Are dev tools covered by ROHS? It's debatable.

The subject of whether or not semiconductor evaluation boards, or development tools as they are often referred to, fall within the scope of the ROHS directive continues to rumble on.

Evaluation boards have always been a grey area. The problem is that they do not have one function and are, in reality, a wide variety of different products. It is fairly obvious that some are “Category 3 – IT and telecommunications equipment” and should comply with ROHS, and for that matter, the WEEE (waste electrical and electronic equipment) directive in Europe. However, some evaluation boards do not have an IT or telecommunications function and do not appear to fit into any of the categories.

The authorities like to keep things simple, and assume that all evaluation boards are the same, which they are not. One major US manufacturer has supplied many non-compliant boards, and appears to have missed the discussions that took place a few years ago.

Look back to 2006 and we can clearly remember the concerns around semiconductor evaluation boards. Were they in scope of the ROHS directive or not? Certainly manufacturers hoped not, and many believed not. This eventually resulted in NWML, the UK enforcement agency, posting guidance on their Web site. It concluded that “most evaluation boards are included under category 3 - IT equipment.”

However, while that was the view of the UK enforcement authority, in other countries such as Germany, the position was and still is that the topic is one of considerable on-going debate. With the publication of the so-called ROHS 2 proposals, the subject is again on the agenda.

Here are some simple guidelines:
-ROHS 2 does not impact any current inventory of development tools.
-Any evaluation boards that are in scope at present should not contain the current six ROHS substances, except where exemptions apply.
-Future substance restrictions will only apply to products put on the market (POTM) after the date that will need to be specified by the European Commission (EC).
-The process for restricting additional substances could take several years and will follow from the implementation of the “revised” ROHS directive. At present it is not known how long this will take. The EC should allow a transition period after the decision to restrict an additional substance has been agreed and published. New POTM dates applicable to additional substance restrictions are unlikely to be before 2012, and could be much later.
-Evaluation boards may contain some of the phthalates BBP, DBP, and DEHP for example in PVC wire, sealants, inks, adhesives, and lacquers.

In summary, there is no need to worry about current inventory, and those POTM before July 1, 2006, are out of scope anyway. However, if the four proposed substances do fall within scope, then manufacturers will need to start looking for alternatives in future products.