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RoHS Lessons … with a focus on Pb. David Bergman Vice President Standards, Technology and International Relations Fern Abrams, Director of Environmental Policy. Agenda. Why RoHS? What problem are we trying to “fix”? What went wrong? Compliance Issues Technical Problems

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rohs lessons with a focus on pb

RoHS Lessons …with a focus on Pb

David Bergman

Vice President Standards, Technology and International Relations

Fern Abrams, Director of Environmental Policy


Why RoHS?

What problem are we trying to “fix”?

What went wrong?

Compliance Issues

Technical Problems

Business effects

Regulatory Development Best Practices

concerns about lead
Concerns about Lead
  • 10,000 tons of SnPb solder used annually
  • Pb indicated as a hazardous element
  • Legislative action has increasingly removed it from a number of products
    • Gasoline
    • Plumbing solders and tin cans
    • Household paints
    • Bullets
precautionary principle
Precautionary Principle
  • Substances are toxic/hazardous
  • Assume exposure
  • Prevent potential risk by banning materials
  • Knowledge or assessment of whether substitutes are better for the environment not part of the precautionary principle
marketing competitive pressures
Marketing/Competitive Pressures
  • Japanese OEMs publish timelines for “lead-free” electronics
    • Mainly eliminating tin-lead solder
  • EU hears “lead-free” is possible
consumer behavior and the environment
Consumer Behavior and the Environment













Environment when purchasing


Bought product because environmentally safe or biodegradable

.(Roper 96)

Currently have product specifically because better for environment

(98 MORI).

Switched Brands after discovering harm to environment.

(1999 Environmental Research Associates Inc.)

Switch brands when price and quality

are equal.

(Roper/Cone Poll)

environmental benefits
Environmental Benefits???
  • Life cycle environmental assessment of banned materials was not conducted
  • No evidence that the substitutes have less environmental impact
  • Studies by the US EPA indicate that Tin-Silver-Copper solder in electronics has higher air, water, and global warming impacts than tin-lead solder due to higher operating temperatures
  • EU currently conducting an assessment of the costs (and hopefully benefits) of RoHS
eu rohs compliance and enforcement
EU RoHS Compliance and Enforcement

RoHS Directive does not prescribe methods to determine compliance

No documentation requirements

No prescribed testing methods

Results in legal uncertainty

Exemption process is lengthy and unpredictable

Ambiguity is costly in the business world

eu rohs implementation
EU RoHS Implementation
  • Lacked adequate technical expertise
  • Lacked adequate stakeholder input
  • From the beginning suffered from lack of clear definitions
    • “put on the market”
    • “fixed installation”
  • Lack of clear definitions caused confusion and uncertainty
eu rohs compliance and enforcement13
EU RoHS Compliance and Enforcement
  • Commission published guidance document “Frequently Asked Questions” in May 2005
  • “Intended to help authorities to interpret WEEE and RoHS Directives”
  • Reflect Commission’s views, are not legally binding
  • Some member states disagree with Commission’s interpretations
eu rohs compliance and enforcement14
EU RoHS Compliance and Enforcement
  • Lacked a clear plan for enforcement
    • Hexavalent Chromium is used in surface coatings
    • Existing test methods all measure mass per surface area NOT mass percent (mass/mass)
    • Result – no way for companies or enforcement authorities to assess whether RoHS Maximum Contaminant level has been exceeded

Concerns from High Reliability Industry

  • SnPb BGA’s will outlast SAC BGA’s by a factor of 20x (or more) using a 3 Grms JG-PP PSD spectrum (0.0062 G2/Hz under first resonance)
  • Potentially a big problem for high reliability electronics?
  • Below some threshold, all SAC BGA’s will survive more than 20 years
  • More testing and modeling required before SAC can be widely used in high reliability electronics
customer expectations are in conflict as products merge and markets change
Customer Expectationsare in conflict as products merge and markets change
  • Consumer-Large Market- Example DVD Player
    • Quality
    • Reliability
    • Product Life
  • Commercial- Medium Market-Broadband Communications
    • Quality
    • Reliability
    • Product Life
  • Military- Small Market-Electronics for the Soldier
    • Quality
    • Reliability
    • Product Life
aerospace issues
Aerospace Issues
  • Unique to Aerospace:
    • Long service lifetimes
    • Rugged operating environments
    • High consequences of failure
    • Repair at circuit card level (mixed alloys)
    • Quantify reliability at design
    • Strict configuration control requirements (obsolescence)
  • Beyond Aerospace Control (most of the time):
    • Alloys on part terminations
    • Alloys on printed wiring pad finishes
    • Reliability tests conducted by suppliers cannot be assumed to assure reliability in aerospace applications
supply chain disruption
Supply Chain Disruption
  • Suppliers Ready for Lead-Free, But Balk at New Part Numbers
    • By Rob Spiegel -- Electronic News, 11/10/2004
  • In a survey of component suppliers conducted by Technology Forecasters Inc. for Phoenix-based Avnet Inc., 94 percent of responding suppliers indicate they are designing components compliant with RoHS regulations, while only 53 percent indicate they intend to ascribe new part numbers to their lead-free components.
  • Meanwhile, a surprising 42 percent of those surveyed by the firm indicated they do not intend to create new part numbers for compliant components.
supply chain disruption23
Supply Chain Disruption
  • iNEMI Wants Unique Part Numbers for Select Lead-Free BGA Parts
    • Rob Spiegel -- Design News, May 9, 2007
  • The International Electronics Manufacturing Initiative (iNEMI), released a statement Monday indicating that the majority of its OEM and EMS members strongly support unique part numbers for BGA (ball grid array) components to differentiate any lead-free ball metallurgies other than SAC 305 or SAC 405
  • iNEMI members supporting the position include 3M, Agilent Technologies Inc., Alcatel-Lucent, Analogic, Celestica, Delphi Electronics and Safety, Huawei Technologies Intel, Jabil Circuit, Microsoft, Micro Systems Engineering, Plexus, Sanmina-SCI, Solectron and Tyco Electronics.
cost of rohs compliance oem
Cost of RoHS Compliance- OEM

1B consumer electronics company

10K parts from 500 global suppliers

10M in design and documentation

3M in equipment upgrades

1M for soldering equipment

2M in test equipment

Full time staff of 10 dedicated to directives

½ time from additional 50 people

cost of rohs compliance component distributor
Cost of RoHS Compliance- Component Distributor
  • “RoHS-related expenses are costing us “millions and millions of dollars”
  • Increasing our staff 5 to 7 percent
  • Additional time and money by legal
  • Marketing department to spread the word on a company's RoHS-compliant products
  • IT department time and effort
cost of compliance
Cost of Compliance


Higher Materials Costs

Supply Chain Management for in-scope and out-of-scope products

Higher energy costs due to higher operating temperatures


Need for tight inventory control and purchasing

Excess and obsolete inventory

Materials Declaration and compliance testing

china rohs better and worse
China RoHS – Better and Worse
  • The Good
    • Items will not be added to the catalogue for substance limits until it is demonstrated to be technically feasible
    • Homogeneous materials adjusted to include minimum testable sizes
  • The Bad
    • Mandatory in-country testing
    • Inadequate lead time between regulatory development and regulatory deadlines
    • No exemption process
regulatory best practices
Regulatory Best Practices

Environmental life cycle assessment of substance bans prior to implementation

Transparent process

Technical input

Consultation with industry

Clear regulations and enforcement plan from the beginning

Adequate lead time for orderly implementation

Clear and efficient review process

Internationally harmonized regulations for a global industry

thank you
Thank you
  • David Bergman
    • VP Standards, Technology & International Relations
  • Fern Abrams
    • Director of Environmental Policy
  • IPC Shanghai Office +86 21 5497 3435
  • IPC Headquarters U.S. 001 847 615 7100