RoHS Exemptions for the Connector Industry

BY BOB HULT

Surprise! You may have thought that with the impending deadline now only 12 months away, the industry would have a clear definition of compliance to the Restriction of certain Hazardous Substances (RoHS) Directive. The connector industry has responded with a pure tin solution and set in motion a variety of channels by which users can implement lead-free components, but confusion continues to reign among many system manufacturers.

The current bump in the road to compliance involves the evolving issue of exemptions to the RoHS Directives. RoHS Directives were created to be capable of addressing the many types and applications of electronic equipment and provides a process for establishing temporary exemptions until a viable alternative to lead can be proven. The original document contained 10 exemptions, such as products intended for military, server, storage, and network infrastructure applications. A lack of reliability data using lead-free interfaces in long-term applications prompted these exemptions. The Technical Adaptation Committee (TAC) reports to the European Commission and is charged with evaluating the merits of all exemptions to determine the validity of a request. Approved exemptions are reviewed for elimination on a 4-year basis as new solutions are introduced. The TAC accepted several additional exemptions including compliant PCB terminations in December 2004, but a conflict over procedural issues and perhaps basic philosophy between the TAC and the European Parliament has turned the process into a political power struggle. Since then, another 22 exemptions have been submitted for consideration. It is unclear exactly what documentation will be required to achieve approval or who is responsible for providing it. Many of these new exemptions are expected to be approved, but there is no assurance if and when that may occur. The European Parliament has clearly indicated that increased cost does not justify granting an exemption. In mid-April, the European parliament plenary body moved a step closer to taking legal action against its own Commission, further clouding the status of all proposed exemptions.

The result in the electronics community has been:

1. Confusion and frustration;
2. Delayed commitment;
3. Differences in interpretation;
4. A logistical nightmare for the entire supply chain.

Electronic component users and suppliers can be absolutely certain that the one aspect of the directives that is cast in concrete is the 7/1/06 implementation date.

Manufacturers of electronic equipment have many years of experience working with leaded solders and tin/lead interfaces. They are understandably reluctant to adopt alternative materials without thoroughly evaluating their performance in both the assembly process as well as in their specific application. Concerns about tin whiskers on pure tin finishes, increased insertion forces on compliant pins, as well as changes to existing solder reflow processes have resulted in a series of new exemption requests to the TAC. Manufacturers are struggling with questions involving interpretation of the existing exemptions as well as the status of exemptions currently in review. Companies that offer a broad range of products will either switch all of their manufacturing lines to lead-free or establish separate production lines and component inventories. This will be particularly tough on subcontractors who build a variety of products for many customers. Distributors are also facing the daunting task of maintaining both standard and lead-free equivalents of thousands of part numbers.

The ultimate responsibility for certifying compliance to the RoHS directives is the company whose name is on the box. The unclear status of pending exemptions is causing some manufacturers to delay their decision to adopt lead-free components, which may result in a potential stampede as the implementation date approaches. Last minute order changes could put real pressure on component manufacturers and the entire supply chain as they struggle to maintain delivery commitments. Suppliers must decide which product lines will be converted to lead-free, and how their part numbers will be changed. The issue of component obsolescence and the ability to support existing long service life equipment in a variety of exempted applications adds one more twist to the situation.

By the way, there is one additional indisputable aspect of the RoHS directive: the rules will change again. Participants are advised to stay tuned for the latest updates.

BOB HULT, director of Product Technology, may be contacted at Bishop & Associates, 1691 Vigilante Ave., Bailey, CO 80421; e-mail: rhult@bishopinc.com.

Lead-free Electronics July, 2005
Author(s) :  Bob Hult

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