Minebea Group Green Procurement Standard. EM th Edition. First Edition: July 12, July 01, 2015 (implemented) Minebea Co., Ltd.

Transcription

1 Minebea Group Green Procurement Standard EM th Edition First Edition: July 12, 2004 Fifth Edition: June 01, 2015 (issued) July 01, 2015 (implemented) Minebea Co., Ltd.

2 Table of Contents Table of Contents..... P1 Preface.... P2 01.Positioning of the Standard P2 02.Basic Policy.. P2 03.Operation Policy P2 1.Objective.. P3 2.Scope of Application. P3 3.Definitions. P4 4.Prohibited Chemical Substances. P5 5.Information of Chemical Substances for Submission P6 6.Operation.. P6 7.Data Requested for Submission.. P8 8.Detail of Data Requested for Submission P9 9.Communicating Information on Chemical Substances in Product. P11 10.Important Information Concerning Packaging/Packing Materials. P12 11.Additional Rules P12 Minebea Group Green Procurement Standard Attachment Ver.1.00 Attachment I Prohibited chemical substances Attachment II Prohibited chemical substances requested by customer Attachment III Information request chemical substance for submission Attachment IV Heavy metals regulations in packaging and packing material Minebea Group Green Procurement Standard - Related Document Document 1. RoHS Exemption List ANNEX III, IV and ELV ANNEX II Document 2. Prohibited chemical substances, and laws and regulations (examples) Document 3. Detailed List of Chemical Substances Forms of Documents required for Submission Form 1. Certificate of Non-Use of Prohibited Chemical Substance/Non-Use Certificate (with List of Prohibited Chemical Substance) Form 2. Environmental Hazardous Substances Survey Report Form 3. Component Sheet Form 4. Report of Analysis Results Form 5. SVHC survey form for REACH regulation Special Requirements (If any, Minebea will individually contact suppliers to make special requirements.) Special Requirements (with Form and Annexes A~E) Minebea will individually make requirement to supplier with regard to customer requirement not specified in this standard. 1

3 Preface 01. Positioning of the Minebea Group Green Procurement Standard As a part of the product chemical substances management performed by the Minebea Group (Minebea), the Minebea Group Green Procurement Standard (Standard) is issued to ensure that no prohibited chemical substances are used in Minebea products. The Standard specifies chemical substances that must not be present in purchased parts and materials, those that must not be used in manufacturing processes so as to avoid contamination of parts and materials, and those that are subject to data sharing, as well as the procedures for managing these substances. Every effort shall be made to share this Standard throughout the Minebea organization and with all its suppliers. 02. Basic Policy (1) Restricted or Prohibited Chemical Substances specified by this Standard This standard basically specifies the chemical substances that have been selected in light of various countries laws and regulations as well as customer requirement for restricting or prohibiting the use of chemical substances in products. Note that this Standard does not encompass all regulatory controls for chemical substances that are currently in effect throughout the world. (2) The Management of Chemical Substances in Products The supplier should appropriately establish the management system of chemical substances in products. When establishing the management system of chemical substances in products in the supplier, the supplier may refer to the standards below. JIS Z 7201:2012 Management of Chemical Substances in Products Principles and Guidelines ISO 9001:2008, etc Quality Management System ISO 14001:2004, etc Environment Management System 03. Operation Policy Operation of the management of chemical substances in products is as follows; (1) Management of chemical substances contained in parts and materials, regulatory compliance of Minebea products, and fulfillment of customer requirements shall be performed using the data provided by suppliers. (2) Minebea does not permit the use, inclusion, or commingling of any prohibited chemical substances in Minebea products. If regulatory limits for a chemical substance are specified in this Standard, the chemical substance must not be included in excess of the specified values, even if the chemical substances are impurities. (3) Minebea may require suppliers to restrict the use of certain chemical substances in their manufacturing processes even when the products do not contain the chemical substances subject to restriction. (4) This Standard shall not apply in matters directly related to the lives and safety of people, in cases where no alternative technologies are available, or in cases where problems of reliability will arise, and only when it is specifically instructed by Minebea. (5) Minebea shall set its own regulatory limits for chemical substances that exist in nature, can be measured quantitatively and need to naturally in measurable quantities to control the concentration level of impurities with due consideration given to the detection threshold of the measuring devices and margin of error. (6) Compliance with the REACH Regulation shall be accomplished via the data sharing system for chemical substances provided by JAMP, the data of supplier form and Minebea form. 2

4 1. Objective The purpose of this Standard is to specify chemical substances prohibited in raw materials, parts, components, packing/packaging materials and indirect materials procured by Minebea. It establishes standards and procedures for distributing information about such chemical substances, requires suppliers to conduct investigations into chemical substances used in their products and stipulates proper management of chemical substances in order to ensure compliance with all regulatory as well as customer requirements. 2. Scope of Application This standard shall be applied to parts, materials and others procured by Minebea and attached to our products Scope Applicable to Parts and Materials (1) Raw materials (e.g. steel, plastic pellets, etc.) and processed goods of raw materials (2) Parts, components (e.g. electric and electronic parts, mechanical parts, semiconductor devices, printed circuit boards, etc.) (3) Packaging materials (those procured by Minebea and third parties to which Minebea contracts production of its products) (4) Accessories, service parts and instruction manuals (5) Indirect materials (e.g. adhesive tapes, soldering materials, adhesives, paints, varnishes, marking materials, anti-rust oil, grease, impregnated oil etc.) (6) Repair parts (repair parts for shipped products specified by Minebea) (7) Customer-specified items purchased by Minebea (may be exempt from this Standard due to contracts with the customer) (8) Other parts used for the product are needed to take action other than specified as above 2-2. Scope Applicable to Products (1) Products designed, manufactured and sold by Minebea (2) Products the design and production of which Minebea contracts to supplier and sells as Minebea products. Detail of entrusting design and production is determined by contracts with the subcontractor Exemption The following items are exempt from the scope of this Standard. (1) Parts and materials used in products directly related to the lives and safety of people in the fields such as aerospace, traffic/transportation, medical applications, etc, and specified by Minebea. (2) Chemical substances that are exempt from EU RoHS and ELV Directives, and other regulations. (Those that are not exempt shall be specified in this Standard.) (3) Goods supplied by customers. (4) Products that are excluded from the scope of this Standard as agreed upon by Minebea customers. (5) Parts and materials specified by Minebea that are used for equipment manufactured by and used within Minebea and cannot be replaced with alternative technologies, or items which are required for safety and reliability. (6) Packaging/packing materials used by suppliers to transport/protect parts and materials when they are to be delivered to Minebea. (7) Other items defined by Minebea. 3

5 3. Definitions This section includes definitions of terms used in this Standard Inclusion Inclusion means that chemical substances remain on products, parts and others by addition, filling, mixture and adhesion. It does not matter whether chemical substances are included intentionally or unintentionally Impurities Impurities are chemical substances that are contained in natural materials and cannot technically be removed by the refining process of the material for industrial use, or chemical substances that are generated in refining or synthesis processes and cannot technically be removed Intentionally added Intentionally added means that chemical substances remain on products, parts and others by deliberate addition or filling in order to provide a specific characteristic, appearance, property and quality. Impurities is not treated as Intentionally added Legal Limits and Minebea Regulatory Limits Legal limit: Maximum weight ratio or content of a legally prohibited or restricted chemical substance allowed in parts and materials Minebea regulatory limit: Maximum weight ratio or content of a chemical substance that should not be exceeded unless such substance is used intentionally. Minebea regulatory limits as well as Legal limits are specified in this standard or Attachment. If Minebea regulatory limit or Legal limit is specified, the contained concentration of chemical substance should not be exceeded the limit. If the value of Minebea regulatory limit or Legal limit is not specified, intentional use of chemical substance is prohibited. Threshold levels use same meaning of Legal limit value Homogeneous Material Homogeneous material means a material that is throughout uniform composition and cannot be disjointed into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. Examples of homogeneous materials: plastics, ceramics, glass, metals, alloys, paper, board, resins and coatings. Source: Refer to RoHS directive (2011/65/EU) Article 3 Definition and FAQ of RoHS directive Certificate of Non-Use of Prohibited Chemical Substance A Certificate of Non-Use of Prohibited Chemical Substance certifies that the supplier does not intentionally use prohibited chemical substances and that the concentration levels of chemical substances do not exceed legal limits and/or Minebea regulatory limits Report of Analysis Results A Report of Analysis Results enables suppliers to provide the results of analysis as well as information on the part on which the analysis has been performed via chemical structure diagrams and bill of material Analysis Report An Analysis Report is a copy of report issued by an analysis laboratory. The information required for an Analysis Report is separately specified. Minebea has a specified form, but if the supplier has another specified form, the supplier may submit the Analysis Report with its own form ISO/IEC Certified Body An ISO/IEC Certified Body is an analysis laboratory that is certified to meet general requirements of ISO/IEC for the competence of testing and calibration laboratories by a third party certification body IEC IEC: International Electrotechnical Commission IEC 62321: Electrotechnical products - Determination of levels of six regulated substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers) REACH Regulation REACH Regulation refers to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorization and Restriction of Chemicals. 4

6 3-12. SVHC (Substances of Very High Concern) Substances of Very High Concern (SVHC) are chemical substances identified through the procedure specified in Article 59 of the REACH Regulation as well as those that meet the criteria specified in Article 57 of the REACH Regulation Halogen-free Parts and materials are halogen-free when concentrations of both chlorine and bromine are less than 0.09 wt% (900 mg/kg), with total chlorine/bromine content being less than 0.15 wt% (1500 mg/kg). Since there are currently no legal regulations that specify standards for halogen-free materials, industry standards are commonly used. Minebea customers may have different halogen-free requirements including halogens subject to control and their threshold limits JAMP JAMP refers to the Joint Article Management Promotion-consortium. URL: JAMP Guidelines for the management of chemical substances in products Guidelines for the management of chemical substances in products published by JAMP are written in compliance with Japan Industrial Standards JIS Z 7201:2012 Management of Chemical Substances in Products Principles and Guidelines JAMP AIS (Article Information Sheet) JAMP AIS is a tool developed by JAMP to facilitate data sharing related to chemical substances contained in products. JAMP AIS is designed to provide downstream users with specific data regarding an article such as mass, part, material, and presence of regulated substances, material name, quantity and concentration per article JAMP MSDSplus MSDSplus is a tool developed by JAMP to facilitate data sharing concerning chemical substances, preparations, and mixtures contained in products. It contains names of relevant laws and regulations, information on the presence of controlled chemical substances as well as names, CAS numbers and concentrations of chemical substances. MSDSplus is used along with the SDS (safety data sheet) / MSDS (material safety data sheet) CAS Number CAS numbers are unique numerical identifiers for chemical substances assigned by the Chemical Abstracts Service (CAS) for its chemical substance registry system. 4. Prohibited Chemical Substances Prohibited chemical substances that are prohibited from being used or included in parts and materials procured by Minebea are specified in the attached Prohibited chemical substances list and List of Prohibited chemical substances requested by customer. Prohibited chemical substances are specified separately into the Prohibited chemical substances list and List of Prohibited chemical substances requested by customer. Prohibit requirements may apply to chemical substances that are used in manufacturing processes (e.g. cleaning, mold release, rust proofing agents, etc.) but not contained in parts and materials Attachment I Prohibited Chemical Substances Prohibited Chemical substances (Attachment I) are chemical substances that are banned or restricted to manufacture, import or use by relevant domestic and overseas laws and regulations, international treaties and agreements and can be included in Minebea products. Prohibited chemical substances in this list are prohibited immediately except the following cases; (1) Chemical substances are exempted from EU RoHS and ELV Directives, and other regulations. (2) Effective date of ban is specified. Section of Restriction is specified applications and use example. Cadmium and its compounds and Lead and its compounds are specified strict limit value than laws and regulation value for each application Attachment II Prohibited Chemical Substances by Customer Except 4-1. Prohibited Chemical substances (Attachment I), chemical substances which are prohibited by customer requirements is specified in List of Prohibited Chemical Substances by Customer requirement. This list includes substances that are restricted by laws and regulations, and restricted to apply to. 5

7 If new substance is listed in List of Prohibited Chemical Substances by Customer requirement, Minebea will submit and request with drawings, specifications and special requirement form. Also if chemical substance which is not listed in List of Prohibited Chemical Substances by Customer requirement, Minebea may request individually to correspond to customer requirements Exemption by laws and regulations Chemical substance which is exempt from laws and regulations is exempt from the scope of this Standard. Representative exemptions from laws and regulation are; (1) EU-RoHS (2011/65/EU) ANNEX III and ANNEX IV (2) ELV directive (2000/53/EC) ANNEX II If expiry date is specified for exemption, the exemption can apply till the expiry date, but the expiry date may be shorten by customer request or Minebea s decision, in case that Minebea requests it Suppliers individually Ban on the Use of Recycled Plastics Suppliers are prohibited from supplying Minebea with parts and materials made partially or entirely from plastic materials that are sold as recycled materials. However, use of regrind (see note) generated in suppliers production processes is permitted to the extent that such use of regrind does not exceed the limit specified by the UL standard or Minebea. Note: Regrind materials are ground or granulated plastic waste materials such as runners, sprues and non-contaminated rejected parts that are produced in suppliers production processes to be recycled with virgin materials. UL 746D limits the use of regrind materials to 25% unless otherwise specified. Materials must meet this requirement in order to be UL approved. 5. Information of Chemical Substances for Submission Except Attachment I Prohibited chemical substances, information of chemical substances which are needed by regulations and/or industry standards is provided by suppliers and through supply chain, and is specified in Attachment III Information request chemical substance for submission. Minebea will make individual requests to suppliers with regards to related regulations, emergency regulations, and Minebea customer requirements not specified in this Standard. 6. Operation 6-1. Basics of Operation Method (1) Minebea s green procurement activities shall consist of controlling chemical substances contained in parts and materials according to this Standard. With regard to implementation, in principle, the supplier and Minebea shall conclude Basic Transaction Agreement (and supplemental agreements if necessary) and exchange a purchase specification (or equal specification document). (2) Minebea shall confirm that the products are regulatory compliant and fulfill customer requirements based on the various reports, Certificate, and other data submitted by the supplier. (3) This Standard was created to fulfill domestic and foreign laws and regulations, as well as customer requirements, but does not necessarily cover all related laws or customer requirements. Consequently, matters not covered by this Standard shall be handled individually as special requirements, and Minebea may ask suppliers to submit reports, Certificate and data accordingly. (4) Minebea s regulatory limits for Attachment I prohibited chemical substances specified in this Standard have been set in accordance with the current technology levels and levels required by the majority of its customers. When an even stricter standard is required by Minebea s customers, Minebea will request suppliers to submit reports, Certificate and data accordingly. (5) Control of chemical substances contained in products should follow JIS Z 7201:2012 Management of Chemical Substances in Products Principles and Guidelines or JAMP Guidelines for the Management of Chemical Substances in Products. Minebea will audit the supplier, if necessary, to verify the management status by utilizing documentations or visiting the supplier Obtaining Chemical Substance Information from Upstream Suppliers 6

8 To verify and ensure the control of chemical substances contained in products, suppliers are asked to obtain information on chemical substances from upstream suppliers and provide such information to Minebea Control of Changes Minebea uses quality control procedures and rules to control changes related to chemical substances contained in products. The documents required for reporting changes vary depending on the types of change. Contact the Minebea department that has placed an order with your company for approval before making any change related to a chemical substance, such as 4M Occurrence of Abnormalities or Noncompliance (1) In the event that any abnormality or noncompliance occurs with regard to the control of chemical substances contained in products at your company or your company s supplier (including minor cases), immediately send written notification to the Minebea department that has placed an order with your company. (2) In the event that any abnormality or noncompliance occurs with regard to the control of chemical substances contained in products during Minebea s or its customer s receiving inspection (including minor cases), provide data and information to Minebea to investigate and verify and, if necessary, take all necessary corrective measures from investigation of causes to prevention of recurrence Avoiding Contamination Take appropriate measures to prevent contamination by commingling, contact or others throughout the production processes of parts and materials (e.g. reactions, synthesis, joining, mixing, molding, and assembly). Likewise, take necessary measures for preventing the contamination of molds, tools, machinery and equipment as well as indirect materials. Parallel production which uses chemical products and parts containing restricted chemical substances under laws and regulations in the same factory building is prohibited by Minebea. If parallel production exists, take appropriate measures to prevent contamination, and make arrival process, production process and shipment process independent each other Data Sharing The information that you provide may be disclosed, in whole or in part, in Minebea s responses to its customer s requests. With regard to any supplier s proprietary information, contact the Minebea department that has placed an order with your company for individual consultation Requirements Not Stipulated in This Standard Depending on the customer s request, Minebea may request separate, individual surveys regarding chemicals not stipulated in this Standard and detailed information. Minebea may also request separate surveys if they become necessary for chemical substances newly regulated due to revisions of/additions to regulations, or if such survey regarding chemical substances is requested by government/administrative agencies Detailed List of Chemical Substances The Detailed List of Chemical Substances, which lists general chemical substances by category of banned chemicals, is available. Note that the list does not encompass all chemical substances. The list of JAMP declarable substances is available following Web site. JAMP Download page: 7

9 7. Data Requested for Submission Minebea s green procurement is based on certifying to our customers, using the related data submitted by suppliers, that the chemical substances contained in our products are being managed. Information we ask suppliers to submit includes documents for sharing data on chemical substances contained in products, Certificate of Non-Use of Prohibited Chemical Substance, Reports of Analysis Results, Analysis Reports, SVHC Survey(REACH regulation), SDS(MSDS), Inspection Certificate, and component sheets, all of which are listed in Table 1 and 2. The information required for these documents is explained in sections 8 through Request for submission data (1) Submit the required data to Minebea promptly and by the specified deadline. (2) Submit data to Minebea Procurement Division that requested submission of data. Various Minebea business units may request you to survey the same parts and materials. Submit your data to each individual business unit. (3) Send data in electronic form by , electronic file, etc. a) Use Excel or Word as the electronic file form for submitting the Environmental Hazardous Substances Survey Report and Report of Analysis Results. The communication methods used for AIS and MSDSplus provided by JAMP shall be enabled by XML (extension.xml). b) When submitting copies of the Non-Use Certificate, Non-Use Certificate Lists, Analysis Reports, SDSs or Inspection Certificate, use Adobe Acrobat PDF. c) Contact us beforehand when you send the data by fax or mail. (4) If submitted forms fulfill Minebea requirements, supplier may use their own form. When Minebea requests supplier to submit AIS data, submit the data using Excel file with XML (extension.xml). Utilize the form Minebea prepared if supplier does not prepare form. Minebea will contact you separately when submission of data in the forms specified by our customers is necessary. Minebea will ask supplier to cooperate with us when we ask you to register IMDS on automobile-related component. (5) Other Submit data in a way that makes verification and the relationships between the various documents simple. Following below; 1) to add control numbers and create list. 2) to standardize names of file names. 3) to create explanatory text and attach it. Submit legible and clear data used PDF format. Title of the submitted documents Certificate of non-use Prohibited Chemical Substances Results Analysis data Reports of Analysis Table 1: Submitted documents on Chemical Substances Contained in Product Prohibited substances and the information provided chemical substance list Attachment I Attachment II Attachment III Submission is necessary. RoHS regulation: Submission is necessary. Others: Need or no-need of submission will be notified. Need or no-need of submission will be notified. Need or no-need of submission will be notified. Need or no-need of submission will be notified. Need or no-need of submission will be notified. Form Supplier s form or form provided by Minebea. Supplier s form or form provided by Minebea. Analytical laboratory REACH regulation/ SVHC survey The latest information of SVHC(Attachment III) Submission is necessary. Supplier s form or form provided by Minebea. 8

10 Table 2: Documents for communication information on Chemical Substances Contained in Product Target Type of the submitted documents Title of the form Form Chemical substances and/or mixture (preparation) Article (product formed into a shape) Information for laws and regulations MSDS plus JAMP Safety information: Chemical substances and/or mixture Products Information: Metals and metal compounds SDS (MSDS) Inspection Certificate Component Sheet Issue source Issue source Information for laws and regulations AIS JAMP Submission is necessary for constituent data 100% Environmental Hazardous Substances Survey Report Composition Table Component List Component Drawing Supplier s form or form provided by Minebea. Minebea s form Supplier s form 8. Detail of Data Requested for Submission 8-1. Certificate of Non-Use of Prohibited Chemical Substance Certificate of Non-Use of Prohibited Chemical Substance (hereinafter called Non-Use Certificate), certifies that suppliers do not intentionally use prohibited chemical substances and that such substances do not exceed legal limits or Minebea regulatory limits. The Non-Use Certificate is designed for Attachment I Prohibited Chemical Substances. In cases where any of the Attachment I prohibited chemical substances is exempt from the requirements of EU RoHS Directive or ELV Directive, enter the substance name, part, and legal basis of exemption (exempt usage or Annex No.). Submission of Non-Use Certificate for Attachment I Prohibited Chemical Substances is necessary. Complete and submit Form 1-4, Non-Use Certificate List, when reporting on multiple parts and materials. Minebea prepares Non-Use Certificate List as data Analysis Report (1) Chemical substances to be reported Chemical substances to be reported in the Analysis Report are the substances defined as RoHS (2011/65/EU) ANNEX II of Attachment I Prohibited Chemical Substances. (Refer to Table 3 for Analysis Items and Application portion.) For packaging and packing material, Minebea requests Analysis Report individually. Adhesives, paints, inks, etc should be analyzed after dry (same condition used in products). Table 3: Applicable Portions and Analysis Items for Analysis Report for Each Homogeneous Material ( : applicable, -: exempt) Analysis Items Parts and materials, Cd Pb Cr 6+ Hg PBB PBDE Phthalates applicable portion Plastic resin (including rubber), ink, pigments, dyes, paints, grease, oil, adhesives etc. Metals, metal alloys, plating, ceramics, glass etc Packaging/packing materials

11 (2) Analysis data to be submitted Submit the following documents as a set. (a) Structural drawing and bill of material Structural drawing which shows the internal condition of parts to clarify the portion being analyzed, the chart of material composition associated with the structural drawing. The form of structural drawing and chart of material composition is at the supplier discretion. When the parts are composed of a single material, raw material, pellets, film, sheet, etc. (excluding laminated materials), there is no need to submit a structural drawing and chart of material composition. (b) Report of Analysis Results A submission of this report is at the supplier discretion. But if Minebea requests to submit it, submit a report outlining the analysis results for each homogeneous material in parts and materials with Structural drawing and bill of material. (c) Analysis Report Submit the report which fulfills the (5) Items that must be entered in Analysis Report with legible and clear PDF. (3) Validity period and updating management for Report of Analysis Results and Analysis Report The effective period of Report of Analysis Results and Analysis Reports is one year from the date of measurement. We ask you to provide annual updates. If you cannot update annually, submit a formal document explaining the reasons (statement explaining supplier s opinion, reason etc.). Once we have reviewed the submitted document, we will contact you and provide you with instructions to follow. (4) Language of Analysis Report Analysis Reports shall be written in English or Japanese. However, when submitting Analysis Reports in Japanese, you may be asked to obtain a separate English translation depending on our customers requirements. (5) Items that must be entered in Analysis Report Enter the following items in the Analysis Report Sample name (to be defined so that it can be related with the submitted data for each homogeneous material) Sample preparation method: official method name, or name of the method if different from the official method Measurement method: measurement method name or official method name Name of analysis laboratory, corporate seal Names and signatures of a responsible person at the analysis laboratory and a person who measured Date of issue, date of measurement Measurement results (if N.D., or not detectable, enter quantification limit value) Analysis flowchart: document that indicates the flow of analysis, such as sampling, preparation and measurement operations. Use Form 4, Sample Analysis Flow Chart, as a reference when preparing an analysis flowchart. If sample preparation involves dissolution, note that the sample was completely dissolved (this can be recorded on the analysis flowchart). Image of sample (The image must be clear enough to enable identification of the sample and the areas measured.) (6) Submission of Analysis Reports from ISO/IEC certified laboratories Requests will be made in cases where an Analysis Report by the ISO/IEC17025 certified laboratory is required to meet customer requirements. (7) Designation of analysis laboratory and analysis method Analysis method for substances specified in the EU RoHS Directive must be in compliance with the latest version of IEC Ask a laboratory capable of analyze substances by this methods. An analysis laboratory or method may be designated in order to meet our customer s requirements. Requests will be made individually as needed. Screening analysis by XRF is not permitted as analysis data for submission. 10

12 (8) Request of resubmitting Report of Analysis Results In the event of noncompliance due to levels in excess of regulatory limits detected during an incoming inspection by Minebea or its customers, you will be asked to perform an analysis again and resubmit the Report of Analysis Results and Analysis Report. Requests will be made individually as needed. (9) Requests for submitting Analysis Reports other than RoHS (2011/65/EU) ANNEX II If requested by Minebea s customers, you may be asked to submit Analysis Reports for substances other than RoHS (2011/65/EU) ANNEX II. Requests will be made individually as needed. (10) Method for obtaining Analysis Reports Obtain Analysis Reports that meet this Standard or equivalent requirements from your suppliers SVHC survey report in REACH regulation SVHC s in REACH are subject to continual addition, and suppliers should be responsible for ensuring that they are the latest version. The submission of this report is necessary. Submit this report using Section 9 Communicating Information on Chemical Substances in Product with Supplier s form describing the latest information, JAMP s form, or Minebea s form. 9. Communicating Information on Chemical Substances in Product Suppliers are asked to submit the information of chemical substances in products using JAMA/JAPIA Standard Material Datasheet, suppliers form, or form provided by Minebea. If suppliers provide the information through their website, Minebea discusses with suppliers individually on this matter Data sheets designed by JAMP JAMP provides the following data sharing forms. (1) MSDSplus: chemical substances and mixtures (preparations) (2)AIS: articles Use these latest tools available from JAMP for free for data sharing When Using JAMP Tools Report information on MSDSplus and AIS referring the preparation guide and operation manual provided by JAMP Selecting File Form and Applicable Standards for JAMP Forms Always use the XML (extension.xml) format when submitting data via JAMP MSDSplus or AIS SDS (Safety Data Sheet), MSDS (Material Safety Data Sheet) Manufacturer s SDS (MSDS) is issued for materials such as chemicals, resins, adhesives, pigments, paints, and inks etc. Obtain and submit them Inspection Certificate Manufacturer s Inspection Certificate are issued for materials such as metals, metal alloys, and other processed goods etc. Obtain and submit them Component Sheet If a component is multiple and composed of several kinds of part, prepare and submit a component sheet, relating the SDS (MSDS), Inspection Certificate, and other report data with the composing part names and data numbers using forms which are provided by Supplier or Minebea Environmental Hazardous Substances Survey Report List, Composition Table The department placing the order may request that the all data (chemical substance name of raw material and parts) be provided via Minebea s Environmental Hazardous Substances Survey Report List form. Instead of Minebea s Environmental Hazardous Substances Survey Report List form, supplier may submit the communicating information on chemical substances in sections 9-8. When you cannot provide data on all constituents of a part to us, contact the Minebea department that placed the order with you. Copies of the Environmental Hazardous Substances Survey Report List form and sample form can be obtained from the Minebea department that places an order with you or can be downloaded from Minebea Web site. 11

13 9-8. Composition Table, Component List (Bill of Material), Component Drawing Supplier may submit the communicating information on chemical substances using supplier s form of Composition Table, Component List (Bill of Material) and Component Drawing on all constituents of a part. When you cannot provide data on all constituents of a part to us, contact the Minebea department that placed the order with you Composition Table If raw material (Alloys, resin pellets, solders, adhesives, paints, varnish, etc.) is used, you may make list including chemical substance name, percentage of constituent, CAS No., and applications. This list can be used as 9-6. Component Sheet Component List (Bill of Material) If parts, component (e.g. electric and electronic parts, mechanical parts, semiconductor devices, printed circuit boards, etc.) are used, you may make list including item such as chemical substance name, percentage of constituent, CAS No., and applications Component Drawing Component drawing shows a section containing certain substances that are deemed to be uniform in property. If the position relations of the part cannot be judged with component list and Constituent table, please submit the component drawing. If the position relations of the part can be judged by a catalogue or sketch, you may submit these documents instead of component drawing Submission using supplier s form If submission of information is using supplier s form, information should be same as AIS and MSDSplus of JAMP tools. 10. Important Information Concerning Packaging/Packing Materials Packaging/packing materials purchased by Minebea should be complied with Attachment IV : Heavy metals regulations in packaging and packing material in EM10507 Attachment. Packaging/packing materials used by suppliers to transport/protect parts and materials when they are to be delivered to Minebea are not subject to the requirements specified in Sections 7 through 9. However, suppliers shall observe the following to ensure smooth disposal and recycling of packaging materials within Minebea. Heavy metals such as cadmium, lead, hexavalent chromium and mercury shall be less than 100 mg/kg (ppm) in total. Plastic tapes and metal staples (large staples) shall not be used. Foam polystyrene shall not be used (excluding reusable container boxes). Contact us when it is to be used to protect parts and materials. PVC packaging/packing materials shall not be used (excluding reusable container boxes). 11. Additional rules The latest information of procurement standard, prohibited substances and etc., please visit the Minebea s web site Corporate>Company>Procurement> Green Procurement (Environmental Activities) Additions, changes and correction of procurement standard, prohibited substances list, etc. publish on the Minebea s web site, too. Additions, changes and correction of contents become effective with an appointed date. The additional contents become effective a placed change, correction with an appointed date. Website: 12