outsourced components:
- Approved material compliance
- Conflict minerals declaration
Mike shared that many electronics companies started out building their own in-house tools to track compliance, but now many have started to considering switching to something off the shelf so that they can focus on their core business competence. Starting with their 2014 SEC filings, the new US law applied to US publicly traded companies, and they must declare that their products don’t contain any conflict minerals, an extensive process where companies have to request data from the OEM all the way down the supply chain, ultimately reaching the smelters of mined ore. Fortunately, the Dassault software manages all of this information throughout the supply chain, ingesting the data, sending out emails, and managing the process.
The Materials Compliance Manager is a browser-based tool that helps any organization create their materials compliance declaration. Companies like Keysight Technologies (ex Agilent) have about 100 people using this software, then thousands of engineers use the results of the tool to confirm that their products are compliant. Other companies that you might of heard about also use the software: AB Sciex (a division of Danaher), GE Healthcare, and Tesla Motors.
I’ve recycled my old consumer electronics devices at the local Staples store, where they gather a variety of scrap electronics and an electronics recycler then decides how to re-use and dispose of all the bits and pieces to protect the environment from hazardous chemicals. Lots of companies need to worry about being compliant: Foundries, Fabless companies, packaging companies, the electronics supply chain.
You can learn a new tool like the Material Compliance Manager in about a week or two to become proficient, and the folks at Dassault can help get your engineers trained. In summary, the key features and benefits of using this approach are:
- Manage materials to meet environmental compliance
- Analyze your product’s compliance
- Security and IP protection
- Assess impact of new compliance directives
- Manage supplier material declarations
- Export of product compliance to customers
- IMDS integration for auto suppliers
- Integrate the supply chain for supplier data collection
- Start supplier material declaration requests
- Determine engineering BOM materials compliance
- Maximize reuse of compliant components