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Ring in the new rules

Environmental mandates continue to challenge the design and electronics supply chain as the industry moves into 2008.

By Barbara Jorgensen, Contributing Editor -- EDN, January 8, 2008

If you thought compliance with Europe’s Restriction of Hazardous Substances (ROHS) would get you through the next phase of environmental mandates, think again. ROHS was only a preview of the challenges the electronics supply chain will be facing in 2008 and beyond.

“The bottom line is there will be more products and restricted substances covered under both the ROHS and WEEE [Waste Electrical and Electronics Equipment] initiatives,” said Gary Nevison, director of legislation and environmental affairs for distributor Newark. “Exemption categories will be reviewed [this year] and exemptions may or may not be withdrawn. A review of the mandates’ scope and definitions could lead to more products falling within restrictions.”  For example, medical equipment and monitoring and control instruments—currently excluded from ROHS—are very likely to be included following an EU review.

Uncertainty still surrounds China’s environmental mandate—commonly referred to as “China ROHS”—as the industry waits to see which products will be subject to controls. A catalog describing which products and their substance restrictions is expected to be published by the end of this year.

Additionally, designers will have to concern themselves with the EU’s Energy Using Products directive (EUP)  and REACH. EUP aims to improve the environmental performance of products through lower power consumption. REACH is a new EU regulation that aims to ensure all chemicals are fully tested by industry and used in safe ways.

Electronics designers, in short, must concern themselves with the entire product lifecycle. At the front-end, components and solder must be free of lead and other restricted substances. Throughout their useful life, devices must consume less energy. And on the back end, electronics have to be easily recycled.

“You wouldn’t think a designer would have to worry about recycling,” said Nevison, “but the costs of recycling extend all the way down to a removing a screw or some plastic clips that can easily be undone so PCBs can quickly be taken apart. So many things must be changed and the onus [of change] falls on the design engineer.”

Any kind of consistency within various global environmental mandates is still a long way away. Many component makers, OEMs, and EMS (electronics manufacturing services) providers will still have to contend with two parallel universes: one in which their customers require compliance and one in which they do not.

For example, Sensata Technologies, a manufacturer of sensors and controls, serves customers in both ROHS-compliant and ROHS-exempt industries. Many customers, particularly those in the automotive and aircraft industries, design systems to exacting safety standards. Because different materials perform in different ways, Sensata provides its customers with its best available test information. “We may have 30 years of test information on a motor control compressor that has lead in the contacts and 6 months worth of testing on the same product that is ROHS complaint,” said Stuart Sleeman, safety manager for Sensata. “We can tell our customers that the latter product works, but is that the one you want?”

Sparton Corp, an EMS provider that serves the defense, medical and aerospace industries, faces the same dilemma. Some customers are reluctant to switch to ROHS-compliant products for design and safety reasons. However, component makers are continuing to phase out noncompliant product lines rather than produce two “flavors” of the same device. “For an OEM to change from leaded to lead-free at the design level is a big deal,” said Dave Hockenbrocht, CEO of Sparton. “You have to do the design and then do the testing to determine if the lead-free products meet all the [industry safety] requirements. In some cases, they don’t.”

Although power-consumption regulations are slightly less burdensome, design engineers will still have to choose components and materials carefully. “Companies have to look at designing equipment with good ventilation because fans are a big consumer of power,” said Newark’s Nevison. “Low power-consumption ICs will also help. A lot of emphasis will be put on the design stage.”

Overall, Sparton’s Hockenbrocht said, environmental compliance “is still a very technically complex work in progress. I think it’s at least another 5 years before [mandates such as ROHS] are mature and are settled out.”

Upcoming mandates and how they impact the electronics supply chain

Versions of ROHS
ROHS was initially developed in the EU, but similar legislation is being adopted worldwide. China ROHS, for example, came into effect in March 2007, and applies to a very wide range of electrical equipment sold in China.

Phase 1 of China ROHS started in March and requires all electrical information products to be marked. There are no substance restrictions in phase 1, but pollution control labels indicating if any ROHS substances are present at concentrations above the maximum limit are needed. If a ROHS substance is present, a table of hazardous substances needs to be printed in Chinese in the instruction manual. The product packaging further requires a label that lists the codes for all of the main packaging materials used.

Phase 2 will start when the Chinese authorities publish a catalog of products subject to substance restrictions. All products in the catalog must be certified by approved Chinese test laboratories before they can be sold. It is likely that further phases will follow. 

Korea has adopted the “Act for Resource Recycling of Electrical and Electronic Products and Automobiles” and this was scheduled to be implemented on January 1. This legislation is the Korean equivalent of EU ROHS and WEEE, but there are differences. Namely, the Korea ROHS scope will initially be restricted to consumer and some office equipment made in large quantities. The Korean government recently announced that the substance restrictions will be the same as EU ROHS, with similar exemptions. As in the EU, Korea ROHS compliance is by self-declaration, but manufacturers and importers will be required to make declarations of compliance on a Korean government Web site.

REACH
REACH aims to control hazardous substances by ensuring chemicals are tested and used safely. Beginning in 2008, designers and manufacturers should check with suppliers to determine that chemicals and preparations will not be withdrawn from the market; look in manufacturer’s safety data sheets to identify hazardous materials as the most toxic substances are more likely to be withdrawn from the market; and avoid using any materials that contain hazardous substances in new product designs.

EUP
These measures will force designers to utilize new energy technologies including: switch-mode power conversion, integrated ICs, efficient transistors, resonant switching, and synchronous power rectification. Designs will also need to have low power consumption when not under load.

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