A RoHS Update

RoHS-An Update
Bob Wettermann, MIT
April 2015

Your BEST choice in Solder Rework/Repair/Test, Solder Training & Soldering Tools
ROHS Overview
A. History
B. 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

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
BGA
Test 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 0.8
U6 297 7010 330 13.3 1.6
U18 4145 23800 35850+ 102 228
Predicted Time to Failure
at Constant 3 Grms (0.0062 G2
/Hz) Input (years)

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
 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 ppm
In production of electrical and electronic appliances and is concentrated
in batteries, switches and thermostats, and fluorescent lamps.
 Cadmium (Cd): < 100 ppm
Used in electronic equipment, car batteries, and pigments.
 Hexavalent Chromium (Cr VI) < 1000 ppm
Polybrominated Biphenyls (PBB): 1000 ppm
Flame 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 ppm
Flame 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?

A RoHS Update

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