RoHS Lessons with a focus on Pb

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RoHS Lessons with a focus on Pb

• David Bergman
• Vice President Standards, Technology and
  International Relations
• Fern Abrams, Director of Environmental Policy

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Agenda

• Why RoHS?
• What problem are we trying to fix?
• What went wrong?
• Compliance Issues
• Technical Problems
• Business effects
• Regulatory Development Best Practices

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WHY ROHS?
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Concerns about Lead

• 10,000 tons of SnPb solder used annually
• Pb indicated as a hazardous element
• Legislative action has increasingly removed it
  from a number of products
• Gasoline
• Plumbing solders and tin cans
• Household paints
• Bullets

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Precautionary Principle

• Substances are toxic/hazardous
• Assume exposure
• Prevent potential risk by banning materials
• Knowledge or assessment of whether substitutes
  are better for the environment not part of the
  precautionary principle

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Marketing/Competitive Pressures

• Japanese OEMs publish timelines for lead-free
  electronics
• Mainly eliminating tin-lead solder
• EU hears lead-free is possible

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Consumer Behavior and the Environment
100
76
66
50
45
44
50
20
1993
1998
0
Consider Environment when purchasing (Roper 96)
Bought product because environmentally safe or
biodegradable .(Roper 96)
Currently have product specifically because
better for environment (98 MORI).
Switched Brands after discovering harm to
environment. (1999 Environmental Research
Associates Inc.)
Switch brands when price and quality are
equal. (Roper/Cone Poll)
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8
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WHAT WENT WRONG?
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Environmental Benefits???

• Life cycle environmental assessment of banned
  materials was not conducted
• No evidence that the substitutes have less
  environmental impact
• Studies by the US EPA indicate that
  Tin-Silver-Copper solder in electronics has
  higher air, water, and global warming impacts
  than tin-lead solder due to higher operating
  temperatures
• EU currently conducting an assessment of the
  costs (and hopefully benefits) of RoHS

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EU RoHS Compliance and Enforcement

• RoHS Directive does not prescribe methods to
  determine compliance
• No documentation requirements
• No prescribed testing methods
• Results in legal uncertainty
• Exemption process is lengthy and unpredictable
• Ambiguity is costly in the business world

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EU RoHS Implementation

• Lacked adequate technical expertise
• Lacked adequate stakeholder input
• From the beginning suffered from lack of clear
  definitions
• put on the market
• fixed installation
• Lack of clear definitions caused confusion and
  uncertainty

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EU RoHS Compliance and Enforcement

• Commission published guidance document
  Frequently Asked Questions in May 2005
• Intended to help authorities to interpret WEEE
  and RoHS Directives
• Reflect Commissions views, are not legally
  binding
• Some member states disagree with Commissions
  interpretations

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EU RoHS Compliance and Enforcement

• Lacked a clear plan for enforcement
• Hexavalent Chromium is used in surface coatings
• Existing test methods all measure mass per
  surface area NOT mass percent (mass/mass)
• Result no way for companies or enforcement
  authorities to assess whether RoHS Maximum
  Contaminant level has been exceeded

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Reliability mode Whiskers
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New failure mechanisms
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Concerns from High Reliability Industry

• SnPb BGAs will outlast SAC BGAs by a factor of
  20x (or more) using a 3 Grms JG-PP PSD spectrum
  (0.0062 G2/Hz under first resonance)
• Potentially a big problem for high reliability
  electronics?
• Below some threshold, all SAC BGAs will survive
  more than 20 years
• More testing and modeling required before SAC can
  be widely used in high reliability electronics

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Customer Expectationsare in conflict as products
merge and markets change

• Consumer-Large Market- Example DVD Player
• Quality
• Reliability
• Product Life
• Commercial- Medium Market-Broadband
  Communications
• Quality
• Reliability
• Product Life
• Military- Small Market-Electronics for the
  Soldier
• Quality
• Reliability
• Product Life

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Aerospace Issues

• Unique to Aerospace
• Long service lifetimes
• Rugged operating environments
• High consequences of failure
• Repair at circuit card level (mixed alloys)
• Quantify reliability at design
• Strict configuration control requirements
  (obsolescence)

• Beyond Aerospace Control (most of the time)
• Alloys on part terminations
• Alloys on printed wiring pad finishes
• Reliability tests conducted by suppliers cannot
  be assumed to assure reliability in aerospace
  applications

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Supply Chain Disruption

• Suppliers Ready for Lead-Free, But Balk at New
  Part Numbers
• By Rob Spiegel -- Electronic News, 11/10/2004
• In a survey of component suppliers conducted by
  Technology Forecasters Inc. for Phoenix-based
  Avnet Inc., 94 percent of responding suppliers
  indicate they are designing components compliant
  with RoHS regulations, while only 53 percent
  indicate they intend to ascribe new part numbers
  to their lead-free components.
• Meanwhile, a surprising 42 percent of those
  surveyed by the firm indicated they do not intend
  to create new part numbers for compliant
  components.

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Supply Chain Disruption

• iNEMI Wants Unique Part Numbers for Select
  Lead-Free BGA Parts
• Rob Spiegel -- Design News, May 9, 2007
• The International Electronics Manufacturing
  Initiative (iNEMI), released a statement Monday
  indicating that the majority of its OEM and EMS
  members strongly support unique part numbers for
  BGA (ball grid array) components to differentiate
  any lead-free ball metallurgies other than SAC
  305 or SAC 405
• iNEMI members supporting the position include 3M,
  Agilent Technologies Inc., Alcatel-Lucent,
  Analogic, Celestica, Delphi Electronics and
  Safety, Huawei Technologies Intel, Jabil Circuit,
  Microsoft, Micro Systems Engineering, Plexus,
  Sanmina-SCI, Solectron and Tyco Electronics.

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Cost of RoHS Compliance- OEM

• 1B consumer electronics company
• 10K parts from 500 global suppliers
• 10M in design and documentation
• 3M in equipment upgrades
• 1M for soldering equipment
• 2M in test equipment
• Full time staff of 10 dedicated to directives
• ½ time from additional 50 people

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Cost of RoHS Compliance- Component Distributor

• RoHS-related expenses are costing us millions
  and millions of dollars
• Increasing our staff 5 to 7 percent
• Additional time and money by legal
• Marketing department to spread the word on a
  company's RoHS-compliant products
• IT department time and effort

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Cost of Compliance

• RD
• Higher Materials Costs
• Supply Chain Management for in-scope and
  out-of-scope products
• Higher energy costs due to higher operating
  temperatures
• Training
• Need for tight inventory control and purchasing
• Excess and obsolete inventory
• Materials Declaration and compliance testing

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Higher Material Costs
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Higher Material Costs
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China RoHS Better and Worse

• The Good
• Items will not be added to the catalogue for
  substance limits until it is demonstrated to be
  technically feasible
• Homogeneous materials adjusted to include minimum
  testable sizes
• The Bad
• Mandatory in-country testing
• Inadequate lead time between regulatory
  development and regulatory deadlines
• No exemption process

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Regulatory Best Practices

• Environmental life cycle assessment of substance
  bans prior to implementation
• Transparent process
• Technical input
• Consultation with industry
• Clear regulations and enforcement plan from the
  beginning
• Adequate lead time for orderly implementation
• Clear and efficient review process
• Internationally harmonized regulations for a
  global industry

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Thank you

• David Bergman bergda_at_ipc.org
• VP Standards, Technology International
  Relations
• Fern Abrams fabrams_at_ipc.org
• Director of Environmental Policy
• IPC Shanghai Office 86 21 5497 3435
• IPC Headquarters U.S. 001 847 615 7100