AVALUE establishes its own environmental policy in accordance with all relevant environmental legislation. The company conducts its business in a manner that respects, preserves, and improves the environment.

We have initiate a series of action plans to comply with RoHS and WEEE regulations to minimize the impact on environment.

It's our objective to have all products converted into RoHS compliance before RoHS Directives effected in 2006. The company has set forth its RoHS conversion plan since July 2004. The first RoHS compliance product has been assessed by third party laboratory with successful qualification. The report verifies the facts that AVALUE is capable to monitor RoHS manufacturing process, and its manufacturing quality achieve 100% lead-free quality.

Milestones to RoHS Conversion

Jul 2004	Task team set up
Sep 2004	Lead-free manufacturing process ready
Apr 2005	Lead-free and RoHS compliant components survey completed
Jul 2005	Rework process definition ready
Aug 2005	Lead-free and RoHS compliant products ready
	ESM-2643D4-A1 (non-standard version)
	ECM-3610-A12
	ECM-3611-A1
	ECM-5612-A13
	DEM-2740-A03 (non-standard version)

EOL plans for non-RoHS-compliant products
We will phase out the following products due to the two chipsets, Intel FW82810 and NS GEODE GX1, can not convert into RoHS compliant and will discontinue in 2006.

Phase out item	EOL	Substitution	Availability
ECM-3412	Not yet	ECM-3512 or ECM-3610-E4	ECM-3610-E4 available (MOQ: 200 pcs)
ECM-3410	Yes	ECM-3512 or ECM-3610-E4	ECM-3610-E4 available (MOQ: 200 pcs)
ESM-2410	Yes	N/A
ESM-2440	Yes	ESM-2540 or ESM-2643-E4	ESM-2643-E4 available (MOQ: 200 pcs)
ECB-642V	Not yet	ECB-663-E4	TBD
ECM-5414	Not yet	N/A
ECM-5415	Not yet	N/A
ECM-5410	Not yet	ECM-5510	TBD
EMB-9160	Not yet	N/A
EMB-9160L	Not yet	N/A
EMB-9664	Not yet	EMB-9680	Oct 2005
EMB-9470	Not yet	EMB-9280	Oct 2005

Component quality control
AVALUE applies XRF (X-ray fluorescence) technique to verify the component quality. It becomes a standard procedure to use the handheld XRF analyzer detecting the banned substances from incoming inspection to component release. These tools can accurately evaluate alloy grades based on the elemental composition, and therefore ensure all components qualified with RoHS compliance.

Process quality control
During the RoHS conversion, AVALUE pays special attention to manufacturing process to avoid any mixture from possible hazardous parts or equipments involved. AVALUE production engineering will examine and update the process control in every stage of manufacturing process to implement RoHS compliance.

Manufacturing quality assurance
For RoHS compliant products, AVALUE could apply for third party RoHS compliance testing and certification upon customer request.

 

Approach to WEEE compliance

	Action plan		Status
Phase I	Have all products correctly labeled to reuse and recycling		Done by Aug. 13, 2005
Phase II	Register to qualified agent in Europe		Dec. 31, 2005
Phase III	Declare the market share data and estimate what/how many products will be recycled by AVALUE or by a competent party;		TBD
Phase IV	Pay for treatment and recycling costs for collected AVALUE products.		TBD

Glossary
RoHS Directive
In January 2003, the European Union iussed Directives 2002/95/EC on the restriction of the use of certain hazardous substances (RoHS) in electrical and electronic equipment. This Directive requires all member states reduce following hazardous substances to minimum acceptable levels by July of 2006.

Lead (Pb)	< 1000 ppm
Hexavalent chromium (Cr +6)	< 1000 ppm
Mercury (Hg)	< 1000 ppm
Polybrominated biphenyl (PBB)	< 1000 ppm
Cadmium (Cd)	< 100 ppm
Polybrominated diphenyl ether (PBDE)	< 1000 ppm

WEEE Directive
At the same time, the EU authorized Directive 2002/96/EC on waste electrical and electronic equipment (WEEE). WEEE encourages the collection, treatment, recycling and recovery of waste electrical and electronic equipment. EEE manufactures are responsible for financing most of these activities.