RoHS Rolling On
By Bob Hult, Bishop & Associates Inc.

The introduction of environmental mandates such as RoHS illustrates how Europe and Asia are taking the lead in environmental issues, leaving the United States no other choice than to follow. Taking an aggressive stance on solving the problem of toxic e-waste, the European Union member states created a series of directives aimed at addressing both the production and disposal of electronic and electrical equipment. RoHS (the directive on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment) has been in effect for nearly two years, and global manufacturers have adapted to the new requirements. The objective was to eliminate six materials used in the manufacture of electronic equipment, which the European Union deemed as serious health hazards. The banned material with the greatest impact on the electronics industry is lead, a major component of traditional solder.

A second directive, WEEE (Waste Electrical and Electronic Equipment) focuses on the collection and recycling of electronic equipment. These two directives have changed the design and manufacture of electrical and electronic products throughout the world.

The EU directives prohibit the sale within any member state of equipment that contains these materials. Not willing to pass up a market of that size, manufacturers have made the necessary changes. For the connector industry, the change involved finding a suitable replacement for traditional 60/40 tin/lead plating and solder.

Much gnashing of teeth occurred over the difficulty in changing proven soldering processes, as well as creating new part numbers. Distributors feared the additional cost of duplicating inventories. Serious questions were raised about which class of products had received exemptions from the rules, and how long they would be in effect. Connector companies were forced to evaluate their plastic housings to determine if they could withstand higher reflow temperatures required by lead-free solders. In some cases, new plastic materials were adopted, which necessitated tooling new molds. Large OEM users bemoaned the cost of documenting all new part numbers in their approved material documents, as well as updating their product specifications.

Now, two years later, the world has conformed to the E.U. demands, and the problems and associated costs have been fewer than anticipated. The adoption of matte tin seems to be an acceptable plating substitute. Achieving consistently reliable soldered joints required increasing the time/temperature of the reflow process—which added cost and raised questions about an environmental mandate that results in the consumption of more energy. The concern about duplicate inventories of leaded and unleaded parts never materialized, as most manufacturers adopted the lead-free process for all of their products. The original exemptions granted to select classes of products, such as military and telecommunications, are unchanged, and will be re-evaluated in four-year cycles. Most interconnect systems today are promoted as being RoHS-compliant.

Some questions still remain. We still have no data on the long-term reliability of lead-free contacts and soldered parts. The question about compatibility with compliant pin technology remains unanswered and will continue to be scrutinized, as the exemption granted for these applications will be reviewed in 2010. The issue about tin whiskers remains the elephant in the room. The exact mechanism of their formation is still not understood, leaving the industry to hope that a nickel underplate and good plating practices will minimize the problem. A new IEC test specification for tin whiskers is currently out for ballot approval, but there is some concern about repeatability of the proposed test and thus, the value of the specification. Tin whiskers will likely continue to be an unintended consequence of RoHS until the mechanics of exactly how they form is fully understood, and documented manufacturing processes demonstrate consistent whisker-free plated surfaces.

A real concern in the industry is that the United States is losing control of factors that have a significant influence on how they do business. The European Court of Justice recently annulled a RoHS exemption for decaBDE, a flame retardant used in plastics. Germany and Sweden had banned the material years ago, but the original RoHS directives had granted an exemption based on data that indicated that decaBDE was inert, and did not pose a health hazard. The recent annulment of the exemption has given the industry, including connector manufacturers in the U.S., only three months to find and implement a suitable replacement. This ruling has set a precedent that a court in Europe can revise a rule at any time, with little concern about the technical or economic consequences that may result.

The trend toward imposing internal rules that have a global impact continues to grow. A so-called RoHS 2, which would ban an additional 46 materials, is currently in the input and review stage. It is doubtful that anywhere near this many materials will ultimately be blacklisted and unclear when a ban would be implemented, but the unknown factor makes long-range planning difficult, especially as U.S. manufacturers may have limited influence on the final list.

Momentum of the European Union for creating environmental mandates continued in June 2007 with the approval of the Registration, Evaluation and Authorization of Chemical (REACH) regulation. Over a period of 11 years, REACH will require the registration of approximately 30,000 chemical substances in use today. Once identified, the chemical industry will be required to provide data on the risks associated with each material and develop a plan to manage the risks to human health. The regulation has the ability to partially or totally ban the use of a material when unacceptable risks are identified. This directive will affect many of the chemicals routinely used in the electronics industry. It will likely create a major documentation task for the entire chemical industry, much of which is based in the United States. All U.S. exporters to Europe will be required to evaluate their supply chain of chemicals and be prepared to respond to this new environmental legislation. Pre-registration of chemicals begins June 1, 2008.

Another EU directive, the Energy Using Products (EuP), is a legislative framework that has been proposed to promote eco-design of electronic products that consume energy. The objective is to inject environmental considerations at the design level of new products, which would ultimately result in greater energy efficiency throughout the life of the product.

The EU is not the only country that has decided to manage hazards to the environment. In February 2006 China entered the environmental protection debate with ACPEIP (Administration on the Control of Pollution Caused by Electronic Information Products). Although this legislation addresses the same six hazardous materials (lead, mercury, cadmium, Hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ether), the process of managing and documenting them is considerably different.

This program, often referred to as China RoHS, is being implemented in two phases. The first phase requires the labeling of all electronic equipment destined for resale within China, and became effective on March 1, 2007. All products must carry a label that discloses any of the six identified hazardous materials. If an electronic product contains no toxic substances, it can be recycled, and carries the green environmentally friendly label.

If any of the listed hazardous materials are present in the product, a different logo must be applied which indicates the approximate number of years it will take before these materials will no longer pose a threat to the consumer. At this point, there is no scientific process by which a manufacturer can determine how long a particular piece of equipment can be considered to be in this “environment-friendly use period.”

The second phase will involve the restriction of materials where toxic substances are banned. Exactly what equipment will be targeted, and when such a ban will be enacted, is unknown at this time.

Unlike RoHS, it appears that the Chinese rules will offer no exceptions. This may change as the directive evolves, but there has been no indication of intent to exempt any class of equipment. China may also demand material testing and documentation at the individual component level, although “family” testing may be acceptable. Only certified Chinese test facilities may be allowed to perform these compliance tests, although that would likely swamp their capabilities. How these directives will be actually enforced is also very unclear. Since ACPEIP applies only to product intended for Chinese consumers, connectors or sub-assemblies shipped to China for assembly into products intended for other markets would not be affected. How China will be able to differentiate the intended end user of the product is an open question. U.S. component and equipment manufacturers have been waiting over a year for more details on China RoHS, but the enormous scope and complexity of this effort is still being sorted out among Chinese authorities. Given the market potential of China, and the immense and growing amount of electronic component as well as end-user product manufacturing that is occurring there, China RoHS will be a major factor in how electronic products are designed and built in the future.

The first wave of environmental mandates required the analysis of all existing products being sold. The certificate of compliance documentation process was established and is an accepted part of doing business. Now that this review has been completed and adjustments made, the next step is to insure that new products are designed for environmental compliance. Compliance begins at the earliest stages of design, as material data is collected simultaneously with the selection of components. Material declarations collected early in the design cycle allow the OEM to verify that none of the prohibited materials will be present in the final product. Data on recycleability of all products can be used to certify WEEE compliance, as well as promote a “green” image to the customer.

Connector manufacturers are watching this developing challenge as well as additional environmental regulations now being formulated in Korea, and even within individual U.S. states. Citing inaction on the part of the Federal government, California and several other states have begun enacting their own set of environmental standards. Lack of harmonization at the state and global level is increasing the burden on manufacturers who must stay current on the latest regulations to insure that their company is able to document compliance. The hidden costs of navigating this increasing maze of regulations adds to the economic pressure connector manufacturers are facing given the dramatic increases in the price of plastic, copper, and gold.

Few people question the value of protecting our environment. The rapid rise in population and the industrialization of countries, such as China and India, is putting a tremendous burden on limited resources, as well as creating unprecedented levels of pollution and hazardous waste. Ever shortening product life cycles of electronic products in particular are a rapidly growing source of e-waste that must be controlled. A global mandate that injects concern for recycleability at the front end of a design allows environmental compatibility to be cost-effective. The transition period we are now working through, with a myriad of individual mandates, is the source of frustration and added costs.

Component suppliers have recognized that environmental issues are here to stay and will be a continuing challenge until the day that global harmonization of environmental standards occurs.

Bishop & Associates Comments: 

1. The European Union, China, and other major economic powers are filling the vacuum created by the lack of U.S. leadership in environmental protection issues.

2. E.U. mandates, including RoHS, WEEE, and the upcoming REACH programs, are adding to the costs of manufacturers around the globe, including the United States.

3. It is interesting that the air and water quality in China is some of the worst in the world, and yet they are in the process of enacting one of the strictest environmental standards.

4. Most of the initial concerns about the economic impact of RoHS have proven to be relatively painless, but the cost of documentation and tooling changes are adding up.

5. The issue of tin whiskers is still a concern in lead-free alternative materials.

6. Designing for compliance is the most cost-effective solution to addressing global environmental mandates. Uncertainty regarding the specifics of emerging mandates complicates design efforts for new products.

7. The limited opportunity to provide input to the environmental mandate formulation process could put U.S.-based manufacturers at a disadvantage, leaving them in a response mode, rather than a proactive contributing position.

8. U.S. connector manufacturers expect the next major step in environmental protection mandates to be the announcement of target industries and implementation dates of China RoHS.

Robert Hult
Director of Product Technology, Bishop & Associates, Inc.
Robert Hult has been in the connector industry for over 36 years. Hult began his career as a sales engineer for Amphenol. He joined AMP in 1972 and served in several management positions through 1996. In 1997, Hult joined Foxconn as group marketing manager for Intel, Chandler, Arizona, U.S.A. Prior to joining Bishop & Associates, Hult was the regional application engineering manager for Tyco Electronics.

Hult graduated in 1968 from Bradley University with a Bachelor of Science degree in electronics technology and a minor in business.