Imposing Standards for RoHS Compliance
RoHS compliance is soon to become one of the most talked about topics amongst semiconductor product manufacturers and the electronic components industry and quite rightly so. The RoHS European legislation is due to take effect by 1st of July 2006.
A key concern for all industry related bodies will be the implementation of this directive. The law itself governs the restricted use of select hazardous substances present in electrical and electronics equipment. It will impose a ban on new equipment made by these industries containing higher than agreed levels of lead, and five other restricted substances on the EU market.
In terms of environmental impact the role of RoHS is to support the reduction of harmful substances from the outset. This will ensure that any hazardous materials in question are not permeated into the environment. More and more electrical equipment finds its way onto refuse sites and land fills where there is no chemical control in place. So initially it is an environmental issue. However RoHS compliance is about so much more than just confirming whether a device is free from lead or any of the six restricted, hazardous substances. It is about the way the product is designed and the impact of potential manufacturing for future generations.
So really the problem was created quite some time ago with the electronics and electrical equipment's industrial growth. The solution now arrives in the form of legislation not to mention preventive measures where producers will be responsible for recalling and recycling consumer goods in a bid to stem the flow of equipment and components finding their way into landfill sites. It will also encourage further improvements for all stages of production to become more Eco friendly.
Originally the composition of solder used by the electronics industry was 60% of tin and 40% of lead. As a result of the ban manufacturers will need to research other materials to develop production ready solder. When lead free solders and RoHS compliant electronic components and materials are identified it will then become a question of proving the instructions of the RoHS directory is satisfied. Precautionary measures require industry to demonstrate that products and associated processes are safe from risking contamination to the environment. A not so easy effect when the proof of adhering to such policy is consumed within the stages of production. Whereas some laws simply contain an absolute prohibition against certain actions, the RoHS directive is to ensure non-compliant products do not even reach the market. Ignorance will be no excuse; the fact that you have contravened the law is sufficient to allow a Court to convict.
There unfortunately is no quick way to demonstrate that measures have indeed been taken to comply with the proposed lead free standards. Within the guidelines of the RoHS directive the responsibility lies with the manufacturer bringing the product to the market place. However in the production process there is the opportunity to formulate an individual method to define how products are RoHS compliant.
It may well be argued strategies of demonstrating adherence to the RoHS conformity come with a multitude of affecting factors. Frequently called into question are the concerns of budget limitations and resourcing issues. But this will pay no dividend to a lapse in compliance, as breach of legislation will not go without discipline. It therefore is important that regulations are met irrespective of cost and resourcing.
Getting away with it
So what then of the implications of failing to meet with the RoHS legislation? As illustrated in a recent press release by Electronicstalk, details of an imposed penalty are documented with "the attempt of a renowned internationally active electronics company" that recently tried to roll out products in Europe via the Netherlands.
The Dutch authorities stopped the cadmiumcontaining import (contravening the applicable Dutch law), issued a fine of Eur 17 million and goods to the value of Eur 226 million had to be returned to be reworked." This exemplifies how European legislation is to be taken seriously and any attempts to bypass regulations will not been met with lenience.
There is however a general means to demonstrate adherence to the RoHS directive These come in the form of a ‘self declaration' which is supported by outside information and a collaboration of data. Such data is comprised specifically for checking by a third party to document the manufacturer's compliance within the regulatory boundaries. It is through a supportive relationship between the suppliers and the company that information can be obtained. The Information between the manufacturer and supplier can then be used to confirm that the merchandise is exempt of all banned substances, which could be in breach of the legislation.
The collaborated information is then put together to encompass all components and materials to ensure RoHS compliance. This method of obtaining and compiling information is certainly acceptable within the guidelines of the RoHS Directive and as a result makes the verification of data sources considerably more feasible. But if the reliability of this method and the accuracy of the information to be called into question then there is the additional means of chemical analysis, which could prove to be an invaluable resource for quality control. Using this type of testing any question of uncertainty may be illuminated. Chemical analysis can be an exceptionally important quality assurance utilised where, any doubts arise.
There are three main tests, which could be used to identify materials and components. The XRF Screening method is a very effective, cheap test which has good portability and is effective in achieving required results. The data may then be evaluated in accordance to IEC62321, standard, Version 1. With any peripheral cases a ‘wet chemical analysis method is used as a control test which in effect provides a strong degree of accuracy and will deliver good conclusive results. The XRF screening method is, fast, cheap and has good portability and will deliver required results where information and data is accessible. For example it is useful when a manufacturer is checking products shipped from abroad. It has the qualities of a control test method rather than a front-line test method. Conventional analysis methods such as semi quantitative X-ray fluorescence analysis (non selective for Cr-VI compounds and for PBB and PBDEs are highprecision test and analysis methods.
It is after such rigorous control testing when a manufacturer can be reassured that they are in compliance with RoHS legislation. Companies should now be well into the stages of considering product integration and developing plans to initiate the imposed regulations. A problem has been identified and the direction of a solution enforced. It is with this regulation that we can hope for a greener environment and with initial changes the practice will become standard.
