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Update RoHS at Electroswitch
September 29, 2005

The European Parliament and the Council of The European Union (EU) has issued directive 2002/95/EC known as the Restriction on Hazardous Substance (RoHS). This directive restricts the use of certain substances in electrical and electronic components and products that have been deemed hazardous by the EU.

The proposed maximum concentration by weight of restricted material is 0.1% for lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers. The proposed maximum concentration of cadmium by weight is 0.01%.

Currently, we are engaged in researching purchased parts and raw materials used in the manufacture of our products and resolving non-conforming issues. Electroswitch will comply with the EU's RoHS directive by evaluating our products and making changes where necessary.

Steps to RoHS Compliance

RoHS compliance will be accomplished through a four-phase process.

Phase 1: Identify hazardous materials in raw materials and purchased parts.
Since 3Q-2004, Electroswitch has contacted our base of over 450 suppliers of raw materials and purchased parts. This effort targeted identification of banned substances found in the manufacture of Electroswitch product. An 81% supplier response has been realized through Q3-2005. Additional staff has been added to address the 19% not responding to our compliance declaration survey. Phase 1 has identified 48 suppliers with compliance issues. Supplier material declarations and their compliance agreements form the basis of an auditable program for RoHS compliance. This phase is anticipated to conclude during Q4-2005.

Phase 2: Identify changes and resolve non-compliant issues.
Based on information gathered in Phase 1, raw materials and purchased parts are being changed as required. Plans and procedures for use of acceptable, compliant alternatives are being established. As non-compliant issues are identified, Electroswitch is qualifying alternate materials through engineering evaluation, performance testing, and conformance to industry standards and trends. The Electroswitch IT Department has developed software for RoHS data input. Additional computer tools will be available in November 2005 to query part number compliance by customer. Compliance data is currently being uploaded to the product data computer system.

Phase 3: Customer notification.
RoHS part specific compliance information will be available as Phase 2 is completed. Customers requiring product compliance will be advised as their requests are evaluated and a completion date will be established as necessary. Certain customers, such as military, aerospace, or others, may still request non-compliant products.

Phase 4: Ship RoHS compliant product.
As required by the customer, RoHS compliant product will ship on the completion date. However, the RoHS compliant program will be fully implemented by 1 July 2006. Specific product labeling and identification will be addressed on a customer specific basis.

Electroswitch provides numerous products to the European market and is subject to those laws and directives. We are committed to comply with the RoHS directive and will make changes as necessary to guarantee conformance to the RoHS directive.


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