A RoHS Update

RoHS-An UpdateBob Wettermann, MIT

April 2015

Your BEST choice in Solder Rework/Repair/Test, Solder Training & Soldering Tools

ROHS Overview

A. HistoryB. RoHS1 (5 pages)C. RoHS2 (23 pages)


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 Household paints Bullets Batteries Plumbing Solders


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 Japanese OEMs publish timelines for “lead-free” electronics

Mainly eliminating tin-lead solder

EU hears “lead-free” is possible


Consumer Behavior and the Environment

20%

45%50%

66%

76%

44%

0%

50%

100%

Consider Environment when purchasing (Roper 96)

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.)

1993

Switch brands when price and quality

are equal.(Roper/Cone Poll)

1998

Your BEST choice in Solder Rework/Repair/Test, Solder Training & Soldering Tools 8


WHAT WENT WRONG?


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 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(1) 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 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


Reliability mode Whiskers


New failure mechanisms


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

BGATest Vehicle 5, SnPb Solder

Test Vehicle 7, SnPb Solder

Test Vehicle 8, SnPb Solder

Test Vehicle 77, SAC Solder

Test Vehicle 79, SAC Solder

U4 14.3 19.2 40 0.6 0.8U6 297 7010 330 13.3 1.6U18 4145 23800 35850+ 102 228

Predicted Time to Failure

at Constant 3 Grms (0.0062 G2/Hz) Input (years)



Aerospace IssuesUnique 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

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 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


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 “RoHS-related expenses are costing

us millions and millions of dollars” Increasing our staff 5 to 7% 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 R&D Higher Materials Costs Supply Chain Management for in-scope and

out-of-scope products Higher energy costs due to higher operating

temperatures Training Need for tight inventory control and

purchasing Excess and obsolete inventory Materials Declaration and compliance testing


Higher Material Costs

Current price approx $7.50


Higher Material CostsCurrent Price $16.50


RoHS1

2002 voted on by EU member states Take effect July 2006 Restricts (6) substances for electronic

assemblies 8 specific consumer areas Medical, transportation, IT

infrastructure, military were some of the exemptions


Restricted Substances Lead (Pb): < 1000 ppm

Electrical and electronics industry solder, lead-acid batteries, electronic components, cable sheathing and in the glass of cathode-ray tubes.

Mercury (Hg): < 100 ppmIn production of electrical and electronic appliances and is concentrated in batteries, switches and thermostats, and fluorescent lamps.

Cadmium (Cd): < 100 ppmUsed in electronic equipment, car batteries, and pigments.

Hexavalent Chromium (Cr VI) < 1000 ppmPolybrominated Biphenyls (PBB): 1000 ppmFlame retardants found in electronic and electrical appliances. They have been found in indoor dust and air through evaporation from plastics.

Polybrominated Diphenyl Ethers (PBDE): < 1000 ppmFlame retardants found in electronic and electrical appliances. Combustion of printed wiring boards release toxic emissions.


RoHs2

2011 voted on by EU member states Entered in force July 21, 2011 Member states adopted and went in

to force Jan 2, 2013


RoHs2 Differences from RoHs1 Expanded Scope of Application Definition of an EEE Restricted Substances Conformity Assessment and CE

Marking Exemption Procedure


Expanded Scope for RoHS2 Large and small household

appliances IT and telecom Consumer equipment Lighting equipment Electronic tools


RoHs2 NOW Applies to Medical devices Monitoring and control devices Industrial control devices “Other” category now covered by

2019


Exclusions in RoHS2 Military equipment Equipment in space Large scale tools Large fixed installations Implantable medical devices R and D equipment for B to B


Broadened the Scope Definition of EEE changed “Any equipment needing electric

currents or electromagnetic fields to fulfill its intended function”


RoHS2 and CE Mark

Declaration of Conformity is required

Technical File is required CE mark on the EEE CE marks means conformance to

RoHS2


RoHS2-More Restricted substances? (36) additional substances on the “to be

investigated list” Many commenters pointed out that it

should be based on science!~ Now periodic review of what substance the

member states want as part of RoHS Have to bring science in to the equation Complete life cycle costs (Unintended

consequences-EPA and RoHS1)


RoHS2-More Restricted substances? TBBA is on the list (Bound in to FR4 for

flame retardance) PVC is on the list


Exemptions have Expiration Dates

5 years for categories 1-7, 10 and 11 7 years for categories 8 and 9 Can apply for extensions-need 18 months

prior to date, commit to a 6 month prior to deadline answer


Manufacturer Shipping to Europe

What is now required under RoHS2? EU Declaration of Conformity Technical File CE Marking Product Marking


Declaration of Conformity Unique identification number Name and address Object of declaration-catalog or photo of EEE Statement of conformity-is in conformity with

Directive 2011/65/US of the European Parliament and Council of 8 June 2011

Which references to the technical conformity declared

Signature, place, address and date

Also need safety and declaration in language of the markets being sold



Technical File EN50581 General description of product Conceptual design and manufacturing

drawings and schemes of sub-assemblies Description and explanation for

understanding of these drawings Results of design calculations Examinations carried out Which standards the EEE conforms to What risks there are in conformance to this

standard


Materials Declaration IPC-1752A Meant to exchange data with supply chain Not a compliance doc Defines what data is to be collected and

shared Defines computer language (XML) for

sharing NOT a reporting form


Questions?

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A RoHS Update

Entertainment & Humor