Life with RoHS: How is the directive doing in Europe today?
By John F. Mason -- EDN, March 27, 2007
The European Union’s Restrictions of Hazardous Substances (RoHS) directive took affect on July 1, 2006, declaring that electrical and electronic equipment must not contain more than the permitted concentrations of six substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers.
Almost nine months in, how is EU RoHS going? What companies are having trouble? And what are they doing about it? The European Commission’s answer is an intelligent guess at the moment, being in the midst of an analysis of just this question, and the EC doesn’t expect to have an official answer for several months.
“In a nutshell, because of the many stakeholders involved from different sectors and continents, some of them may have wished that the implementation of the RoHS directive had been smoother and easier to adhere to,” a Commission spokesman said, adding that companies are coping very well. “They are finally understanding the importance of the changes required and trying to go along with them. The new rules have been broadly accepted and their relevance recognized. An important indicator is also that some of our major trading partners are adopting RoHS-like legislation. In any case the forthcoming review will provide further insight on stakeholders' views and we will remove any unnecessary administrative burdens or costs that are revealed.”
However discussion with European companies show they are not as consistently comfortable as the Commission seems to be.
“Adhering to the EU Commission’s changing rules and regulation has been a burden, but not from what you might expect,” said Markus Terho, director of environmental affairs at Nokia. “Technological implementation has been straightforward; the burden has been, and still is, that the legal requirements keep changing. We would have liked the requirements frozen, giving us a year to implement them. Instead, the changes are frequent [and] sudden changes by the Commission are not transparent.”
Nokia noted greater challenges on a global scale. “Since our products are manufactured and used globally, we feel that the changing rulings issued by the European Union should apply throughout the world,” Terho said. “If not, we could be exposing people to hazardous substances.”
Terho also questioned the return on Nokia’s investment in RoHS activities. “The cost element is tricky. We have tens of thousands of engineers and have hired more because of the rapid technology changes—all of whom spend time implementing changes. How much this extra work costs we have not calculated.
“As for all this being worthwhile, this, too, is tricky. The time spent doing all the above could have been used to improve our products in other ways.”
One thing Terho is grateful for are the exemptions permitted in EU RoHS, allowances that are not being included in some other environmental regulations impacting the electronics supply chain. While Nokia itself has not made any requests for RoHS exemptions, it does use some of the 30-plus exemptions that have been granted.
“You can not have an integrated circuit without some lead, which is still allowed. Each component has from two to 20 materials, and in the device you need to determine how many, such as lead, cadmium or chromium, have been used. In a mobile phone we have from 50 to 350 components. So we are talking about thousands of components which makes it very difficult -- if not impossible -- to test them all. We know some small companies make products that do not comply, but the regulators can not test them all.”
Freescale Semiconductors France SAS is in a similar situation, although its outlook differs.
“Freescale France had several years to prepare for EU RoHS, and the EU had an open process to ensure the industry understood the regulations,” Griffin Teggeman, manager of Freescale’s Environmentally Preferred Product Program, said. “Preparation was a major global effort for Freescale involving technology development, product qualifications, and material content certifications. Things have been relatively quiet in Europe since July 2006. Most of the activity has shifted to Asia.” [See: “China RoHS: Ready or not, it’s here”]
As for problems, Freescale reports fewer issues with suppliers and with its own internal work than expected.
“We provide customers with at least a year’s notice before ending production on [lead] products, which is still legal,” Teggeman said. “We’ve been asked if RoHS has been a burden, costly or worthwhile. Unfortunately, the answer is all of the above. Technology required for the initial implementation was costly, as was product qualifications, compliance process development and staffing. The on-going information collection, certification and delivery process is an industry burden; it uses resources that might otherwise develop new products or solve new problems. Yet, if RoHS can effectively reduce the hazardous substances in the environment, it will be worthwhile.”
While the Commission has been deluged with requests for exemptions, like Nokia, Freescale has not asked for any. The company is, however, a member of several industry organizations that did request exemptions on behalf of the semiconductor industry during the early phases of RoHS. Exemption 15 -- lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages -- was the most critical for Freescale as it prepared for RoHS, Teggeman said. “We have not actively supported or opposed any subsequent EU RoHS exemptions,” he noted.
Exemptions not a free pass
Those companies that are most influenced by RoHS exemptions are military/defense and aerospace, which, because of the critical electronics they deal with, are not held to the same RoHS standards as other vertical electronics makers. But exemptions aren’t always a free pass and companies, including Airbus, have felt the push and pull of the European directive.
“Though aeronautic is considered ‘out of scope’ of the RoHS ruling, it is affected anyway because our supply chain has to transition from lead-based to lead-free alternatives,” Bruno Costes, Airbus’ head of industrial coordination, said, noting that the company has been tracking the RoHS directive since its preparation, providing responses and aerospace information to the Commission and European aerospace associations.
“As for problems, RoHS concerns practically all industry sectors, which has required an in-house and supply chain revamping to all involved to lead-free manufacturing with various alternatives,” Costes said.
In doing so, Airbus has set up a lead-free working group involving all necessary sectors of the company’s 16 production sites for current and for new lead-free systems.
“RoHS becomes a burden when there is a restriction on a substance, coordinating this internally and with suppliers represents a substantial cost.”
