Intel's Bold Challenge
In a little-known, yet very bold move, Intel is preparing to stare down EC regulators over the ill-defined RoHS reporting requirements. By choosing to report material content concentrations for the entire component, Intel will force the EC to clarify exactly how concentration limits are to be calculated.
The Intel strategy is clearly displayed in their Material Declaration Data Sheets. This public document contains material declarations for many of Intel's products. The 55 page report contains a sheet for each of the covered IC packages. To understand the implications, you need to read it carefully.
Consider the page for the SSOP package with 48 to 56 leads. The bullet item "This product contains lead/lead compounds" is marked with a large, bold "YES." Below the bullet is a table specifying the lead (Pb) content. I have reproduced this table in RoHSwell format for convenience.
| Description of Use | Location in Product | Material Concentration (ppm)2 | Material Mass (g)3 | |
| Lead/Lead Compounds | Leadframe finish | Leadframe | 500 |
Note 2 says that ppm concentrations can be used to estimate content for similar packages. This is in no way surprising. What I find interesting is that the table arrangement implies that concentration is reported for the leadframe finish. Most companies consider each plating layer to be a homogeneous material, as defined by a RoHS guidance document. If you simply stopped there and took the table at face value, you might conclude that the leadframe plating on this Intel package has only a 500 ppm concentration of Pb. You would be very wrong.
The key is to read note 3 attached to the empty Material Mass column. Note 3 reads, in-full, "Material mass can be estimated by multiplying concentration (ppm) by product weight." The concentration formula is then
| Material Mass | |
| Concentration = |
|
| Part Mass |
This is very different from the more common interpretation of the homogeneous material restriction
| Substance Mass | |
| Concentration = |
|
| Homogeneous Material Mass |
What Intel has done is to draw a line in the sand and say that material declaration stops at the component level. There will be no concentration calculations made from measurements of every substance in every material used in the component. Intel provides only the component mass and, indirectly, the mass of each reportable substance in the component. It is a bold strategy however you look at it.
Intel has invested considerable energy into their material declarations. The company is also very active in standards activities and has several large programs aimed at improving their environmental profile. Like most large companies, Intel has dozens of people working hard at doing the right thing in the constantly moving realms of regulation and culture. Management obviously expects this compliance approach to pay off.
It is not a wildly popular strategy within the electronics industry. I have observed lots of ruffled feathers around this topic. Consider though, that what is popular regarding RoHS is largely driven by fear. Most businesses fear risk, and RoHS has huge associated risks. Everyone wants a guaranteed, definitive answer to questions about RoHS. The majority thinks safety lies in homogeneous material reporting.
In reality, the issues will not be resolved until compliance challenges are converted into legal precedents by the courts. Intel is simply refusing to give in to the fear.
Right or wrong, Intel has taken a stand. It appears to be driven by common-sense, economics and a desire to comply with the regulations. Intel differs from the rest of the industry by pushing back on the regulations in a meaningful way.
One thing is clear regarding this stare down. If the regulators blink, Intel will look like a strategic genius.
