Time to catch up on RoHS & WEEE

Apologies to any who read this about my long silence regarding RoHS. For the record, I still hate it. But during the
last five weeks, I have been so busy I haven’t had a chance to read all
the posts on the technical forums I subscribe to. After spending the
last couple days reading through a few hundred e-mails, here are the notes
of interest from the IPC TechNet & LeadFree forums, from posts
submitted in late July through early August of this year:

  • In late July, there was a post from a manufacturer of military
    items who was highly frustrated with electronics manufacturers &
    distributors. Among other things, it was stated that about 50% of electronic
    parts manufacturers have eliminated lead (Pb) from part finishes without
    changing part numbers, forcing the equipment manufacturer to use XRF
    equipment to identify which parts would have the 3% lead finish required
    by the mil specs. Even more worrisome was the statement that some parts
    suppliers have supplied parts that they claim are mil-spec with a pure
    tin finish, which in many (all?) cases is not a mil-spec acceptable

  • Another MIL manufacturer also stated that they are getting a lot
    of parts that they buy & spec as MIL compliant, but which are still
    sent to them in non-MIL compliant models. He made the observation that
    they can usually catch errors in incoming inspection, but that still adds
    time & money to product production. He also said that he had opened up
    his own laptop and was amazed at what he found inside, and that maybe
    the MIL world should take a look at what the commercial world is up to
    lately, since the MIL world probably couldn’t make a laptop that was as
    small and compact and durable as most commercial laptops are for even
    10 times the price of a commercial laptop.

  • Dan K. posted a link to an interesting documenting put out by
    the Electronic Industries Alliance (EIA) in September of 2000. The title
    of the document is “The Evoloution of Materials Used in Personal
    Computers”, it is six pages long, quite interesting, and available here.

  • There was some discussion about a whether a middle ground exists
    between leaded (SnPb) assembly & lead-free (SnAgCu or SAC) assembly.
    This is a tricky situation for manufacturers using ball-grid arrays
    (BGAs). Some BGAs are only available with SAC solder balls, some are only
    available with leaded solder balls. If a SAC-solder BGA is used on a
    leaded assembly, the temperatures used for the lead solder will not be
    enough to fully melt the SAC-solder balls, resulting in poor solder joints
    for that BGA. One manufacturer on the list said they they have found a
    middle ground, running leaded assemblies with SAC-solder BGAs through a
    process that gets hot enough to fully melt the SAC solder.

    Concerns from other list members were that

    • the process would run so hot that the other components on the
      assembly would be damaged,
    • the leaded solder pastes would have fluxes that would not be able
      to work in the higher temperatures, or would not be able to work for the
      entire time needed at the higher temperatures, and
    • mixing leaded solder & SAC solder leads to the formation of
      undesirable (and weak) intermetallics in the solder joint.

    The manufacturer using the hybrid process said one of the purposes of
    the high temperatures was to ensure a homogenous solder joing on the BGA
    solder balls, and as long at they did that, the equipment was passing
    all endurance & aging tests, and ongoing lifecycle testing had shown no

  • There was mention of a new specification for vibration testing
    of PCBs & PCB assemblies. Previous specifications often used a swept
    profile and dwelling at found resonances, but the the new specification
    was random vibration with a controlled frequency distribution, including
    some sub-audio frequencies.

  • There was an interesting note about how to tell if a piece was
    stainless steel or titanium. Due to differences in specific gravity,
    titanium parts will float in a pool of molten leadfree solder, while
    stainless steel parts will sink. Both titanium & stainless steel parts will
    float in a pool of molten SnPb40 solder.

    This also explains why it is important to use titanium tools with
    leadfree wavesolder machines, since if you slip and drop a tool into the
    solder bath, you don’t want it sucked into the solder pumps.

  • There is continued discussion within the industry of whether
    RoHS really is environmentally friendly or not. There are many who believe
    that it is NOT friendly to the environment (for a number of reasons)
    and in generally a very BAD idea all around (again for a number of
    reasons, and I agree with those who oppose RoHS). There are also those who
    support RoHS. One of the commonly stated reasons for supporting RoHS is
    that it makes recycling safer for those who work in recycling plants,
    since they will not be exposed (or at least not be exposed as much) to
    toxic materials such as lead (Pb), cadmium (Cd), etc.

    Another side to the debate about whether WEEE & RoHS create an
    environment with more & safer recycling is discussion about where this
    recycling is being done. There are a number of videos taken of “recycling”
    in the Orient (especially in China) which show mounds of electronic
    trash being put in a heap, burned right next to a river or seashore, and
    bits of melted & solidified metal being picked out while the rest of the
    slag heap is left where it sits. But how prevalent is this really?
    Robin I. said that some of the worst recycling she had ever seen was done
    in China, Malaysia, Singapore & Indonesia, but some of the best & most
    efficient recycling she had ever seen was also done in China, Malaysia,
    Singapore & Indonesia. Even more notable was the observation that as
    more affluent people in the industrialized nations trade up for newer
    computers, phones, TVs, monitors, etc., it would make the most sense for
    the old BUT STILL WORKING OR FIXABLE items to be made available for sale
    to those who are not as affluent and who would be willing to pay a
    lesser amount for an older or smaller item. But because of protectionist
    concerns of large manufacturers regarding market cannabalization and
    counterfeiting, many times old electronic gear has to be significantly
    damaged before it will be sent off-shore. China has a ban (dating from
    2002) on working CRT units, so any units sent there have to be smashed up
    beforehand. Similar laws in California require CRT recyclers to ruin
    each CRT before sending it off to be recycled. I can’t do a better summary
    than what she has said, so I will quote a large part of her e-mail

    With all that said, the main threat to the well-run Asian refursbishing
    factories is NOT Greenpeace or BAN, it is protectionist elements in the
    Fortune 500 Electronics manufacturing, who consider refurbishing of
    computers and TVs to be “market cannabalization” or
    “counterfeiting”. China’s 2002 “ban” on CRT imports, which we had translated, specifically
    excluded working units, and when working or refurbishable units are found
    at port, the customs agent orders them smashed, then allowed in as
    scrap metal. A novel form of environmental remediation. These
    protectionist policies were put into greater force after Europe and USA attempted
    to put tariffs on Chinese made CRTs between 12 and 24 months ago. The
    net effect of all of this is to drive the recycling business
    “underground”, where standards are worse, not better.

    [. . .]

    Honest and conscientious USA recyclers, who are able to send ONLY the
    working and refurbishable CRTs, back away from supplying them while this
    “ban” is in place, and Greenpeace and BAN herald them as fine companies
    for charging residents to smash working computers. California CRT
    recycling laws specifically require the recycler to “cancel” or “ruin”
    each CRT, so that it cannot be refurbished, and charge taxpayers to
    subsidize the practice. The vacuum created by the absence of good monitors
    causes the smugglers to import from less reputable companies, who ship
    the junk and unrepairable CRTs as “toxics along for the ride”. The 2/3
    which function and are refurbished and resold disappear into the
    marketplace, the 1/3 which are junk go nowhere, the pile gets bigger, and
    Greenpeace photographs it as more proof that recycling in Asia is

    Robin’s e-mail also contained a link to http://www.wr3a.org/, the
    website of the World Reuse, Repair & Recycling Association. It looks like
    quite an interesting website.

    And as some of the more cynical (or perhaps realistic?) members of
    the lists pointed out, isn’t it strange that environmentalist groups
    (like Greenpeace) LOVE to talk about how IMPORTANT it is that recycling be
    required by the government, and how CRUCIAL it is that recycling be
    made safer and easier for those who recycle, and therefore how WONDERFUL
    WEEE & RoHS are, and how HORRID the recycling practices in more
    primitive countries, and how only MORALLY REPREHENSIBLE CRETINS would DARE ship
    government-mandated recycling off to those horrid primitive countries .
    . . but strangely, environmentalist groups never seem to put nearly as
    much energy into getting those horrid primitive countries using safer
    recycling methods. The industrialized countries need to become as
    non-impact as possible, people living in industrialized countries must forgo
    any motive like profit or wanting more convenience or just wanting a
    newer gizmo in favor of being environmentally friendly, and the
    nonindustrialized countries need to keep living in picturesque (but squalid)
    rural conditions without any contact with the nasty industrialized world.

    And the debate is still continuing. Also at issue is whether the use
    of SAC solder will increase

    • the amount of tin mined
    • the number of new tin mines
    • whether tin mining is a very environmentally unfriendly type of
      mining or not
    • all of the above concerns for silver
    • how often lead is found in ore along with tin & silver, and
      therefore how much more lead will be mined & smelted BECAUSE of the increasing
      use of tin & silver
    • whether the higher temperature required by SAC solder will result
      in greater energy usage and more waste heat generated worldwide

    Joe Fjelstad wrote a great article, “Commentary: Note to European
    Union – Repeal RoHS!”
    , dated July 25, 2006 & appearing in Electronic
    . It has
    a lot of good points about how RoHS is NOT a good idea.

  • And with regards to TBBPA (a commonly used flame retardant in
    printed circuit boards, which is NOT environmentally mobile while in said
    circuit boards, and which WAS studied for years by a European Union
    environmental impact group, and based on that study WAS exempted from the
    list of banned flame retardants in WEEE), well, . . . I guess hell hath
    no fury like an environmentalist ignored. There are still groups in
    Europe trying to outlaw the use TBBPA. There will be a meeting in
    Frankfurt, Germany, on September 7, 2006 titled “Update on TBBPA European
    Regulatory Status & Implications for Downstream Use in the Future”. I wish
    them the best of luck.

  • Speaking of printed circuit boards, there are a number of new
    laminates that have been developed. The development was driven by the
    higher temperature required by the lead-free solders, which were in
    turning damaging many of the laminates historically used with leaded SnPb
    solder. But, some of these laminates seem to do worse than the older
    laminates when used at the lower temperatures seen by the older laminates.
    Which makes no sense, since the newer laminates also seem to work okay
    at the higher lead-free temperature.

  • China’s equivalent of RoHS continues to cause concern & generate
    confusion. Official documentation is only available in Chinese. Design
    Chain Associates has had the Chinese documents translated into English.
    Copies are for here. Unlike the European
    RoHS, the Chinese RoHS may require that product documentation include a
    substance tables showing the percentage of the products that comes from
    certain substances.

  • California has also started writing RoHS-like laws into
    legislation, although for now they seem to mainly be focused on devices that
    have screens greater than 4 inches in any dimension. John Burke
    (http://www.rohsusa.com/) notes that new California assembly bills seem
    to be more grounded in reality than the EU legislative process. Among
    other things, consideration of exemptions & the exemption process needs
    to include effected stakeholders, such as environmental groups AND
    manufacturers, distributors & users. Additionally, there is a requirement
    that all new regulations have exemptions for products that a refurbished
    or sold for reuse.

    As others pointed out, there’s still a lot of time for unreality to
    set in between now & those bills becoming law, and there’s still more
    opportunity for idiocy when the regulations are implemented. But at
    least there were some legislators that tried to make it workable, which
    seems to be a lot more than can be said for the EU legislators.

  • And it’s so nice to see that the hardworking European Union
    legislators are moving right into the next phase of product regulations. If
    I were in their shoes, I would probably wait to see how RoHS & WEEE
    turn out before implementing the next phase, but then that just goes to
    show how limited my horizons are, right?

    So, the next two pieces of legislation are REACH and EuP.

    Roland Sommer, who is Managing Director of RoHS & WEEE Specialists
    (International) Ltd.
    of New Zealand, has an
    interesting presentation posted on the internet here.
    helps put WEEE, RoHS, EuP & REACH into perspective, and has some
    interesting predictions for the next few years.

  • IPC has come out with standardized forms for tracking &
    reporting which chemicals are used in products, IPC-1752-1 & IPC-1752-2.
    Specifications for filling out the forms are located in IPC-1751, IPC-1752 &
    IPC-1752-3. However, use of these forms is still not widespread.
    General feeling on the list was that lack of use was due to forms being
    introduced & finalized relatively late in the time period when most
    companies were trying to figure out how to deal with RoHS due diligence
    On the other hand, most people on the list reported a plethora of
    different formats in use for RoHS declarations, both in what they received
    from suppliers in response to requests, and what they received from
    customers are requests from them. There are still concerns that out of all
    the different formats used, many may be found lacking by the European
    Union courts with regards to whether they constitute “due diligence”.

    So perhaps IPC-1752 may become more widespread after all.

  • Chad R. posted this satire on the list:

    32 July, 2006

    Australian Government Improving Competitiveness; Legislation Passed to
    Limit Intellectual Effort

    Premier John Howard today announced legislation to enforce a
    restriction on the amount of intellectual effort required to operate electronic
    equipment. The Australian Simplification In Necessary Intelligence
    Nationalistic Exercise (ASININE) mandate would apply to electronic and
    electrical equipment, the components that make up the equipment as well as
    any media viewed on or outputs of the equipment.

    The legislative efforts are said to be driven by the increasing
    globalize complications involved in basic functions on many of the affected
    devices. Specific examples outlined in the proceedings include the
    programming of VCRs, use of in-vehicle GPS systems and basic operation of
    personal computers. The efforts are based on the need to remain
    competitive in the light of increased global competition and a shortage of
    skilled labour. Howard said in his announcement, “There is a need for the
    rapid deployment of the Australian workforce into the job market. The
    over-complication of everyday technology is significantly reducing the
    ability of the average Australian to remain competitive.”

    Howard indicated that positive steps were already taken with regards to
    the media output on general electronic devices. Following a meeting
    with U.S. President George W. Bush, the progressive steps at simplifying
    the dominant American media shown on Australian televisions was seen as
    moving in the right direction. To achieve compliance, everything from
    printed circuit assemblies to packaging would require an ASININE
    Certificate of Conformance, stipulating that minimal intelligence levels were
    involved in the manufacturing of the materials.

    Countries such as Canada and Mexico were expected to follow the U.S.
    support of the proposal. It is anticipated that the Asian countries will
    comply due to their position of manufacturing 98% of the targeted
    materials. The European Union may postpone an official position until the
    situation has been assessed by a technical consortium, which is
    currently reviewing open ROHS legislation until 2009.

  • And here are a couple of off-topic interesting tidbits I picked

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