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Getting To The Source

By Jeff Reinke, Editorial Director, Product Design & DevelopmentRecent RoHS and WEEE developments continue to impact design processes abroad, and in the U.S.

There are few topics outside of the political realm that can elicit immediate responses and generate genuinely strong, opinion-based feelings on a given subject. However, that’s definitely the case when the subject of RoHS (Restriction of Hazardous Substances) is broached within the design engineer and component supplier communities.

With an estimated 50,000 electrical and electronics manufacturers in the U.S. alone, the impacts of these legislative efforts have been felt on several fronts by companies of all sizes. Backtracking a bit, RoHS regulations have their genesis in Europe, where the buildup of hazardous waste in landfills was generating significant environmental concerns. Their version of RoHS was adopted in February 2003 and went into effect last July. The generation of this increasing amount of electrical part and component waste centers around the advancement of computer and home entertainment technology, and the resulting shorter product lifespans. The environmental group Greenpeace estimates that as much as 4,000 tons of high-tech waste is discarded in the world every hour.
Just to quickly re-cap, RoHS specifically targets the use of lead, mercury, cadmium and hexavalent chromium, as well as the flame-retardants polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE). Maximum concentration values (MCVs) of the materials entail 0.1 percent by weight.
Even with the EU’s RoHS taking effect over a year ago, the UK-based National Weights and Measure Laboratory, which has been charged with regulating RoHS compliance, estimates that over 90 percent of imported products are not fully compliant, with one or two components usually containing a restricted substance.
Some of this can probably be traced to the individual enforcement of RoHS by each country. This agency also appears to have an agenda focused on a willingness to work with the product producer in getting to a compliant level.
Another reason for the high rate of non-compliance probably stems from the EU’s number of exemptions in several major product areas, such as medical and telecommunications. These exemptions stem from the unknown impacts of using different materials in vital performance areas, like a lead substitute in soldering joints. However, developments continue to be made in meeting these compliance levels so companies can mesh with RoHS developments in other markets. Additional EU exemptions can apply to:
  • Large stationary industrial tools.
  • Control and monitoring equipment.
  • National security and military equipment.
  • Some light bulbs and batteries for critical applications.
  • Spare parts for electronic equipment on the market before July 1, 2006.
Next Stop, China

Where EU RoHS seems inclined to work with producers that are not immediately compliant, China RoHS, which went into effect earlier this year, is much more stringent. It requires all electronic information products to be appropriately marked with either a compliant or non-compliant label. As of press time, the only exemption extended to imported product is the military category. Of course, China’s exports are not held accountable to these same restrictions.

Those products which contain any of the restricted substances are required to show the number of years before these substances will leak into the environment on their label. The only problem with this “environment use period” law is that little or no guidance is available to show a manufacturer or exporter how they can determine this number, or how these products will be replaced after this term.

One proposed solution comes from IPC 1752, the standard set forth for material declaration that was developed by a host of OEMs, component manufacturers, material suppliers and the National Institute of Standards and Technology. Currently, industry sources say that only 30 - 40 percent of all manufacturers are using this declaration standard in working to comply with China RoHS because of concerns over divulging too much intellectual property to a government body that has holdings throughout industry in the country.

The unfortunate response for many companies is a familiar one - manufacturing electrical components in China, or setting up distribution centers there to meet this market’s needs. However, in working to avoid that scenario, many electronic component distributors have established programs focused on helping suppliers ease the process of getting their offerings to a RoHS-compliant level.

In particular, Newark has established a 10-step quality assurance process. Although it was initially set-up for complete compliance with EU RoHS, it also provides a step in the right direction, as these regulations expand to other parts of the globe.
“As a distributor, we start by collecting RoHS data from our suppliers to pass on to our customers,” explains Jeff Shafer, senior vice president - product at Newark. In addition, we have worked with our sister distributor in the UK, Farnell InOne, to develop a rigorous due diligence process intended to further help mitigate the compliance risk for both our customers and ourselves.” These steps entail: 
  • All RoHS compliant parts are physically segregated from non-compliant parts at Newark’s warehouse.
  • Newark issues new stock numbers for each RoHS compliant part, even if the manufacturer does not change its part number.
  • RoHS data is collected and double-checked for accuracy.
  • Each manufacturer is rated using a risk assessment process that evaluates the quality of the compliance information it provides. Manufacturers are re-assessed at regular intervals.
  • Manufacturer quality risk designations for each supplier are compiled for quick reference.
  • To verify the reliability of the RoHS data furnished to Newark, they ask for additional conformance statements and independent test results, or even conduct their own third-party tests.
  • Markings are checked upon receipt at Newark’s warehouse.
  • If a discrepancy is found, they contact the manufacturer to resolve the issue. If that part is found to be non-RoHS compliant, they advise any customer who purchased the part after the date it was flagged as RoHS compliant.
  • A Newark Certificate of Compliance may be requested for any RoHS-compliant part.
  • Careful audit trails are kept to support their accuracy.

Additionally, more than one of the distributors contacted for this article said they will break down bills of materials for customers to help them understand where their products stand from a RoHS-compliance issue, and even help them re-design it.

Steve Tsukichi, the vice president of marketing at DigiKey feels that the biggest challenge they faced was, and continues to be, educating customers on the topic in order to help them order smarter. In going through the RoHS transition, his company doubled their warehousing space to handle two part numbers for several products, and allocated significantly more internal resources towards customer service, inventory management and proper order fulfillment. RoHS-centered projects represent the single largest expenditure in the company’s 35-year history, and he knows that these regulations are far from being a one-time deal.

Shafer goes on to state that while he sees some pockets of non-compliance, most multi-national companies and OEMs have become compatible, but as many as 40 percent of the suppliers Newark works with still offer non-compliant products. This creates interesting issues for distributors in having to carry two part numbers and often charge as much as 25 percent more for non-compliant components.

When Phase 2 of China RoHS goes into effect some time before the end of the year, compliance will need to be confirmed through a Chinese test house. The advise coming from many throughout the industry is for design engineers to re-examining their bill of materials for any products they are looking to ship to China. In many cases re-designs may be the rule for products that are not 100 percent compliant. Next up in Asia is probably Korea, as that country looks to implement RoHS regulations as early as next year.

Not So Wild West

While foreign markets are key for growth, RoHS concerns also exist in our own backyard. California RoHS, which took effect January 1 of this year, prohibits the sale of eight types of electronic devices:

  • Those that contain cathode ray tubes, including computer monitors and TVs.
  • Laptop computers, monitors and TVs with LCDs.
  • Plasma TVs - if they contain more than the specified concentrations of lead, mercury, cadmium or hexavalent chromium allowed under the EU’s directive.

Although California’s approach is the wider-reaching, other states have also implemented regulations focused on restricting substances like mercury. Exemptions for California RoHS include video displays in electronic medical devices, specialty equipment such as thermostats and heating regulators in motor vehicles, large commercial or industrial equipment applications and video displays in several appliances. In contrast to the EU, California does not restrict PBB or PBDE. Although these restrictions essentially target older technology, it does stir a potential hornet’s nest if other states follow California’s lead in establishing individual RoHS-focused legislation.

Can’t We All Just Get Along

“Newark has come out in support of a RoHS-like law for the U.S.,” states Shafer. “Environmental issues aside, I share the belief that one standard law is the most pragmatic and cost-effective solution for the U.S. electronics industry. And it is a long overdue discussion for Congress to have.”
The problem is that no entity has really taken the lead in trying to establish a consensus agreement as to what a U.S RoHS statute would look like. Even the E-Waste Working Group established in the House of Representatives was able to only state the obvious when it released its thoughts on how varying state regulations would negatively affect the competitiveness of U.S. electronics manufacturers.
While the dust continues to clear on the long-reaching ramifications of China RoHS, and the marketplace waits to see what happens in other parts of the world, the best advise for design engineers is to be an early adapter. By understanding the current restrictions, one can probably better understand which materials need to be controlled or avoided in future product designs. Being proactive now will most likely save time, energy and money going forward.
Product Design & Development is an industry-leading monthly magazine published by Advantage Business Media for design engineers and engineering management readers in the original equipment market. For more information visit