Managing Critical Substances

This directive restricts the use of harmful substances such as lead, mercury, and cadmium in products. It applies to 11 categories of electrical and electronic equipment but as of today excludes products in Category 9, Monitoring and Control Instruments, under which NI products fall. NI voluntarily complies with the directive.

NI began offering RoHS-compliant products in September 2005. NI manufacturing and engineering teams continually work to adapt products to use RoHS-compliant components and manufacturing processes.

The move to RoHS-compliant products is a significant effort because it impacts nearly every step in the supply chain. Therefore, NI will complete this transition over a progressive timeline as new products release and some existing products transition to hazardous substance-free components. At this pace, NI will transition all products before the RoHS directive includes the category under which NI products fall. Through continued efforts to better the environment and exceed regulatory requirements, more than 70 percent of NI products met RoHS requirements in 2011.

All products released in 2011 were RoHS-compliant, with the exception of a few select products. Starting in 2007, each exception case required officer-level approval. In some instances, high-demand products require components that are not available in a RoHS-compliant version. After these products release, NI adds them to the list of products pending a transition to RoHS compliance.

In addition to the far-reaching impact on the supply chain, NI faces the following challenges in the process of eliminating hazardous substances from its products:

Organizations such as the Environmental Protection Agency (EPA) have found that the replacement options for certain hazardous substances may have an environmental impact equal to or worse than the original hazardous substance. To mitigate this issue, NI is actively involved with numerous trade organizations around the world. Through involvement with these organizations and close relationships with suppliers, NI stays at the forefront of both advanced technological developments in materials and compliance with worldwide regulations of hazardous substances. For more information, see the full EPA report.

Regulations in this area evolve rapidly. NI is a member of the Test and Measurement Coalition and is providing feedback on the revision of RoHS currently under review and planned for publication in 2012.

View the full text of the RoHS directive. For more information about NI compliance with RoHS, contact rohs@ni.com.

Refer to the following NI resources to learn more about the RoHS directive.

In 2006, the European Parliament and the Council adopted Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH). One of the regulation’s primary objectives is to protect the environment from harmful substances.

The scope of the REACH regulation differs from RoHS in that REACH is not limited to electrical and electronic equipment. REACH requires manufacturers and importers of substances and preparations to register the substance or preparation before placing it on the market if it meets certain criteria:

The Substances of Very High Concern Candidate List and Annex XIV of REACH (the list of substances subject to authorization) drive notification, authorization, and restriction requirements. Once a substance has been added to the Candidate List, requirements for customer notification apply immediately. Once a substance on the Candidate List is selected to be added to Annex XIV, authorization requirements are imposed on that substance. At some point after the list of substances for authorization is published, the included substances may also be restricted.

As a producer of articles—not substances or preparations—NI is not required to register any substances or preparations. NI does not produce or import chemical substances in excess of 1 tonne per year, and NI products do not release any substances into the environment during normal and foreseeable conditions of use.

NI is required to comply with downstream users’ obligations. To accommodate this, NI is working closely with its supply chain as new substances are added to the candidate list. A list of NI products that contain substances of very high concern (SVHCs) in concentrations greater than 0.1 percent wt/wt can be found here. For additional information on NI REACH initiatives or specific product information related to REACH, contact reach@ni.com.

In 2010 the US Congress passed the Conflict Minerals Trade Act as part of the Dodd-Frank Financial Reform legislation. The law’s aim is to curb violence in the Democratic Republic of the Congo and surrounding regions by restricting the use of certain minerals originating in rebel-controlled mines. These substances include the base minerals for gold, tantalum, tin, and tungsten.

Most NI products contain at least one of these substances and fall into the scope of the law’s requirements, which state that any US company that uses these minerals for the functionality or production of its product(s) will be required to disclose details on the origin of these substances in its annual report to the SEC. NI is obligated to begin disclosing this information for fiscal year 2012. To meet the law’s obligations, NI started working with its supply chain in 2011 to understand the origin of these minerals used in NI products.