New RoHS Exemptions - No Big Deal
The latest amendment to the RoHS directive greatly expanded the exemptions list in the annex. But did it really have a big impact on the environment or on compliance activities?
The RoHS directive has been amended three times in 2005. The first one officially added the concentration limits everyone was assuming. As of 19 Aug 2005, the official, allowed concentration limit for Cadmium (Cd) is 0.01% by weight in homogeneous materials. The other five have an allowed concentration limit of 0.1% by weight. This official declaration was added as a note to the annex.
On 15 October 2005 the EC exempted decabromodiphenyl ether (decaBDE) and Lead (Pb) in "lead-bronze shells and bushes." DecaBDE is one of the class of PBDE flame retardants. It turns out to be less hazardous than pentaBDE or octaBDE, both of which have been banned in the EU for some time. Though decaBDE is an effective flame retardant, most electronics manufacturers are either phasing out all brominated flame retardants or never used them in the first place. This was reported in a survey conducted by IFP Research for the Swedish Chemicals Inspectorate (KEMI). Lead has been used in bronze bushings for years as a self-lubricating material around rotating steel shafts.
Less than a week later, on 21 October 2005, the EC released the latest amendment. This one removed the 2010 expiration of the server exemption and added five very specific exemptions permitting the use of Pb. It is now acceptable to use Pb in compliant pin connector systems, thermal conduction module c-rings, microprocessor pin to package connections, and Flip Chip packages. In addition, Pb and Cd may be used in optical and filter glass.
Obviously, a few sectors will feel the greatest impact. Server manufacturers are now completely off the hook. Certain IC packages may continue to use Pb solders freely. It does look like the crystal glassware industry will be hurting.
Still, is it really that big a change? Consumer and business PCs must comply and there are far more of these ubiquitous boxes sold than servers. While telecom infrastructure is exempt, cell phones and other mobile devices using the telecom networks must all comply.
To me it still looks as though the only smart strategy is to aim for compliance. The vast majority of products, by weight, must be RoHS compliant. So the same pressure exists to convert the supply chain to compliant parts. Soon it will be almost impossible to buy non-compliant components. Engineers are learning that the new PC board materials designed for higher-temperature Pb-free solder have higher quality and lower defect rates than the old FR4.
Certainly a strong business case can be made for using an exemption if a large part of your business exists completely inside the scope of the exemption. Just keep in mind that the rest of the industry is evolving and the EC is far from being finished with new directives that will impact electronics. China RoHS contains no such exemptions, the law is written only in Chinese, and the comment period ends 27 November 2005. An EC exemption will likely be of no use whatsoever in China on 1 July 2006.
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Report (PDF) by IFP Research for KEMI on DecaBDE flame retardant and alternatives.
Europa RoHS and WEEE web site with links to the directives (Legislation) and to the amendments (Secondary legislation).