Global RoHS Compliance for Home Appliance Manufacturers

1. Global RoHS Compliancefor Home Appliance Manufacturers ASTM International Technical Committee A05 – Metallic-Coated Iron and Steel Products May 23, 2007

2. Outline • Whirlpool Corporation Overview • RoHS Overview • Current and Pending RoHS Programs • Policy Implications • Compliance with RoHS • Conclusion

3. Whirlpool Corporation Overview • Largest global manufacturer and marketer of major home appliances • Annual sales of more than $18 billion • 73,000 employees • Over 70 manufacturing and technology research centers around the globe • Market Whirlpool, KitchenAid, Maytag, Jenn-Air, Amana, Brastemp, Bauknecht, Consul and other major brands to consumers in more than 170 countries. • Additional information at www.whirlpoolcorp.com.

4. Whirlpool Global Operating Platform #1 N.America • $12 B Sales • 24 Plants #4 Europe • $3.4 B Sales • 13 Plants $18 B Revenues 73,000 employees #1 Global Share #1 Global Brand #1 L.America • $2.4 B Sales • 5 Plants Asia • $457 M Sales • 6 Plants Leading an $80 Billion Global Industry

5. Strategy Supports Best Cost, Best Quality Products

6. What is RoHS? • RoHS regulations generally restrict the following substances in electronic and electrical equipment: • Lead • Mercury • Cadmium • Hexavalent Chromium (Cr6+) • Polybrominated biphenyls (PBBs) • Polybrominated diphenyl ether (PDE)

7. Current and Pending RoHS Programs • European Union – Directive 2002/95/EC • China • Japan • Korea • United States – State of California (limited to video display devices)

8. EU RoHS • Implemented July 1, 2006 • Compliance is the responsibility of the company that puts the product on the market. • In some cases, regulations are inconsistent because each member state adopted separate implementing standards and enforcement procedures. • Contains broad definition of “electronic and electrical equipment” and contains specific exemptions for certain products. • Maximum concentration is 1000 ppm, except Cadmium, which is 100 ppm. • Everything identified as homogenous must meet the requirements.

9. China RoHS • Phase 1 (March 1, 2007): • Marking requirements for electronic information products • Environment-friendly use period must be indicated inside the pollution control symbol. • Phase 2 (timetable uncertain, likely 2008): • Restrictions on Hazardous Substances • Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs, PBDEs • Indications are that major appliances will be excluded, with exception of microwaves. • Replacement parts for appliances will be subject to RoHS if listed on the catalogue.

10. Japan RoHS • Design for Environment (DfE) criteria (promulgated in 2000) • Rationalize use of raw materials • Use recycable and reusable parts • Promote long-term use of products • The cabinet member with jurisdiction establishes basic policy and requirements for industry • Changes effective July 1, 2006: • Manufacturers of computers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must label products to indicate presence of Mercury, Lead, Cadmium, Hexavalent Chromium, PBBs and PBDEs. • Importers of computers, copiers, televisions, refrigerators, washers, dryers, microwaves and air conditioners must meet Design for Environment Criteria (DfE).

11. Korea RoHS • Requirements include: • Restrictions of hazardous substances in electrical/electronic equipment and vehicles • Improvement of materials and structure • Recycling requirements for manufacturers and importers • Mandatory recycling rate • Establishment of an Operation and Management Information System • Implementation date: January 1, 2008 • However, implementation date does not mean anything until decisions are ordered by Presidential Decree.

12. California RoHS • Currently under consideration in the California Legislature • Consistent with EU RoHS regulations, with the following exceptions: • Applies to products manufactured on or after January 1, 2010 • Applies only to mercury, lead, cadmium and hexavalent chromium (PBBs and PBDEs are excluded) • Excludes fixed installations • Twenty-four month grace period for products that lose their RoHS exemption • Exempts products that are refurbished or sold for reuse • Specific exemptions for spare parts • A process for securing exemptions or time extensions • Annual reporting to California Integrated Waste Management Board • Passage is likely in 2007.

13. Compliance Challenges • Obtaining and verifying data on thousands of parts from around the world • Vague and varying regulations • No common reporting because of various states, languages, formats, etc. • Constantly changing parts and components • Lack of best practices for mitigating risk

14. Various End Manufacturers Strategy for RoHS • No single universal approach • Can have thousands of components with multiple homogenous materials each • Too many components for one company to feasibly deal with by itself • Most rely on reporting from supplier base • Letters of compliance • Test data showing compliance • In-house testing • 3rd party testing • Often requested from Tier 1 suppliers, which trickles down the supply chain • Mixed strategies commonly used • Components and suppliers are ranked into categories based on degree of risk • Level of documentation and testing can increase with each category

15. Typical Sampling Strategies for Compliance Testing • No single universal approach • Test every lot of material • Unusual except when lots of material commonly come from unknown production sources (commodity buyers, resellers, etc). • Test once for each part # produced. • Retest when any changes in material, source, or process occurs (similar to PPAP) • Test once for each part # used to produce multiple part #’s (e.g., cutting a larger coil of steel into various smaller width coils). • May apply conformance to all downstream part #’s where no RoHS materials are added • Retest when any changes in material, source, or process occurs. • Typically, any change that occurs that would prompt sending production samples for engineering approval should prompt a decision as to whether a RoHS compliance retest is needed

16. Test Methods • No single universal approach • Many various test methods, highly dependant on the material, processing method, and type of component • 3rd Party Testing • Currently no official accreditation process for 3rd party labs • Some companies have list of labs they use or accept results from • Internal Testing • Many large companies use internal screening tests to reduce the amount of expensive 3rd party tests (~$200-$400/sample) • Portable XRF testers have become very popular • 30 seconds/test • Provides elemental analysis only (cannot tell difference between Cr6+ and Cr) • Not very useful for certain materials • ASTM D6492 or ISO 3613 spot tests for detecting presence of chromate conversion coatings

17. Conclusion • RoHS regulations are being implemented globally, not just in the EU • Despite having extensive global supply chains, manufacturers have developed and are continuing to enhance compliance procedures.

18. Questions or Comments? Contact information: Brandon Bokhart Luke Harms Senior Metallurgical Engineer Government Relations Specialist Whirlpool Corporation Whirlpool Corporation 269-923-4210 202-639-9420 Brandon_J_Bokhart@Whirlpool.com Luke_M_Harms@whirlpool.com