Corporate Responsibility

Product Content and Regulatory Compliance

Related Links

CA Transparency in Supply Chains
Disclosure
(updated 24-Apr-2012)
Conflict Minerals Policy (updated 17-Apr-2014)
Conflict Minerals Report (updated 30-May-2014)
EICC Applicant Member (updated 06-Sep-2012) 
Environmental Policy (updated 03-May-2013) 
REACH Policy (updated 17-June-2014)
Environmental Certifications 

TriQuint prides itself on being a good environmental steward by creating products that are more Earth friendly. We constantly strive to reduce the size and energy usage of our products to reduce their environmental footprint.

Our Product Compliance Team monitors new regulations around the world and works with our industry partners to ensure that we and our suppliers provide our customers with products that meet the highest manufacturing expectations. This mission includes compliance with laws, regulations and initiatives such as RoHS, REACH, conflict minerals and social responsibility. Contact TriQuint at rohs_info@triquint.com if you have any questions regarding the product compliance of any TriQuint products.

The expandable sections below give more detailed information regarding TriQuint's work in each of these areas:

  • RoHS Directive (2002/95/EC)
  • REACH Regulation (EC) No 1907/2006
  • Conflict Minerals
  • Social Responsibility

Global Environmental Regulations

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RoHS Directive (2002/95/EC)

The European Union RoHS Directive (2002/65/EC) went into effect on July 1, 2006. This directive was modified extensively in 2011 (2011/65/EU) and the recast version can be found here. You can follow changes since the recast of the RoHS Directive here. The RoHS Directive bans the use of certain hazardous substances in Electrical and Electronic Equipment (EEE), unless that use is covered by a listed exemption. If a use is not covered by an exemption, the following maximum concentrations are allowed at the homogeneous material level shown here in Table 1.

Table 1. Maximum Concentration Values (MCVs) from 2011/65/EU

RoHS Restricted Substance Allowable Limit
Cadmium and its compounds 100 ppm (0.01 weight %)
Mercury and its compounds 1000 ppm (0.1 weight %)
Hexavalent chromium and its compounds 1000 ppm (0.1 weight %)
Lead and its compounds 1000 ppm (0.1 weight %)
Polybrominated biphenyls (PBB) 1000 ppm (0.1 weight %)
Polybrominated diphenyl ethers (PBDE) 1000 ppm (0.1 weight %)

 

What is a "homogeneous material"? It is a material that is the same throughout. If you think about a pencil, there are several homogenous materials. Let's work our way from the outside of the pencil to the inside:

pencil

  1. The ink for the printing of the labels
  2. The yellow paint on the outside
  3. The ink on the metal grommet holding the eraser
  4. The metal of the grommet holding the eraser
  5. The eraser
  6. The wood
  7. The graphite (the lead)

So a relatively simple item like a pencil has seven homogeneous materials.

We can apply this same concept to one of TriQuint's parts — for instance, a leadframe packaged semiconductor.

Cross-section image of a leadframe packaged semiconductor

In this part, there are six homogeneous materials:

  1. The gallium arsenide semiconductor (GaAs Die in the figure)
  2. The Die Attach compound bonding the GaAs die to the leadframe
  3. The Leadframe Material (base material)
  4. The leadframe plating (Tin Plating)
  5. The gold bond wires (Au Wires) connecting the GaAs die to the leadframe
  6. The Mold Compound that encapsulates the entire leadframe package to protect everything

TriQuint's more complex parts can have dozens to hundreds of homogeneous materials, and a very complex product like a smartphone, tablet computer or laptop computer may have thousands to tens of thousands of homogeneous materials. Each of these homogeneous materials needs to meet the maximum concentration values listed in Table 1 above.

Although most TriQuint products that are sold into the commercial market meet these maximum RoHS concentration limits, certain products require the use of exemptions to meet compliance. The list of exemptions (which is included in the RoHS Directive as Annex III) is not static, as exemptions are added and removed periodically. TriQuint uses Exemption 7(c)-I for those modules that contain resistors and some capacitors at this time:

  • 7(c)-I – Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound

Under the Recast RoHS Directive (2011/65/EU), exemptions have either a specified expiration date, such as December 31, 2012 for the 7(c)-III exemption, or a general expiration date. The 7(c)-I exemption listed above has a general expiration date of July 21, 2016. These general expiration dates can be found in Article 5, paragraph 2 of the Recast Directive.

TriQuint is working with its supply chain and industry organizations to determine if it is necessary to seek an extension of these exemptions or if the technology has reached the point where the lead can be removed from these components without impacting their quality or reliability.

It is expected that in the next RoHS revision, several new substances will be added to the list in Table 1 above. You can follow the processes for the selection of possible new substances here. Among the probable substances are:

  • Hexabromocyclododecane (HBCDD)
  • Bis (2- ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)

TriQuint does not use any of these substances in its products. TriQuint will closely watch the development of potential new substances to determine if any of these substances are used in our parts and what our plans should be for ensuring compliance.

If there are any questions regarding RoHS compliance, please email us at rohs_info@triquint.com.

REACH Regulation EC No 1907/2006

It is difficult to talk about the REACH regulation without talking about the CLP Regulation. You can learn more about these regulations on the European Chemicals Agency website (ECHA). The full names of these two regulations are:

  • REACH: Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation, which went into effect on June 1, 2007
  • CLP: Classification, Labelling and Packaging Regulation, which went into effect in January 2009

You can find the text of these regulations here. Chemical substances are classified by the Risk Assessment Committee (RAC) according to their hazard under the CLP Regulation, and hazards may be physical or chemical. Examples of chemical hazards are carcinogenicity, mutagenicity, reproductive toxicity, acute toxicity, endocrine disruptor or a Persistent Bioaccumulative Toxin (PBT). Examples of physical hazards are explosive, flammable or oxidizing. Substances are evaluated according to the hazard posed to both human health and the environment. It is important to note that the evaluation of the hazard of a substance does not involve any evaluation of the risk of exposure to a substance.

The generic hazard classifications listed above (carcinogenic, mutagenic, etc.) are further classified as 1A, 1B or 2. To make a simplification, it can roughly be assumed that "1A" means "known," "1B" means "presumed" and "2" means "suspected." Therefore a Carcinogen 1A is a known human carcinogen, which should be largely based on human evidence, while a Carcinogen 1B is a presumed human carcinogen that can largely be based on animal evidence.

It is important to note that the CLP Regulation is about classifying, labeling and packaging substances, and TriQuint does not manufacture or sell substances. TriQuint manufactures and sells articles, which are objects that during production are given a special shape, surface or design that determines their function to a greater degree than their chemical composition. It will become apparent later why we are clarifying the difference between substances and articles.

Now we move into the REACH Regulation. The substance meets the criteria for being classified as a Substance of Very High Concern (SVHC) if during the CLP classification process, the RAC has classified a substance as any of the following:

  • A Carcinogen, Mutagen, or Reproductive Toxin 1A or 1B (referred to using the abbreviation CMR 1A or 1B)
  • A PBT
  • A Very Persistent Very Bioaccumulative (vPvB)
  • An equivalent concern such as an endocrine disruptor

The Member State Committee (MSC) of ECHA is the group that classifies substances as SVHCs.

If a substance is classified as an SVHC and is present in an article to be put on the EU market, then some other considerations must also be met. If more than 1 metric ton (tonne) of the SVHC is put on the market by the manufacturer and the SVHC is present in the article above a concentration of 0.1% (weight to weight), the manufacturer needs to notify ECHA (Article 7 of the REACH regulation). In addition to notifying ECHA, the manufacturer is subject to the notification requirements under Article 33, requiring the manufacturer to notify the customer with sufficient information to allow safe use of the article. The minimum information required to be supplied is the name of the substance.

TriQuint has some SVHCs in our products, but they do not reach the 0.1% (weight-to-weight) threshold at the part level. Lead oxide is contained in some glass and ceramic materials in our resistors and in some capacitors (see our RoHS section on this page for RoHS implications on the use of lead oxide). We also have a very small concentration of 4,4'-Methylenedianiline in an adhesive used to glue some lids on some parts. 4,4'-Methylenedianiline has also been listed in Annex XIV of the REACH Regulation for Authorisation, with a sunset date of August 21, 2014. TriQuint has a team working on the elimination of the use of this substance in our products and we expect to meet the sunset date.

TriQuint will continue to watch the Registry of Intentions on the ECHA website to track potential future regulation of substances used in TriQuint products. If there are any questions regarding CLP and REACH compliance, please email us at rohs_info@triquint.com.

Conflict Minerals

TriQuint has been working with its supply chain since 2009 to trace the origins of the conflict minerals derivatives in its products. TriQuint shares the world's concerns about the use of natural resources to fund armed conflict in the Democratic Republic of the Congo (DRC) and is working to ensure that our activities are not contributing to the issue. At the same time, we also want to make sure that our actions do not lead to a ban on all minerals coming from the DRC region, because it would unfairly impact the many legitimate artisanal miners working there.

Dodd-Frank Wall Street Reform and Consumer Protection Act Requirements

It is important to understand the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act signed on July 21, 2010. Sec. 1502 of this law makes certain requirements on companies that (1) report to the Securities and Exchange Commission (SEC) and (2) whose manufactured goods contain metals derived from conflict minerals. If a company meets these two requirements, they need to determine whether or not their use of conflict minerals is contributing to the ongoing conflict in the DRC or adjoining countries (Angola, Congo, Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania and Zambia) — sometimes abbreviated as the "Covered Countries." This determination can be done through a Reasonable Country of Origin Inquiry (RCOI). In their final ruling in August 2012, the SEC intentionally did not prescribe the required actions for an RCOI, as the required inquiry depends on each company's facts and circumstances. However, the SEC gave some general standards that apply to the RCOI:

  • The company must conduct the RCOI in a way that is reasonably designed to determine whether any of its conflict minerals originated in the Covered Countries or are from recycled or scrap sources,
  • The company must perform the RCOI in good faith, and
  • If a company determines that its conflict minerals did not come from the Covered Countries, or are from scrap/recycled sources, it must briefly describe the RCOI it used to reach this determination and the results of the RCOI.
  • The company must file a Form SD with the SEC, which contains a description of their RCOI, its results, and their determination of the origins of the conflict minerals in their products.

If a company determines through its RCOI that the conflict minerals did come from the Covered Countries, it is required to complete a Conflict Minerals Report (CMR) that includes a description of the measures taken to exercise due diligence on the source and chain of custody of its conflict minerals. The due diligence measures must conform to a nationally or internationally recognized framework. TriQuint's Conflict Mineral Program was designed to conform to the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

What are conflict minerals and their derivatives?

The Dodd-Frank Wall Street Reform and Consumer Protection Act defines "conflict minerals" as:

  1. Columbite-tantalum (coltan), cassiterite, gold, wolframite or their derivatives; or
  2. Any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the DRC or an adjoining country.

It is important to note that this definition of conflict minerals means that all coltan, cassiterite, gold and wolframite are conflict minerals, regardless of the source of the minerals. If the source was determined to be located in the Covered Countries, then reporting to the SEC is required, along with the Conflict Mineral Report, as described above.

The common derivatives from these minerals are:

  • Coltan – tantalum
  • Cassiterite – tin
  • Gold
  • Wolframite – tungsten

TriQuint uses all of these metals in its products. Not every product contains every metal, but nearly every product contains at least one of these metals.

What is TriQuint doing?

TriQuint is a member of the Electronic Industry Citizenship Coalition (EICC), and participates in the Conflict Free Sourcing Initiative ("CFSI"). TriQuint uses CFSI tools such as the CFSI Conflict Mineral Reporting Template ("CMRT") to learn the identities of the smelters in its supply chains. We participate on teams within the CFSI that:

  • determine if facilities are smelters,
  • manage the development of the CMRT, and
  • develop best practices for supply chain due diligence.

We use the information gathered from our participation in the CFSI to provide feedback to our suppliers and promote participation in the Conflict Free Smelter Program ("CFSP").

TriQuint has modified its Banned and Restricted Substances Specification and its Terms and Conditions for Suppliers to ban metals from the conflict region that are contributing to armed conflict in the region. It is important to note that TriQuint has not banned all conflict minerals from the Covered Countries — just those mineral sources that are being used to fund armed conflict. TriQuint has also put procedures in place to require all suppliers of new materials and components to investigate their supply chain to ensure that any conflict minerals in their products have not contributed to armed conflict, prior to those materials being used in TriQuint products. TriQuint provides its suppliers with training and tools to build their capabilities regarding the management of Conflict Minerals.

TriQuint has identified several smelters in its supply chain that source from the Covered Countries. TriQuint's knowledge of these smelters is obtained through its direct involvement in the CFSP program and as a condition of this participation the identification of individual smelters as sourcing from the Covered Countries is prohibited by confidentiality agreements. All smelters in TriQuint’s supply chain known or believed to source from the Covered Countries are on the CFSP Conflict Free Smelter Lists. If you wish to know more about how TriQuint gathers this information, please see the explanation in TriQuint's Conflict Minerals Policy.

Since TriQuint is aware that conflict minerals in its supply chain may have come from the Covered Countries, it is required to file a Conflict Mineral Report with the SEC. You can access TriQuint's Form SD and its Conflict Mineral Report here.

If there are any questions regarding conflict metals issues at TriQuint, please contact us at rohs_info@triquint.com.

Social Responsibility

TriQuint is an applicant member of the Electronic Industry Citizenship Coalition (EICC). As such we have adopted the EICC Code of Conduct. We have until August 2014 to become full members, and during this period we are putting systems in place to ensure our supply chain adheres to either the EICC Code of Conduct or an equivalent social responsibility code.

We are also putting other Corporate Social Responsibility (CSR) processes into place, such as launching a permanent CSR team to evaluate TriQuint's compliance with its commitments, and to drive continuous improvement in our CSR practices. We are also completing the E-TASC and EICC-ON Self-Assessment Questionnaires (SAQs), as many of our customers request those two industry-standard forms.

If there are any questions regarding corporate social responsibility issues at TriQuint, please contact us at rohs_info@triquint.com.