Seagate s Approach to. Product Environmental Compliance Director. Brian Martin. Seagate Technology April, 2011

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1 Seagate s Approach to Product Environmental Compliance Brian Martin Product Environmental Compliance Director Seagate Technology

2 Seagate products must meet both regulatory and customer requirements RoHS (and RoHS 2) Full substance data is required by customers Lab reports are required to meet customer and regulatory requirements Exemptions are used, but are limited by some customers Customer restrictions are much tighter than RoHS REACH and other new regulations Managing changing SVHC lists is a key challenge FMD (Full Materials Disclosure) is one means of managing REACH Homogeneous material level reporting enables compliance to article-level restrictions Nonregulatory restrictions Customers must meet market and consumer demands Low Halogen, BFR/PVC-free, phthalates, etc.

new regulations Managing changing SVHC lists is a key challenge FMD (Full Materials Disclosure) is one means of managing REACH Homogeneous material level reporting

3 In order to meet regulatory and customer requirements, Seagate collects full substance content data from suppliers Product Bill of Substances (example) Currently restricted and reportable substances Track exempt applications Transparency, credibility RoHS (and RoHS 2) Manage compliance to new/future substance restrictions like REACH Know what s in your product to respond rapidly to changing requirements Anticipate necessary engineering changes and implement efficiently Supply chain analyses: Extractives (conflict metals) Constrained materials Cost improvements Product design improvements Cost reduction Green product attributes Reliability WEEE/recycling reporting Green Chemistry Life Cycle Assessment Full disclosure positions Seagate to quickly respond to new regulations and customers product sustainability and environmental data requirements 3

requirements Anticipate necessary engineering changes and implement efficiently Supply chain analyses: Extractives (conflict metals) Constrained materials Cost improvements Product design

4 Resource requirements and impact to suppliers spike in response to new requirements, and total resource requirements ratchet up over time Re esources Required 2004 New restrictions drive peaks in resources expended RoHS, WEEE Batteries Overall resources increase to accommodate increasing number of restrictions. Deca BDE China RoHS Low Halogen Japan Green ELV Procurement REACH ODM Detailed Reporting US states, Canada, and other RoHS regs RoHS 2, New Annex Life Cycle Assessments (LCA) Time 2011 Emerging new restrictions result in spikes of NRE and business process change Resource levels rise over time to sustain compliance Challenge: Meet increasing i requirements with limited resources 4

Deca BDE China RoHS Low Halogen Japan Green ELV Procurement REACH ODM Detailed Reporting US states, Canada, and other RoHS regs RoHS 2, New Annex Life Cycle Assessments

5 By investing early in full disclosure data, Seagate has been able to flatten the sawtooth' in resource requirements Res sources Re equired RoHS, WEEE Seagate invested in CAS* system and developed full disclosure (Bill of Substances) strategy to deal with changing requirements Deca BDE ELV Low Halogen REACH RoHS 2, New Annex US states, Canada, sawtooth is and less other pronounced, overall China resources required RoHS reduced d as compared to RoHS other compliance regs strategies. Resource Life Cycle trend is Assessments Batteries ODM almost Detailed flat. Why? Because Seagate collects full (LCA) Reporting content data up front, and software is used to grade against new specifications. Japan Green Procurement Seagate is able to respond quickly to changing substance restrictions Full disclosure and alignment to standards allows Seagate to manage substance restrictions at low cost and resource levels e 2005 Time 2011 *CAS Compliance Assurance System, Seagate s materials content compliance database 5

China resources required RoHS reduced d as compared to RoHS other compliance regs strategies. Resource Life Cycle trend is Assessments Batteries ODM almost Detailed flat. Why?

6 Overview of Seagate s Supplier Engagement Approach Put data requests in the context of business need and mutual benefit Build supplier capacity to provide data through standardization, training, and help desk support Ask suppliers for data in a stable, standard format Ask for sufficient data to avoid having to go back to supplier for more data (avoid supplier fatigue ) Use software automation ti to collect, check, manage and report supply chain data Partner with suppliers and commit to making the process more efficient i as long as they provide the data

for sufficient data to avoid having to go back to supplier for more data (avoid supplier fatigue ) Use software automation ti to collect,

7 Thank You

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