Qorvo 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 Qorvo at qorvogreen@qorvo.com if you have any questions regarding the product compliance of any Qorvo products.

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

    • RoHS Directive (2011/65/EU and amendments)
    • REACH Regulation (EC) No 1907/2006
    • Conflict Minerals
    • Social Responsibility

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    RoHS Directive (2011/65/EU and amendments)

    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 %)

     

    In March 2015, the EU Commission added 4 phthalate compounds to the RoHS Directive. The restrictions in Table 2 below will take effect on July 22, 2019.

    Table 2. Maximum Concentration Values (MCVs) from 2015/863/EU
    RoHS Restricted Substance Allowable Limit
    Bis(2-ethylhexyl) phthalate (DEHP) 1000 ppm (0.1 weight %)
    Butyl benzyl phthalate (BBP) 1000 ppm (0.1 weight %)
    Dibutyl phthalate (DBP) 1000 ppm (0.1 weight %)
    Diisobutyl phthalate (DIBP) 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 Qorvo's parts — for instance, a leadframe packaged semiconductor.

    Product Cross-Section

    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

    Qorvo'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 Qorvo 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. Qorvo 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

    If there are any questions regarding RoHS compliance, please email us at qorvogreen@qorvo.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 Qorvo does not manufacture or sell substances. Qorvo 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.

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

    Conflict Minerals

    Qorvo shares in the global concern regarding human rights abuses related to the illegal mining and trade of minerals in the Democratic Republic of Congo ("DRC") and its adjoining countries (Angola, Congo, Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, and Zambia) – collectively referred to as the "Covered Countries." Such activities have been linked to financing armed conflict and violence in the region, and Qorvo is committed to ensuring that our activities do not contribute to the issue. At the same time, we continue to support the responsible sourcing of minerals within the Covered Countries, and will not institute a ban on all conflict minerals coming from the region.

    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. Section 1502 of this law requires annual disclosures from any company that (1) reports 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 Covered Countries. This determination can be done through a Reasonable Country of Origin Inquiry ("RCOI") that is (1) reasonably designed to determine whether any of its conflict minerals originated in the Covered Countries or are from recycled or scrap sources; and (2) performed in good faith.

    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. Qorvo'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 minerals or their derivatives determined by the U.S. Secretary of State to be financing conflict in the Covered Countries.

    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 a Conflict Minerals Report.

    The common derivatives of these minerals are:

    • Coltan – columbium (niobium) and tantalum
    • Cassiterite – tin
    • Gold
    • Wolframite – tungsten

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

    What has Qorvo done so far?

    Qorvo is a member of the Electronic Industry Citizenship Coalition ("EICC"), and is an active participant in the Conflict Free Sourcing Initiative ("CFSI"). We utilize CFSI tools such as the Conflict Minerals Reporting Template ("CMRT") to collect conflict minerals sourcing data from our upstream suppliers, and learn the identities of the smelters in our supply chain. We also participate on teams within the CFSI that:

    • Determine if facilities are smelters;
    • Engage smelters in the Conflict-Free Smelter Program ("CFSP");
    • Manage tools for CFSI members to determine the status of facilities supplied to them by their supply chains;
    • Manage the development of the CMRT form; and
    • Develop best practices for supply chain due diligence.

    Qorvo has identified several smelters in its supply chain that are sourcing from the Covered Countries. Qorvo’s knowledge of these smelters is obtained through its direct involvement in the CFSP Program. 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 our supply chain that are 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 Qorvo gathers this information, please refer to Qorvo's document on Sourcing of Conflict Minerals from the DRC and Adjoining Countries

    If there are any questions regarding conflict minerals at Qorvo, please contact us at conflictminerals@qorvo.com.

    Social Responsibility

    Qorvo is a member of the Electronic Industry Citizenship Coalition (EICC). As such we have adopted the EICC Code of Conduct. Qorvo's Corporate Social Responsibility program forms the basis of our ethical standards, policies, and business practices, and is our guide and management policy for maintaining our status as a good, global corporate citizen. As a global corporation, Qorvo is accountable for our actions and policies that affect people, our local and extended communities, and the environment.

    If there are any questions regarding corporate social responsibility issues at Qorvo, please contact us at qorvogreen@qorvo.com.

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