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Rowland on RoHS 2 Draft Exemptions
July 14, 2010 |Estimated reading time: 4 minutes
As I noted in my last column on RoHS 2, it seems like only yesterday that we were struggling to meet the July 1, 2006 deadline for EU RoHS (Restrictions on Hazardous Substances). In December 2008, the EU Commission revealed plans to recast the existing RoHS Directive (nicknamed RoHS 2). RoHS 2 is intended to be an improved version of the existing RoHS legislation; the objective is to develop a regulatory process that is simple, understandable, effective and enforceable. RoHS 2 is still a proposal at this time; it must be formally approved before it becomes official. The RoHS 2 approval vote is provisionally set for October 2010.Exemptions were a key part of the original RoHS Directive. Certain materials are exempt if no suitable alternative material is available for a specific application or if material availability is not sufficient to meet demand. The proposed list of exemptions is similar to the most recent list of approved exemptions. The 29 exemptions that were in place for the past few years have been modified and expanded to 39 exemptions. There is one major change to the exemption process--the new exemption list will include expiration dates. Before they expire, manufacturers can re-apply if suitable alternatives are not available.RoHS Directive 2002/95/EC prohibits the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) in electrical and electronic equipment (EEE) put on the market after July 1, 2006. Exemptions are listed in the Annex (which is now a separate document) to the Directive. According to notes in the new Annex it was necessary to make substantial changes so the original Annex was replaced.The new Exemption Annex includes three key statements:
- Certain applications should continue to be exempted since the elimination of those substances in specific applications is still scientifically or technically impracticable. It is therefore appropriate to maintain those exemptions.
- For certain applications the elimination or substitution of those substances has become scientifically or technically possible. It is therefore appropriate to delete those exemptions.
- For certain applications the elimination or substitution of those substances will become scientifically or technically possible in the foreseeable future. It is therefore appropriate to set expiration dates for those exemptions.
Many of the exemptions in the new Annex impact the PCBA industry. Here is a list of exemptions most likely to impact PCBA's and SMT assembly. Some of these exemptions include recommended expiration dates.7(a). Lead in high melting temperature type solders (i.e. lead-based alloys containing 85% by weight or more lead).
7(b). Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network management for telecommunications.
7(c)-I. Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices or in a glass or ceramic matrix compound.
7(c)-II. Lead in dielectric ceramic in capacitors for a rated voltage of 125 V AC or 250 V DC or higher.
7(c)-III. Lead in dielectric ceramic in capacitors for a rated voltage of less than 125 V AC or 250 V DC. Expires on January 1, 2013 and after that date may be used in spare parts for EEE placed on the market before January 1, 2013.
11(a). Lead used in C-press compliant pin connector systems.
11(b). Lead used in other than C-press compliant pin connector systems. Expires on January 1, 2013 and after that date may be used in spare parts for EEE placed on the market before January 1, 2013.
14. Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80% and less than 85% by weight. Expires on January 1, 2011 and after that date may be used in spare parts for EEE placed on the market before January 1, 2011.
15. Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages.
23. Lead in finishes of fine pitch components other than connectors with a pitch of 0.65 mm and less.
24. Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors.
33. Lead in solders for the soldering of thin copper wires of 100 μm diameter and less in power transformers.
34. Lead in cermet-based trimmer potentiometer elements.RoHS 2 and the new Exemption Annex is an evolutionary step in European environmental compliance. RoHS 2 will likely go into effect in the 2012 to 2014 timeframe if the vote in October goes forward and RoHS 2 is approved. Now is the time to start developing and implementing a strategy for complying with RoHS 2.
Reference: Exemption Annex (11.11.2009) to Directive 2002/95/EC
Rob Rowland is currently the Supplier Engineering Manager at RadiSys Corporation. He has more than 25 years of experience with surface mount manufacturing technology. Rowland is currently serving as the technical director of SMTA International. He received the Founders Award from the SMTA and several Distinguished Committee Service Awards from the IPC for his contributions to IPC-7095. He is the co-author of the book "Applied Surface Mount Assembly." He received a Bachelor of Science Degree in Manufacturing Engineering from Weber State University.