Transcript Will your Company’s Products Meet the European Directive

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
Business effects
Regulatory Development Best
Practices
WHY ROHS?
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
•
•
•
•
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
100%
76%
66%
45%
50%
50%
44%
1993
20%
1998
0%
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.)
Switch brands when
price and quality
are equal.
(Roper/Cone Poll)
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 TinSilver-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 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
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
Reliability mode Whiskers
New failure mechanisms
Concerns from High Reliability Industry
Predicted Time to Failure
at Constant 3 Grms (0.0062 G2/Hz) Input (years)
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
U6
U18
14.3
297
4145
19.2
7010
23800
40
330
35850+
0.6
13.3
102
0.8
1.6
228
• 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
•
•
•
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
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 ComplianceOEM
•
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 ComplianceComponent 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 RoHScompliant 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
Higher Material Costs
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
• 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
•
David Bergman [email protected]

•
Fern Abrams [email protected]

•
•
VP Standards, Technology &
International Relations
Director of Environmental Policy
IPC Shanghai Office +86 21 5497
3435
IPC Headquarters U.S. 001 847 615
7100