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RoHS: Y2K for OEMs?
December 31, 1969 |Estimated reading time: 3 minutes
Determining RoHS-compliance preparedness and redesigning products to satisfy the Directive is the main discussion topic between EMS providers and OEMs.
By Rod Howell
OEMs intending to ship electronic products into the EU after July 1, 2006, must comply with the RoHS Directive. This means the finished product and components within must comply with strict limits on the weight-percent content of lead, hexavalent chromium, cadmium, polybrominated biphenyls and polybrominated diphenyl ethers.
Determining compliance and redesigning products to satisfy the Directive is the number-one discussion topic of EMS providers and the OEMs they serve. With the implementation date approaching, OEM design engineering resources are in high demand. The demand is something of a microcosm of the Y2K challenge the IT industry addressed more than five years ago. It was a challenge that was overcome through a focused and concerted effort. With the same effort from OEMs and EMS partners, RoHS compliance can be achieved.
Penalties for violating the Directive have not been determined; and compliance is based on the honor system with producers self-declaring compliance for exported products. The responsibility for certifying compliance seems focused on the OEM, except in less-common instances where EMS providers also contract for distribution.
Products subject to the Directive have been divided into ten categories. Exemptions have been proposed for Category 8 and 9, as well as some areas within Category 6. As part of their compliance strategy, the burden of responsibility falls on OEMs to determine if they will be covered by these exemptions and others being proposed. These exemptions should be treated as temporary “stays.” Non-compliant components will be progressively more restricted. OEMs with exempted product categories should work to redesign existing products and design new, fully-compliant products.
Ensuring Compliance
How does one ensure RoHS compliance? There are several steps:
- Bill of Materials (BOM) “scrubbing” to determine current compliance of each component.
- Research and specification of alternate components to address non-compliant items within the BOM.
- Redesign of the product to adapt to new components and new assembly-process conditions.
- Implementing new assembly processes.
- Prototyping of redesigned assemblies.
- Reliability testing of new, compliant designs.
- Production.
The work required to complete each step will vary depending on product complexity and current component use. Many progressive EMS companies are working side-by-side with OEMs to complete each task.
Working with an EMS provider to assist with product compliance should include several considerations. Process knowledge and a solid implementation plan for new assembly technology is a must-have. After careful review of the OEM’s internal engineering capacity, the OEM should consider the EMS provider’s ability to assist with BOM analysis, redesign support, prototyping and pilot builds, reliability testing and failure analysis.
While some product classifications may be exempt for a period of time, the mass market for components and assembly services will eventually convert to RoHS compliance. Decreasing availability of materials containing tin/lead will affect exempt products, as well as those not intended for export to the EU, forcing some level of redesign due to obsolescence. Current data indicates that mixing lead-free assembly processes with eutectic tin/lead components (particularly BGA and other area-array types of packages) can result in less reliable interconnects. Increased process temperatures for lead-free processes would also cause problems with current SMT components that cannot tolerate peak reflow temperatures of 260°C.
Separation and control of different types of components will become critical to assure that a given product is truly RoHS-compliant. Currently, there is no universal agreement within the supply chain to designate unique part numbers for compliant components vs. non-compliant items. Many component manufacturers choose to identify compliant parts by lot code or date code instead of unique part numbers.
While the EMS industry is in favor of new part numbering schemes, no industry-wide agreement has been reached. The EMS provider will need to institute procedures to distinguish between RoHS-compliant and non-compliant components. This will help ensure that each compliant OEM product contains only compliant components and is assembled with lead-free soldering.
Conclusion
It is nearly inevitable that some amount of non-compliant material will be stranded as excess and obsolete inventory because of this transition. OEMs must work closely with EMS partners to implement changeover plans.
RoHS implementation is being compared to the Y2K scenario for good reason. Component engineers and PCB designers seem similar to Cobol programmers of 1999 in terms of short-term capacity requirements. Currently exempt industries will be affected eventually. Careful planning and close coordination throughout the supply chain will minimize costs and impact on OEMs and EMS providers.
Rod Howell, president, Libra Industries, may be contacted at (440) 974-7770; e-mail: sales@libraind.com.