The EU RoHS Directive: Big Issues Linger
By Tim McGrady, President and Principal Scientist of Serious Science, Cortland,
N.Y.
As of July 1, 2006, all new electrical and electronic products put on the European Market
and falling under the scope of the European Union directive "Restriction of the Use of
Certain Hazardous Substances in Electrical and Electronic Equipment" (RoHS) have to
comply with its requirements. Every "homogeneous material" within covered products is
restricted to maximum concentrations of 0.1% by weight lead, mercury, hexavalent
chromium, PBB and PBDE and a maximum of 0.01% by weight cadmium. To the
uninitiated, these requirements seem reasonable and clear. But to those who have studied
the EU RoHS Directive and its implications, the requirements are as clear as mud.
The European Union (EU) Commission has published a guidance document for RoHS,
but on the bottom of every page is the phrase: "not legally binding." When pressed, EU
officials say that only the European Court of Justice may make binding interpretations of
Community legislation. In other words, legislators write the laws, but it is up to the courts
to determine what they mean. Following this statement to its logical conclusion, in order
to know what constitutes infractions of RoHS, we will have to wait for convictions of
those accused of infractions. The guidance offered by the EU Commission is somewhat
helpful, but there are many issues left unsettled.
The first issue is that it is difficult to interpret the EU definition of what constitutes a
"homogeneous material." The latest revision (August 2006) of the European Commission
guidance document states that homogeneous materials "are individual types of plastics,
ceramics, glass, metals, alloys, paper, board, resins and coatings." The document further
states, "Homogeneous material means a material which cannot be mechanically
disjointed into different materials." In addition, "the term'‘mechanically disjointed' means
that the materials can, in principle, be separated by mechanical actions such as:
unscrewing, cutting, crushing, grinding and abrasive processes." One must be careful in
interpreting these definitions, since the EU Commission has stated that it does not mean
that a homogeneous material must be separable from another by mechanical means; they
mean only that such separation is possible in principle. In the case of testing, one may
employ any means of separation necessary to disjoint two homogeneous materials. For
example, the common practice of stripping plating or coatings from substrates via
chemical processes would be a viable means of separation for testing purposes.
An important example of interpretation issues concerns hexavalent chromium conversion
coatings (CCCs). The EU Commission states that they consider coatings to be
homogeneous materials, but there have been two interpretations in the coating industry as
to whether CCCs meet RoHS requirements. One camp has maintained that CCCs cannot
be mechanically separated from substrates without also including some of the substrate
with the coating; therefore, this camp concludes, CCCs are part of the substrate and the
substrate is to be considered a homogenous material. If the coating and substrate are
tested together for weight percent hexavalent chromium, the result is nearly always a
passing value for hexavalent chromium (i.e. <0.1% hexavalent chromium). The other
camp has interpreted RoHS as a ban of the use of CCCs and has decided that no
hexavalent chromium may be used.
As it turns out, neither camp is correct. RoHS is not a ban; it is a "restriction." The
guidance from the EU Commission states that concentrations up to 0.1% by weight will
be tolerated, so hexavalent chromium could be used if its concentration is less than 0.1%
by weight in a homogeneous material. The EU Commission also states that coatings are
considered to be homogeneous materials. That means they consider CCCs to be
homogeneous materials.
The real problem concerning CCCs is a fundamental misunderstanding of the
characteristics of such coatings and how they are measured. CCCs are typically used on
zinc, aluminum and cadmium substrates as corrosion inhibitors; they may be used over
plating or on metals and alloys. Heavy yellow CCCs have been measured to be on the
order of a few hundred nanometers in thickness. The thickness of "clear" or "precoat"
CCCs has been estimated to be on the order of 10 nanometers. These coatings are a
mixture of trivalent chromates, hexavalent chromates, base metal, water, proprietary salts
and perhaps a few other ionic forms of chromium in valences other than three or six.
There is currently no standard method that may be used to determine the total coating
mass of CCCs. Typically, coating and plating masses are measured via the "weigh-stripweigh" technique, whereby the coated sample is weighed, the coating is chemically
stripped and the dried sample is re-weighed. But in the case of CCCs, such a method in
not used, since the coating thickness (and, thus, mass) is so small. Analytical balances are
not accurate or sensitive enough to measure the total mass of CCCs. One could try to
increase the number or surface area of samples to be measured in order to increase the
overall sample mass, but the low-level sensitivity of balances is inversely proportional to
the mass to be measured (i.e., as the mass increases, so does the minimum mass, which
can be accurately measured). So it seems that even "in principle," the total mass of CCCs
cannot be accurately determined whether mechanical or chemical separation is employed.
The implication of this measurement problem is that if we cannot measure the total mass
of CCCs, then we cannot measure the concentrations of hexavalent chromium in weight
percent within CCCs. We can measure hexavalent chromium in CCCs, but we cannot
measure the total mass of CCCs. Since determination of weight percent requires
determination of a numerator (hexavalent chromium mass) and a denominator (CCC
mass) in order determine a ratio, weight percent is currently not a viable measurement
technique for hexavalent chromium within CCCs. That is why the one standard method
used to measure hexavalent chromium in CCCs, ISO 3613, requires reporting results in
mass per area (typically). General Motors’ worldwide specification GMW 3059 sets a
maximum limit for hexavalent chromium in CCCs at 0.1 µg/cm2—even though the EU
End-of-Life Vehicle requirements now state that the maximum concentration value
(MCV) for hexavalent chromium is 0.1% by weight.
Neither IEC TC 111 WG3 nor the EU enforcement bodies have developed a means of
measuring hexavalent chromium in CCCs in units of weight percent. The most recent
draft of IEC TC 111 WG3's test method document references only a spot test for
measuring hexavalent chromium in CCCs. That spot test can only indicate presence of
hexavalent chromium and cannot be correlated with weight percent units. In a May 2006
guidance document, the EU enforcement task group made no mention of how to measure
hexavalent chromium in CCCs. Since violation of RoHS allowable MCVs in
homogeneous materials carries legal ramifications in the form of fines, the EU must have
a legally acceptable means of determining hexavalent chromium in CCCs in units of
weight percent, or the requirement is unenforceable. Similarly, if no standard method of
determining hexavalent chromium in CCCs exists, companies wishing to determine if
their products meet the requirements of RoHS cannot do so. In other words, if you cannot
measure it, you cannot enforce it; if you cannot determine if you meet a requirement, you
cannot comply with the requirement.
The measurement of RoHS substances is legal metrology, and it should be treated as
such. All member states of the World Trade Organization (WTO) are bound by the
Agreement on Technical Barriers to Trade (TBT) when they put technical regulations
into force. In the case of RoHS, there are provisions within the TBT Agreement that
require the EU and/or its Member States to adopt international standards of measurement
if they already exist (reference ISO 3613) or they "shall play a full part, within the limits
of their resources, in the preparation by appropriate international standardization bodies
of international standards for products for which they either have adopted, or expect to
adopt, technical regulations."
But neither the EU nor its Member States have developed those methods, nor have they
adopted ISO 3613 for measuring hexavalent chromium in CCCs. When EU
representatives have been questioned on why they did not adopt ISO 3613 and the proper
units of measurement for hexavalent chromium in CCCs, answers range from "we did not
know" to "it was not the appropriate standard" because it did not express results in weight
percent. One EU Technical Adaptation Committee (TAC) member stated that it did not
matter whether they could measure hexavalent chromium in CCCs accurately, since they
could just rub the surface of metals, collect the rubbings and analyze them for percent
hexavalent chromium. If the result was greater than 0.1%, the TAC member said, they
could infer that the hexavalent chromium concentration was greater than 0.1% in the
CCC.
In response to this statement, it was suggested that the method as described be made into
an international standard, with the caveat that they would have to define how hard to rub
a surface, for how long it should be rubbed and with what the surface should be rubbed.
Otherwise, any number of non-equivalent methods of rubbing could be employed, with
the results varying from less than 0.1% to high percentages of hexavalent chromium.
The U.S. government has said it did not seek action in the WTO for EU (or its Member
States') violations of the TBT Agreement because the U.S. Trade Representative’s office
did not think the EU violated provisions of the TBT Agreement. (The RoHS directive
impacts products made by European-owned companies in the same manner as it does
products made by companies owned outside the EU.) This is only one provision of the
TBT Agreement, and compliance with that provision does not relieve members of the
WTO of their responsibilities for complying with other provisions of the TBT (such as
adopting or developing appropriate standards). Another theory: the electronics industry
may have convinced the U.S. government not to act, since they wanted to develop the
necessary standards for RoHS themselves. Electronics industry representatives have also
stated that attacking the EU on legislation meant to protect human health and the
environment would be "a public relations nightmare."
Bottom line: without the proper standards in place, industry suffers. There are literally
thousands of standards necessary to comply with the RoHS directive. Standard material
specifications, test methods, reporting guidelines and management practices—none of
these standards are in place, even though the RoHS directive took effect on July 1, 2006.
Those standards offer an infrastructure by which industry buys and sells goods. Without
those standards, there is duplication of effort, superfluous testing and general confusion
on RoHS compliance issues.
The cost to the supply chains has been estimated in the billions of dollars. Those
uncounted billions need not have been spent had the EU and/or its Member States been
held to their responsibilities vis-à-vis the WTO TBT Agreement. Think about it: had
industry been able to buy compliant materials prior to the RoHS directive going into
effect, only a fraction of the billions spent on RoHS compliance to date would have been
necessary.
Tim McGrady is the President and Principal Scientist of Serious Science, a new materials
testing, consulting and research company located in Central NY. He is a founding
member and Chairman of ASTM International Committee F40 on Declarable Substances
in Materials. He may be reached at tim@seriousscience.com.
http://www.imrtest.com/What_we_do/RoHS_Services/rohs-faq.html
1. What is RoHS?
RoHS is European Union Directive 2002/95/EC on the Restriction of Certain Hazardous
Substances in Electrical and Electronic Equipment. It is pronounced “ross”.
2. What hazardous substances are covered by RoHS?
RoHS restricts the use of lead (Pb), cadmium (Cd), mercury (Hg), hexavalent chromium
(Cr6+), polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs).
Those restrictions are in addition to existing regulations, such as the 47 categories of
dangerous substances restricted for use in nearly every product by EU Directive
76/769/EEC and its numerous amendments.
3. What products are covered by RoHS?
The scope of RoHS is given in the EU WEEE Directive Annex IA, categories 1 -7 and
10. The following is a summary of covered product categories:
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (except large-scale stationary and industrial tools)
7. Toys, leisure and sports equipment
10. Automatic dispensers
Categories 8 and 9, which cover medical devices and measuring and control instruments,
are exempt from RoHS requirements until which time the EU Commission includes them
(estimates are that this will occur in 2008 or 2009).
Electrical and Electronic Equipment (EEE) is defined as devices which are dependent on
electric current or electromagnetic fields to work properly, including that equipment used
to generate, transfer, or measure such currents or fields. The definition of EEE for RoHS
is limited to those devices operating on a maximum 1000 Volts AC or 1500 Volts DC.
4. When do my products have to be compliant with RoHS?
The RoHS Directive goes into effect on July 1, 2006. If you are selling products on the
EU market, your products must be RoHS/WEEE compliant by that date. Note, however,
that many manufacturers are requiring compliance from their suppliers earlier than July
1, 2006 so they can make sure they can supply finished goods to the EU.
5. What are Maximum Concentration Values (MCVs)?
Maximum Concentration Values (MCVs) are limits set by the European Commission for
each RoHS-restricted substance in the Commission Decision 2005/618/EC amending the
RoHS Directive. MCV limits apply to each “homogeneous material” making up a
product. Note that EU officials have stated that RoHS is considered to be a ban on the
listed substances, and that any intentional use of those substances is not allowed. Other
EU officials have stated that the term “intentional use” has no meaning in relation to
RoHS. The MCVs are as follows:
0.1% by weight maximum for Pb, Hg, Cr6+, PBBs, and PBDEs
0.01% by weight maximum for Cd
6. What is a “homogeneous material”?
The term “homogeneous” is understood as “of uniform composition throughout”.
Examples of “homogeneous materials” are individual types of: plastics, ceramics, glass,
metals, alloys, paper, board, resins, and coatings. The Commission further states that a
“homogeneous material” cannot be mechanically disjointed into different materials.
7. What does “mechanically disjointed” mean?
The term “mechanically disjointed” means that the materials can be, in principle,
separated by mechanical actions. This means that an insulated wire is considered as two
homogeneous materials: the metal wire and the plastic insulating material.
8. Are there any exemptions to RoHS?
Yes. The list of exemptions is growing all the time. Exemptions may be found in RoHS
and the RoHS Directive Annex. Information on pending exemptions may be found at the
UK DTI website.
9. My company is based in the US. Why should we worry about RoHS?
If you sell electrical or electronic equipment to any member country of the European
Union, or if you sell parts or materials to companies that then sell their products on the
EU market, your products are likely to be covered by RoHS. But even if your products
aren’t destined for the EU market, you still may have something to worry about. First,
laws such as SB 20 and SB 50 in California are already taking effect in the US, and many
more are in the works here and in countries such as China, Japan, and Canada. Also, you
may find that availability and reliability are issues, since the “old” products containing
restricted substances will become harder to find and more expensive to buy. For example,
even though medical devices are now exempt from RoHS, manufacturers may have
problems getting printed circuit boards with the tried and true tin-lead solder. That means
they will have to test circuit boards with “lead-free” solders to make sure they will be as
reliable as the “old” boards.
10. Where do I find information on RoHS?
The following are good sources:
The United Kingdom Department of Trade and Industry (DTI) – they have the lead
responsibility for RoHS, WEEE, ELV, and Packaging Directives in the EU. Search for
“DTI” and go to the environment department, or click on the link above.
DTI - Sustainable Development and Environment: Latest TAC Committee meeting
notes
Europa is the website of the European Union. Information on RoHS is available on that
site, but is not as easy to find as on the DTI site. Click on any of the links below.
EUROPA - Environment
EUROPA - RoHS Directive
EUROPA - WEEE Directive
EUROPA - Committee on Environment, Public Health and Food Safety
EEA - European Environment Agency - Home
SCADPlus: WASTE MANAGEMENT
The Electronics Industry Alliance (EIA) often has free information on RoHS, but you
may have to join to get full access.
iNEMI is also a good source of free information.
AeA is a good source for RoHS seminars and other information. AeANET : Advancing
the Business of Technology
11. My customer has sent me a “material declaration”; why does it ask for
information on substances not covered by RoHS?
Material Declarations are prepared by electrical and electronic OEMs and companies
throughout the supply chain. Rather than being specific to RoHS, they are a compilation
of all requirements concerning restricted substances world wide. Those requirements may
be from regulations or they may be something your customer wants or needs. Material
Declarations also include elements or compounds that are not restricted but either may
become restricted or are needed by the company to assess other issues, such as residual
value. For example, it is desirable to know the gold content of a material even though
gold is not restricted, since the material may have residual value depending upon its mass
and gold content.
12. Do I need to test all my products for every item on the material declarations?
No. If you tried to do that, you would get a very big bill from a laboratory. First, you
should try to obtain information on the concentration of RoHS and other declarable
substances in your materials from your suppliers or from the manufacturer of the
materials. If that information is not available, you have two real choices: 1) test each
homogeneous material you use, but limit the testing to one set per unique material to
avoid duplication; only test the materials for substances that are likely to be present as
additives or contaminants (your lab should be able to help with this); or 2) stop doing
business with that client. Note that the substances to be tested will vary from material to
material; for example, it does not make sense to test steel for brominated flame
retardants, but it does make sense to test for them in plastic.
In every case, it is highly recommended that you have your legal representative(s) review
the material declaration before and after you fill it out. These material declarations may
be used to place blame on you and/or your company in case of an infraction in the EU.
Tell your legal representative(s) that the UK (and probably all other EU member states)
will allow “due diligence” as a defense for infractions. That means that third parties, such
as your company, may be prosecuted for infractions if your customer can show due
diligence. Part of that due diligence will be based on the material declarations received
from suppliers.
13. We sell populated circuit boards. How do we demonstrate compliance with
RoHS?
This is a difficult subject. The best and cheapest way is to get information on RoHS
compliance for each material or component from your suppliers. If this is not possible,
you have a difficult task. You will have to get information for each “homogeneous
material” comprising your populated circuit board. It would be best to test each material
BEFORE they get made into individual components. Barring that, supply enough
individual parts to your lab (including samples of solders) so they may be tested – it is
very difficult, if not impossible, to test every homogeneous material on a populated board
for RoHS compliance. That is why ASTM International Committee F40 has proposed
testing materials for compliance prior to their use in component manufacture: it is easier,
and it is less costly to the entire supply chain.
14. Why can’t we just grind components into a powder, then test for RoHS
compliance?
Remember, RoHS compliance is based on each “homogeneous material” and not
components or devices. If a component or populated circuit board is ground up and
tested, restricted substance concentrations in the homogeneous materials are diluted. If a
lab grinds up a complex component or entire product, they will not be able to state
anything about RoHS compliance, since they will not know which material any restricted
substances found come from, or if the restricted substance comes from an exempt
application.
The grinding equipment specified by the electronics OEMs to use in grinding up
components is difficult if not impossible to clean. Plastic and low melting elements (e.g.,
lead) get smeared onto the blades and other surfaces of the equipment. Also, abrasive
samples such as populated circuit boards will abrade parts of the equipment such as
stainless steel and contaminate the sample with chromium and/or nickel or other
elements.
For example, let’s say that a circuit board is ground up using the electronic OEM
technique. The first issue will be whether the ground sample has been contaminated by
past samples or the grinding equipment. Even if that was not an issue, let’s say the final
ground sample is analyzed for TOTAL lead, cadmium, hexavalent chromium, mercury,
PBB, and PBDE. The analysis cannot separate exempt lead from non-exempt lead,
exempt cadmium from non-exempt cadmium, and so on. So which is the “good” lead
and which is the “bad” lead? No one can tell. Besides, there is no way to create a
certified reference material to validate the results. So such testing is essentially
WORTHLESS. If an electronics OEM tells you to grind up your sample and you tell us
to grind up your sample, we cannot state compliance. Neither should you. Let the OEMs
have the data and let them state conformance or non-conformance based on the results.
15. This is all very confusing. Isn’t there a better way to regulate substances?
While the EU has noble goals concerning protection of human health and the
environment, their means of doing so cause confusion and great expense to industry.
There is a better way to do this, and the EU is bound by the World Trade Organization
Agreement on Technical Barriers to Trade (TBT) to do things to minimize costs and
unnecessary work. Unfortunately, no sector affected by the EU hazardous substances
Directives has decided to take the EU to task on the issues. The result is that supply
chains all over the world are spending billions of dollars more than necessary to comply
with the EU legislation. It is likely to get worse before it gets better, but something must
be done. If you feel your business is spending too much on compliance issues PLEASE
WRITE YOUR REPRESENTATIVES IN GOVERNMENT! Government will only take
action if industry says there is a problem. Here are two people you can write to
concerning RoHS issues:
Robert Straetz
Dept. of Commerce, International Trade Admin.
14th & Constitution Ave.
Room 3632
Washington, DC 20230
202.482.4496 Email
Jim Sanford
Deputy Assistant USTR for European Affairs
Office of the U.S. Trade Representative
1724 F Street, NW.
Washington, DC 20508
202.395.3320 Email
16. What is being done to help companies comply with RoHS?
ASTM International has created Committee F40 on Declarable Substances in Materials.
This Committee was formed to help industry develop the standards and test methods
necessary to comply with RoHS and other legislation. ASTM is working with the US
government and industry trade associations to help fix this mess. If you would like to
help, please feel free to get involved – email Don Shuman at IMR Test Labs.
17. What test methods are used to assess RoHS compliance?
Standard test methods are under development. The EU Member States have not told
anyone how they will test products for compliance, which is a violation of the WTO TBT
Agreement. Meanwhile, most labs are adapting current tests to determine concentrations
of RoHS substances in materials. X-Ray Fluorescence (XRF), Inductively Coupled
Plasma Atomic Emission Spectrometry (ICP-AES), Cold Vapor Atomic Absorption
Spectrometry (CVAAS), Direct Mercury Analysis (DMA), UV-VIS, GC-MS, and other
techniques are currently being used.
18. What is “Due Diligence” defense?
Due diligence means that you can show that you did everything “a reasonable person
would do” in order to comply with the law. It also means that you may be able to show
that an infraction was not due to your or your company’s actions; you may be able to
show that an infraction was due to someone else’s action or inaction. Material
Declarations are used to show due diligence, since they are used to get statements of
compliance from suppliers. Once such a document is in the possession of a company, it
may be possible to point to the document and state that there was no reason to disbelieve
the information given. Then, an infraction may be assigned to a third party as if they had
committed it themselves. So anyone making false, misleading, or incorrect statements on
material declarations may be prosecuted as if they had committed the infraction.
19. How do I document my compliance efforts to show due diligence?
Keep your test results, Certificates of Analysis, and Material Declarations in a safe,
accessible place. It is recommended that you keep both hard copies and electronic copies.
Make sure you keep records of everything you fill out for other companies. Also, it is
important to document any changes you made to your products, production method, or
materials in order to comply with RoHS – this also helps show due diligence. Keep track
of costs associated with compliance as well.
20. Is plating a “homogeneous material”?
According to the EU Commission, plating and coatings are “homogeneous materials”.
The problem with this view is that in chemical analysis, plating and coatings are
commonly removed from substrates by chemical means, and are not “mechanically
disjointed” from the substrate. This is not such a big problem technically, however, since
there are quite a few chemical methods for removing plating and coatings from surfaces.
But if the Commission or the TAC decides to specify that plating and coatings must be
removed by mechanical means, we will be left with insurmountable technical challenges
involved with mechanical removal of plating and coating from small, complex parts.
Imagine trying to mechanically remove a 0.001” zinc coating from the surface of a
galvanized screw without removing any of the steel. Impossible? Maybe. Impractical?
Absolutely.
One exception to the chemical removal of coatings from substrates is hexavalent
chromium conversion coatings. Since hex chrome coatings vary in mass over time due to
exposure to the environment and because hexavalent chromium coatings are often very
thin (on the order of 200 nanometers), determining the total coating mass on a chromated
surface is difficult if not impossible. Besides, there exist no certified reference materials
with which such a method could be evaluated, and it is unlikely that such reference
materials will ever be produced. It is the standard practice that hexavalent chromium
coatings are determined in units of mass of hexavalent chromium per unit area (such as
ug/cm2) instead of weight percent. But the EU Commission has not backed away from
their definition of hexavalent chromium conversion coatings as homogeneous materials,
nor have they changed their MCV units of weight percent.
21. Where in “old” electronic equipment is hexavalent chromium found?
Hexavalent chromium is used in two general applications in relation to electronic
equipment: as a chromate conversion coating on metal surfaces to act as a corrosion
inhibitor, and as pigments in plastic and ink. Other possible applications in relation to
electronic equipment are the use of hexavalent chromium in the textile, leather, and glass
industries. Note that the chromium found in a metal alloy such as stainless steel is not
considered to be in the hexavalent state, and it is not environmentally available; the
exception to this statement is when high chromium steels are welded, hexavalent
chromium may be created and released in the fumes.
Pigment colors that may contain hexavalent chromium include red, yellow, orange, and
green.
22. What are the steps my company should take toward demonstrating RoHScompliance of our products?
The first step is education. It is very important to understand, as much as possible, what
it means to be RoHS-compliant and what products are affected by RoHS. One of the
most important things to know is that the (proposed) basis of compliance is each
“homogeneous material”; that means that each material used to construct every part in
every covered electrical and electronic product must comply with RoHS. It is also
important to know what is and is not exempt from RoHS. There are several ways to go
about educating yourself and your company, including attending seminars, hiring in a
consultant for a seminar, and reading free information available on the internet (the best
official sites are www.dti.gov.uk/sustainability/ and
www.europa.eu.int/comm/environment/index_en.htm.)
The second step is awareness. Make sure that upper management is aware of RoHS,
when it comes into effect, why the company's products are affected, and what the
potential impact on the company might be. Most people in the know about RoHS will
tell you that it is vital that leadership and support for a RoHS-compliance effort comes
from upper management. RoHS-compliance can be a costly and time-consuming
endeavor, so upper management will have to be on board. RoHS-compliance can mean
that your company will have to go through big changes, including retooling, redesign,
renumbering of part numbers, adjustment of purchasing practices, and editing of
drawings and other internal company documentation such as material specifications.
The third step is assessment of your product line. In a very real sense, this is risk
assessment: you are trying to determine in which cases you know you are compliant, in
which cases you know you are not in compliance, and in which cases you do not know if
you are compliant. Risk assessment should be conducted with “due diligence” in mind,
meaning that you should do what a reasonable person would do to ensure your products
comply. That usually means you have to be able to back up your claims of compliance
with statements and/or data. The following mantra should be running through your head:
“What do we think, what do we know, what can we prove?”
The fourth step is to do a survey of your materials and parts suppliers. You should ask
them if their products are RoHS-compliant and if they are, ask them if they can supply
either a statement to that effect or a certificate of analysis. If not, ask them if and when
they expect to be compliant or if they would be willing to get the necessary information
together to support their product compliance. That may require them to do a survey of
their suppliers and/or test their products. You may want to test their products if the
statements you receive are suspect.
The fifth step is to fill in the gaps in your product compliance. That may mean you will
have to change suppliers to those who can demonstrate RoHS-compliance, or you may
have to test your remaining items for compliance. Make sure that any testing you have
done is done by a competent laboratory; the best choice is a materials testing laboratory
with accreditation to ISO 17025. It is not recommended that you engage a laboratory
without the assurance that their results are trustworthy. A key to making such a judgment
is to ask the laboratory if, based on the results of testing, they will make a statement of
RoHS-compliance. If they will not do so, you may as well be throwing your money
away.
The sixth and last step is to organize all the information you have gathered to back up
statements of compliance for each product. This information should be kept available in
case it is requested by your clients or by an enforcement authority. It is recommended
that you keep hard copies in addition to electronic copies of the information.
23. What is the difference between a PBDO and a PBDE?
There is no difference. These are acronyms which stand for different names of the same
compounds. So PBDOs are restricted by RoHS, because they are PBDEs.
24. What is the official definition of “homogeneous material”?
Unfortunately, there isn’t one, and there will not be an official definition. The EU
Commission says that only the European Court of Justice may decide what the definition
will be. The best advice I can give is to follow the definition(s) given in the EU
Commission FAQ document or the UK DTI draft RoHS regulations, because the
definitions will not appear in any official document.
25. Should energy dispersive XRF be used to determine RoHS compliance?
Because energy dispersive XRF, or EDXRF, is a quick and easy technique for measuring
chemical compositions, IMR Test Labs has hoped that it would be a useful, time and
cost-saving method for analysis of samples for RoHS substances. But even the IEC TC
111 WG3 has shown in a recent round robin that the technique is not yet accurate or
precise enough to yield dependable results. We continue to hope that EDXRF will be
developed into a sound, trustworthy technique for analysis of RoHS substances in a wide
variety of materials. Right now, we suggest that anyone using XRF to measure RoHS
substance concentrations take care in evaluating the results.
http://www.ema-eda.com/services/RoHS.aspx
Make RoHS compliance an inherent part of your design process
Now that the EU RoHS Directive has become law, companies that have not taken
the necessary steps to become RoHS compliant risk having their products banned
from the European market. Non-compliant product shipments may be halted
outside the EU, and suppliers may be fined. RoHS-related legislation is spreading
across the world to the USA, Canada, Japan, China, Australia, Korea and other
countries. Environmental compliance issues that were left on the “back burner”
must now be resolved with a sense of urgency.
It’s more than a manufacturing problem!
Waiting until the end of the design cycle to assure RoHS compliance might be acceptable
for designs currently in production, but for new designs, companies must consider RoHS
compliance from the very beginning of the design phase — at the time of component
selection. There is a common misconception that RoHS compliance is a manufacturing
problem. "The design is done; all that is necessary now is to select the RoHS compliant
parts and build it." It seems simple enough to replace non-compliant parts with compliant
replacements, often called BOM scrubbing, but this is a costly approach with a number of
potentially fatal problems.
Many designs contain more than 50 percent discrete parts, and these parts tend to get
examined for compliance every time. This redundant compliance checking over many
designs adds up to a considerable amount of time. Additionally, there's the concern that
replacement parts won't be 100 percent compatible. If a component change has a negative
affect on the performance of the design, you won't discover the problem until testing the
prototype. This results in costly design iterations and PCB re-spins
Compliance by Design
EMA offers a unique approach. We call it Compliance by Design™. This design
methodology incorporates a database containing all component data, including
RoHS/WEEE information, into the schematic design tool. This allows an engineer to see
part information and RoHS compliance data while selecting parts. Using this design
process, an engineer can guarantee that parts used in the design are compliant. We've put
together the best tools and the most comprehensive RoHS hazardous material content, so
your engineering team can make RoHS an inherent part of the design process. We can
help you change compliance issues from a time-consuming, complex, costly problem, to
a one-time manageable cost.
The RoHS Directive (EU Directive 2002/95/EG), which became effective in Europe on
July 1, 2006, mandates that electrical and electronic products (EEE) put in the market
within the European Union (EU) shall contain restrictive levels of the following
substances:
1. Lead (Pb)
2. Cadmium (Cd)
3. Mercury (Hg)
4. Hexavalent Chromium (Cr6+)
5. Polybrominated Biphenyls (PBB)
6. Polybrominated Diphenyl Ethers (PBDE)
This Directive, which aims to protect human health and the environment and mirrors the
Directive on Waste Electrical and Electronic Equipment (WEEE), applies to electrical
and electronic equipment that is dependent on electric or electromagnetic fields in order
to work properly. It also applies to some equipment used for the generation, transfer, and
measurement of such currents and fields designed for use with a voltage rating not
exceeding 1,000 volts for alternating current (AC) and 1,500 volts for direct current
(DC).
The RoHS/WEEE directive does not call for a total elimination of these substances. It
mandates that the homogeneous materials within complaint products, or materials that
cannot be mechanically disjointed into different materials, contain the levels of the six
restricted substances below the maximum concentration levels.
The definition of homogeneous materials has caused some confusion in the past, but has
been clarified in draft guidelines published by the European Commission. Homogeneous
material is defined as "a material that cannot be mechanically disjoined in to different
materials", such as a plastic (ex. the PVC insulation on insulated copper wire).
Components such as capacitors, transistors and semiconductor packages are not
"materials" but will contain several different materials. For example, a semiconductor
package will contain at least six homogeneous materials as shown below.
Who does RoHS/WEEE affect?
RoHS/WEEE compliance has a direct and significant impact in the entire electronics
industry. It directly affects the development and supply chain, such as purchasing,
material control, marketing…all the way to R&D.
If you think your company is not affected by RoHS, please note the following:
· The state of California is initiating its own version of EU’s RoHs Directive, The
Electronic Waste Recycling Act of 2003, or SB20 for short, scheduled to take effect
January 2007. Twenty other states in the United States have bills pending for RoHS-like
regulations.
· China’s Regulation for Pollution Control of Electronic Products (RPCEP), which is
modeled after RoHS and WEEE, has more restrictions than RoHS and scheduled to go
into affect around July 2006.
· The green procurement practices (JPSSI) in Japan has more stringent mandates than
RoHS.
· Taiwan, Korea, Canada, and Australia are initiating versions of the RoHS directive.
RoHS affects companies who produce household appliances; IT and telecommunications
equipment, lighting equipment, electrical and electronic tools, toys, sports equipment,
medical devices, and eventually monitoring and control instruments, which will be
regulated.
Examples of industries that are affected by RoHS legislation:
a. Service Bureaus
b. Original Equipment Manufacturers (OEM)
c. Manufacturing
d. Automotive
e. Chemical Processing
f. Electronics
Who is responsible and what is required to comply with RoHS legislation?
Producers of electrical and electronic products (EEE), which include those who:
1. Manufacturer and sell their own brand of products
2. Re-sell products, produced by others, under their own brand
3. Import/export products into a member state
All are responsible for ensuring their products contain information on the levels of the six
restricted substances below the maximum concentration levels.
Producers are responsible for self-declaring if products comply with the RoHS directives
or obtain material declarations or certificates from their suppliers. Although there are no
standardized forms, these declarations need to state that materials, parts, and/or
components may be used to produce RoHS compliant equipment. The authorities within
the EU are conducting routine checks on products. If a product does not comply with the
RoHS legislation, and producers cannot prove that they have taken reasonable steps to
comply, authorities may ban the product from the EU and/or issue a penalty, including
fines and/or imprisonment.
In a recent survey conducted by Electronics Supply Manufacturing, ESM, 70% of
respondents wanted new part numbers for RoHS/WEEE compliant components. This,
along with part availability will affect Purchasing. Purchasing departments should
prepare for "end-of-life" notifications for components suppliers deem as not worth
investing in to meet the RoHS/WEEE Directives.
Material Control, important for inventory storage, will be affected by physical
identification, labeling policies, handling procedures. Inventory storage needs to be
considered because, not only should RoHS compliant and non-compliant components be
stored separately, but different components need to be stored at different temperatures.
For example, lead-free components manufactured with pure tin plating should not be
stored for longer than one week at temperatures below 13°C due to a phase
transformation known as "Tin Pest", where the tin plating converts to a powdery form
that can cause solderability and electrical continuity problems.
RoHS Compliance Issues in the Engineering World
Components and Assembly
Because alternatives for lead-free soldering, such as tin and copper, have higher melting
points than typical tin-lead solder, each component’s internal raw materials, plastics and
other encapsulation materials must be analyzed for compatibility and assurance that yield,
reliability, or parametric degradation does not occur with the increased soldering
temperature.
Since boards manufactured at higher temperatures are also susceptible to moisture,
Moisture Sensitivity Level (MSL) for each component needs to be analyzed. Interfacial
delamination, popcorn-induced cracking, warping, and bond wire separation are some of
the failures that can occur if MSL is not taken into account and considered.
In addition, the replacement on non-compliant components and product re-design must
take into account the characteristics and assembly requirements of compliant components
and soldering process. Therefore, the effect of the higher reflow temperature on the
reliability of the entire assembly needs to be assessed.
Labor
The solder type used to manufacture the board may need to be identified on boards,
because the effects of using two different solder compositions, one in manufacturing and
a different one during repair, is unknown. Although the solder is removed during
component removal, a trace of solder will still remain. Therefore, the concern is the
creation of a third alloy by two different solder compositions and its effects on solder
joint reliability and the temperatures needed to reflow the solder.
Protective Finishes on Printed Circuit Boards, PCB's
Protecting the copper finishes on the surfaces of PCB's is necessary to eliminate
oxidation and prevent bad solder joints. Hot Air Solder Leveling (HASL) has been the
preferred method used to protect the copper finishes on the surface of PCB's. Because it
uses a tin/lead alloy, other protective finishes need to be considered, most other options
available have drawbacks.
One of those options is using Organic Solder Preservative (OSP). Unfortunately, OSP
is sensitive to manual handling. Due to the significant changes needed to the assembly
process, it’s expensive.
The most expensive finish is the Electro-less Nickel Immersion Gold, (ENIG). Pricing
is about five times as much as HASL. A drawback is the “black pad” issue, where the
finish becomes brittle and cracks during mechanical stress.
Currently there are restrictions in the United States for using Immersion Tin to protect the
copper finishes on the surfaces of PCB's, because it contains a known carcinogen. Not
only does the tin solutions have a limited number of heat cycles, but allows development
of “tin whiskers”. This can develop at any time for products using lead-free pure tin
coatings, has caused the loss of billions of dollars worth of electrical equipment and
poses major safety / reliability issues to the users of high reliability electronics.