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Information on Pb-free Soldering

Reports

View the latest Perchards Report entitled “Transposition of the WEEE and RoHS Directives in other EU Member States” (July 2005)

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Coverage

Europe

See the original RoHS directive. The coverage has not changed since its initial release, except through the addition of other exemptions. Expanded definitions of the eight categories are provided here.

The UK Department of Trade and Industry (DTI) has recently released a comprehensive guide towards understanding how RoHS applies to you and your product.

California

In September 2004, the state of California passed SB 50, an amendment to SB 20 (The Electronic Water Recycling Act of 2003), which states that an electronic device prohibited from being sold in the European Union, as per Directive 2002/95/EC (WEEE/RoHS), shall be prohibited from being sold in California starting January 1, 2007. This broad categorization has caused some confusion among American producers about the need to change to Pb-free due to California regulations.

However, in a workshop held on April 8, 2005, the California Department of Toxic Substances Control (DTSC) clearly stated that its definition of an electronic device is limited to consumer video display devices with screens greater than 4 inches diagonally. Industrial, automotive, commercial, medical, and home appliances are exempt. The complete presentation can be found here.

China

The China RoHS legislation, developed by the Ministry of Information Industry (MII), is still in draft form. As with the EU legislation, it will ban hazardous substances (lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and “Other toxic and harmful substances or elements provided by the State”) from electronic products on July 1, 2006. There are three important differences:

  • Unlike the European Union’s RoHS legislation, which is reviewed every four years, China’s RoHS “catalog” will be reviewed annually.
  • Product categories covered by the China RoHS legislation may be gradually implemented, with only consumer electronics being affected initially.
  • Certain readings of the legislation seem to suggest that the restrictions apply to manufacturers as well as product released into the marketplace. That is, if your product is made in China, but sold in the U.S., you might still be covered by the China RoHS legislation.

Visit the Design Chain Associates (DCA) website to view an unofficial translation of the Chinese RoHS legislation.

Canada

Recycling requirements and environmental legislation are currently being handled by the individual provincial governments. There is some indication that Alberta and Ontario will soon pass WEEE-type legislation on recycling, but RoHS type legislation is currently not under consideration.

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Exemptions

The original exemptions have been expanded and modified since the initial release. A final round of exemptions has received tentative approval, pending independent technical studies of justification for exemption (view them here).

However, escalating tensions between the TAC and the European Parliament threatens the dismissal of most or all exemptions.

  • In February 2005, an EU Parliament resolution, sponsored by environmental groups, rejected the exemptions passed by the TAC in December 2004 and called on all exemptions since the passing of the RoHS legislation to be re-examined (including the current exemption of industrial controls and medical equipment).
  • In March 2005, the TAC reaffirmed its original decision to allow exemptions accepted in December 2004.
  • In April 2005, the TAC accepted additional exemptions, subject to an independent technical review.
  • In May 2005, the EU Parliament accused the TAC of exceeding its executive powers and called for an investigation.

More information on these legislative maneuvers can be found at EPP and BNA.

The great concern is additional delay and uncertainty. The EU Parliament cannot reject or change decisions by the TAC, but they can request the intervention of the European Court. This possible diversion could take months and further muddy the waters on who is expected to comply with RoHS legislation.

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Compliance

The exact methodology of ensuring compliance is still somewhat unresolved. The United Kingdom is pushing for a Europe-wide approach, but this has not been finalized. At this time, two countries have provided some guidance as to their approach to compliance. The UK has indicated that it will accept self-certification by the manufacturer, with periodic market surveillance as an enforcement mechanism. If a self-certification is challenged, then the company will need to demonstrate that “reasonable steps” have been taken to resolve the issue. At a minimum, reasonable steps would include documentation from every supplier stating conformance to the RoHS legislation. A detailed document has been made available here.

The Danish RoHS Implementation Group has put forward an example of a supplier declaration document.

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Industry Response and Concerns

Regardless of what is published and what is offered, industry still tends to move in lock-step. This is one reason why the tin/silver/copper (SAC) alloy is now the solder of choice. To find out more about what industry is doing in response to Pb-free, click here.

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