Article: Update On European Lead Free Legislation

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UPDATE ON EUROPEAN LEAD FREE LEGISLATION

We receive many questions on the status of the lead free laws being implemented in Europe and whether there will be laws passing in North America that would affect the electronics industry here. We know California has passed a law banning lead in CRT's larger than four inches but there is no current threat that would have the effect of the European requirements in North America at this time. More regulation may be considered as regulating bodies see that Europe has successfully implemented the lead ban in electronics. Here is an update based on the most recent industry news.

The RoHS and WEEE legislation is now in place and the directives are being acted on by the individual countries in Europe. It usually takes 18 months for member states to implement a Directive, which means laws would be passed by August 2004. With these two regulations, only Greece has fully implemented the requirements. Hungary, Latvia, and Lithuania are almost there and all other countries have been delayed. This means there are still no definitive requirements for recycling under WEEE for every country in Europe.

Under the WEEE regulations, each producer is responsible for recycling costs and retailer take-back systems that must be in place by August 31, 2005. WEEE recycling includes the following categories of consumer products:

1. Large household appliances

2. Small household appliances

3. IT and Telecommunication equipment

4. Consumer equipment

5. Lighting equipment (light bulbs and luminaries)

6. Electrical and electronic tools

7. Toys, leisure and sports

8. Medical equipment systems (exceptions-all implanted and infected products)

9. Monitoring and control instruments

10. Automatic dispensers

Growth in these wastes is 3 times any other wastes and is expected to double in 12 years. An example used is computers. In the 1960's, computers were used for 10 years. In 1998, the average computer was used for 4.3 years. In 2000, computers averaged 2 years usage before disposal.

The WEEE Directive also requires communication of what hazard is present so the user and treatment facility can act accordingly. The information must include the identity of the hazard and its location within the product.

The biggest question now is which products are included in the RoHS and this is subject to interpretation until someone is found in violation and the courts have a chance to act and interpret the law. The list is clear for many products, such as consumer, office, and IT. The exemptions are also clear and include automotive, aerospace, and military. What is not so clear are the overlapping products such as car radios, and computers for aerospace. Clarification is expected by the end of the year but the final decision will again be up to the EU Court of Justice. For lead exemptions, there is still one in place for component manufacturers who use the high melting point alloys containing more than 85% lead. This is because there is no lead free alloy with similar high melting points. There is no technical replacement for processes requiring solder with a melting point greater than 250°C.

Once it is determined that the product produced is within the scope of the requirements, the control of lead content then has to be considered. The RoHS has set an impurity limit for lead at a maximum concentration of 0.1% per homogeneous material. The question now is what is a homogeneous material? The Council around November 2004 will consider the definition. The current interpretation is that homogeneous material means a material that can not be mechanically disjointed into different materials. Under this definition, solder joints will need to be less than 0.1% to meet the requirements. This will require wave solder pots to be maintained with less than 0.1% lead. This could increase the costs during transition as many parts may still have lead plating, which will dissolve into the pot during the soldering operation.

So you have determined the status of your product and you are implementing a lead free program to meet the requirements. Now management wants to know what happens if you are found in violation. How are the laws going to be enforced? RoHS compliance is the responsibility of the individual EU States (25 countries!) which means there may be as many as 25 different compliance laws. Each State will determine penalties and the EU Commission can prosecute the individual States for non-compliance. The control methods will most likely be a combination of methods:

• A standard reporting format
• Manufacturer self-certification
• Audit testing under a set of standard methods
• Exchange of information between States

This means more paperwork for manufacturers as the recommended steps to compliance include:

• Preparing a self-declaration using "due diligence"
• Obtaining certificates from suppliers
• Ensuring a method of traceability

Although the laws have been passed, there is still much clarification needed as to exemptions, compliance, and impurity levels. The EU States are behind in passing legislation to meet the EU Directives and will be working feverishly to meet the deadlines. The laws passed should not vary with regard to RoHS but may be quite different for meeting the WEEE Directive as the WEEE allows States to go beyond the regulation.

If your products are being sold in Europe, it is important to keep up with the regulations and the future decisions on interpretations and revisions. We will be posting any updates on the RoHS and WEEE Directives as they become available so please check our Web site regularly.

DAIKIN INDUSTRIES, LTD.

High Reliability Even With Through-hole Boards

Daikin Industries, Inc. is the world's one and only manufacturer of air conditioners that undertake the development and production of all system components, from refrigerant to hardware. Its main environmental preservation activities are namely, energy-saving of the air-conditioner, the adoption of a new refrigerant (based on hydrofluorocarbons) that does not harm the ozone layer, and recycling. Going lead-free is one of the important clauses in the recycling field. In October 2002, SN100C was adopted in Ururu and Salala room air conditioners and the ZEAS II packaged air conditioners. Both are flagship models of Daikin, and SN100C was fully adopted after the tests and comparisons of all kinds had been conducted.

The Shiga plant is the development and production base of the Ururu and Salala model. Product Development Group's Chief Engineer Mr. Takano Tomohiro said, "Driven by the worldwide cost competition, we have chosen the lead-free solder that we can be ensured of its tensile strength and reliability, and low-cost as well. In conferences and national projects, the tin-copper-silver solder has been the most researched into, but argument regarding cost is now the issue." "We are worried about the incidence of ion migration due the fact that silver easily ionizes," said Mr. Fulisawa Hitoshi of the same group.

Daikin's outdoor air conditioning unit's printed circuit board is a double-sided through-hole type, but with SN100C, "There are no lift-offs, and copper erosion is diminutive, therefore we can be confident of its quality and reliability,"  proclaimed Mr. Fujisawa. "It has also passed the criteria with regard to thermal fatigue resistance of components due to high temperature, and the bad solderability of through-hole printed boards. The optimal use of low-cost solder is our manufacturing/development technology," said Mr. Takano, proud of the company's technology.

The company's aim was to remove lead from all its manufacturing products by March 2003.

SN100C has been patented by Nihon Superior and is offered worldwide through licensed manufacturers including FCT Solder for North America. We offer SN100C for wave solder and lead tinning application and SN100CL for lead free hot air solder leveling (HASL) of P.C. Boards.

We will be including in future newsletters, many of the advantages our current customers have discovered in switching to SN100C as their lead free alloy of choice and we welcome your comments and questions. We look forward to working with you to make your transition to lead free as successful as possible. 

For more information about our products, please visit our web sites at www.finelinestencil.com for stencil products and www.fctassembly.com for solder products.

All files for stencils, templates and PCB carriers should be sent to sales@finelinestencil.com to assure immediate attention.

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