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Lead-free: China RoHS Requirements
December 31, 1969 |Estimated reading time: 7 minutes
China RoHS is very different from the EU’s RoHS. With the March 1st China RoHS deadline looming, the directive offers a new set of risks and opportunities. This article aims to inform readers about China RoHS’ legal and operational requirements, and outline key points to reduce costs and save time.
By Jim Dills, The GoodBye Chain Group and Robert Rowland, RadiSys Corporation
China’s gross domestic product (GDP) increased six-fold between 1984 and 2004. In the first half of 2006, it grew nearly 11%. Today, China is the world’s largest region for electrical and electronic manufacturing. Furthermore, China’s 2005 average income of $1,290 (USD) is expected to rise sharply. The country likely will emerge as the top consumer of electrical and electronic products. It is expected that by 2010, China will have more than 1 billion cell phones. The downside to China’s success are enormous environmental problems:
- China has 5 of the world’s 10 most-polluted cities;
- 25% of citizens lack clean drinking water;
- China ranked 133rd out of 146 countries in a university study on environmental sustainability;
- The World Bank estimates that air and water pollution cost the Chinese economy up to 8% of its GDP.
China also surpassed the U.S. as the world’s largest municipal solid-waste generator. In comparison to recycling industries in Japan and the U.S. that generate $360B and $100B, respectively; China’s $5.4B recycling industry is already inadequate. It’s within this context that reasons behind China RoHS are best understood.
“China RoHS” is the colloquial name for the “Measures for the Administration of the Control of Pollution by Electronics Information Products” Directive. Like the EU RoHS, it targets products sold domestically, and restricts the use of the same six substances at the same maximum concentration values (MCVs - Table 1). What are the differences? Nearly every other part is different (Table 2).
A Two-phased Approach
Phase 1: Labels and Tables. Effective March 1, 2007, China RoHS Phase 1 covers more than 1,800 electronic information products, including medical devices, components, PCBs, and other products out-of-scope or exempt in the EU. If a company believes that none of the homogenous materials (HM) in any parts within any covered product exceeds the MCV for any of the six restricted substances, it may use the label shown in Figure 1. If just one HM exceeds the MCV, the label shown in Figure 2 must be used. Companies also must determine the product’s environmentally friendly use period (EFUP), or number of years until the product will break down and cause environmental damage. The EFUP is placed in the middle of the label, i.e. 10 in this instance.
Phase 2: Pre-market Testing & Certification. The Chinese government has not yet released its catalog of products covered in Phase 2. When released, it will contain a to-be-determined (TBD) subset of the 1,800+ products covered in Phase 1. Additional products will be added periodically. Catalog products must not contain any restricted substances above MCVs. To ensure compliance, China will require pre-market testing by an approved native lab. Assuming compliance, companies will use the China compulsory certificate (CCC) mark when placing their products on the market. Some key points of China RoHS are:
- There are no product exemptions.
- As of March 1, 2007, any unsold product in a Chinese warehouse, or on a retail shelf, must have the appropriate label and, where applicable, an information-disclosure table.
- The table must be in Chinese (Figure 3).
Operational Issues of Compliance
From design, manufacturing, and procurement perspectives, complying with China RoHS is virtually the same as EU RoHS. For example, companies must use lead-free solder, reduce the use of cadmium and other restricted substances, and revise their documentation system. All of these activities are part of building a compliance assurance system (CAS), by which companies can demonstrate due-diligence activities and mitigate penalties if a governmental agency finds them non-compliant.
China RoHS goes beyond EU RoHS, providing the final motivation to collect parts-per-million (ppm) data at the homogenous-material level for at least the six RoHS substances, and depending on requirements or proactive management, on all substances.
Figure 1. This label denotes that no homogenous materials in any parts within the covered product exceed the MCV for any substances.
Until recently, ppm data was difficult to obtain. Yes/no data had to suffice. However, in the last year, guidance from the U.K. indicates that yes/no data is not adequate. Additionally, industry examples abound where yes/no data were unreliable. By requiring Phase 2 pre-market testing, the Chinese government has moved the need to collect ppm data to center stage. More companies with financial risk are accelerating demands for RoHS ppm data, full-disclosure ppm data, or something in between. Below are three suggestions that set the stage for concerted action.
Figure 2. This label denotes that at least one homogenous material exceeds the MCV.
- Accept the handwriting on the wall. Driven by legislation, financial risk, and future opportunities, our industry is transitioning to environmentally benign products.
- Accept change - transitions are difficult. Whether it’s shifting from a “flat-world” to a “round-world” perspective, or whether it means having to take into account toxicity and other environmental parameters, delay will only increase the pain.
- Turn “compliance” into a “competitive advantage.” No one wants to “comply.” It costs money and requires extra work. Everyone wants to increase revenue, profits, and market share, while staying ahead of the competition.
With regard to collecting, managing, and reporting ppm data, one company* began RoHS-compliance work two years prior to July 1, 2006. This company supports and uses the IPC-1752 material-declaration format. Initially, they collected only yes/no information (IPC-1752 Class 1) on thousands of electrical and mechanical parts. Later, a process was developed to collect material information at the HM level (IPC-1752 Class 5). Having a homogeneous-material-information database enables users to analyze components proactively as a standard process and reactively, when necessary, in response to government or customer requests.
Figure 3. China RoHS disclosure report.
Due to a customer request, the company had to collect Class 5 information on eight product codes. Two decisions had to be made: create a database using a common software tool or select a software tool designed for the task; and collect all of the information internally or partner with outside firms to collect and archive the information. The company purchased a software tool** that supports the XML data-exchange format required in IPC-1752, and can create the disclosure tables required by China RoHS. The company also decided to partner with a consultant and a parts-procurement company.***
Figure 4. Item roll-up status report.
The time line for completing the initial data-collection effort was three months. To start the process, the company created a file for each product code that included the internal part number, the approved manufacturers’ part number (MPN), and a description of the part. This information was transmitted to one of the partner companies, and they started to collect and compile Class 5 information. Progress reports were submitted on a regular basis until the data-collection effort was completed. Every few weeks, information was transmitted to a consultant, loaded into the database software, and analyzed for compliance. Three things were discovered as the process progressed:
- Class 5 information could be obtained for 70% of the components. Remaining components had to be reported as Class 1.
- Material analysis provided by the software discovered 130 components with reporting issues. These issues were resolved by reviewing and applying several RoHS exemptions.
- IPC-1752 can’t handle mixed-parts classes (i.e. Class 1 and Class 5), and the IPC-1752 .pdf form cannot handle Class 5 declarations, if the XML file size exceeds 250k.
The third issue was a major obstacle because the initial plan involved exporting finished information into an IPC-1752-2 form. However, the IPC-1752-2 .pdf form would not handle all of the information because of size, so alternate solutions were needed. Two reports were recommended to replace the IPC-1752-2 .pdf form - a summary report and an XML report that contained all Class 5 material-declaration information (Figure 4). The file contains: red oval - description and product code number; blue oval - product summary that contains total number of parts, percentage of parts with Class 1 information, and percentage of parts with Class 5 information; orange oval - line-item status showing what type of information is in the XML report (Class 1 or Class 5); green oval - line-item status showing exemption claimed by this part number.
Lessons LearnedRoHS is a work in progress; this project was no exception. Working through all of these issues was not easy or mistake-free. In retrospect, the learning curve gradually flattened and the implementation curve increased. Lessons learned were:
- Meeting the initial ppm requirement is a time-consuming RoHS rite-of-passage.
- Collecting and analyzing information fits a bell curve; as the size of the database increases, time-to-compliance drops.
- Using a dedicated software tool and forming partnerships saves time and money.
- Acquiring information from a third-party simplifies and streamlines the data-collection effort and reduces internal staff workload.
- Providing periodic update reports is critical to satisfy customers and senior managers, and to preserve RoHS-related revenues.
Conclusion
China RoHS provides the final legislative motivation for collecting, managing, and reporting ppm data. While the initial data-gathering process can be arduous, it is accelerated through the availability of highly functional database software tools, the ability to purchase third-party data, and the ability to outsource product roll-up.
* RadiSys Corporation, Hillsboro, Ore.**Material Declaration Wizard (MDW) software, the GoodBye Chain Group.***The GoodBye Chain Group, Colorado Springs, Colo.; and Total Parts Plus, Ft. Walton Beach, Fla.
Jim Dills, managing director, The GoodBye Chain Group, may be contacted at (719) 488-0500; e-mail: jdills@goodbyechain.com.Robert Rowland, supplier engineering manager, RadiSys Corp., may be contacted at (503) 615-1354; e-mail: rob.rowland@radisys.com.