Managing Critical Substances

National Instruments is committed to producing environmentally friendly products as part of the NI Hazardous Substance Reduction initiative, a voluntary program modeled after the European Union Restriction of the Use of Certain Hazardous Substances (RoHS) directive. As part of this commitment, in 2012 NI implemented a system for managing environmentally sensitive materials in NI products.

RoHS Compliance

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. NI products fall under Category 9, Monitoring and Control Instruments. Some Category 9 products will be required to comply in 2014, with a subcategory for industrial and professional products being required to comply in 2017. NI plans to fully comply with the directive by the appropriate dates.

Timeline

NI began offering RoHS-compliant products in 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, the transition of NI products will be complete before the RoHS directive includes the category under which NI products fall. Through continued efforts, more than 84 percent of NI products met RoHS requirements in 2012.

All products released in 2012 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.

Challenges

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 works through this organization to refine legislation.

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

Resources

Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH)

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:

  • Products imported or manufactured in quantities of 1 tonne annually
  • Products intended to be released under normal or reasonably foreseeable conditions of use (for example, printer cartridges)

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.

Conflict Minerals Trade Act

In 2010, the United States enacted Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act to address humanitarian concerns in the Democratic Republic of the Congo (DRC). The concerns stem from four minerals obtained from rebel-controlled mines in the DRC region—gold, tantalum, tin, and tungsten. The law and subsequent rules published by the US Securities and Exchange Commission (SEC) require publicly traded companies to disclose the following information starting for fiscal year 2013:

  • Which products require the four minerals for functionality or manufacturing
  • The presence of any of the four minerals that originate from conflict sources
  • The efforts taken to determine the origin of the minerals used in products

NI has a policy to avoid purchasing components that contain minerals obtained from conflict sources. NI also contracts with third parties to collect additional details on the sources of NI components containing conflict minerals. Moving forward, all new suppliers to NI will be assessed for their ability to provide reliable data regarding the country of origin for conflict minerals. In the event that minerals from conflict sources are found in the NI supply chain, appropriate actions will be taken in a timely manner to resolve the situation. NI expects its suppliers to react the same way and has communicated this policy to all suppliers.