| Another RoHS/WEEE Update!
There has been increased interest in the European regulations
relating to the elimination of lead so we are following up last
month’s discussion with another update on how the industry
experts are interpreting the regulations and how this will affect
electronic assembly manufacturing.
As the deadline approaches for the European regulations concerning
limiting lead use in electronics, interpretations of the regulations
are beginning to take shape. As with any law passed by a legislative
body, it will be up to the courts to officially interpret the regulations.
Recently, experts in the electronics field have begun making recommendations
on how the new laws should be followed and this update includes
a review of some of these recommendations.
BACKGROUND:
The RoHS and WEEE regulations have targeted a specific group of
electronic products and the list includes the following:
(1) Large household appliances
(2) Small household appliances
(3) IT & Telecommunication equipment
(4) Consumer equipment
(5) Lighting equipment - Light bulbs and luminaries
(6) Electrical and electronic tools
(7) Toys, leisure & sports
(8) Medical equipment systems (with the exception of all implanted
and infected products)
(9) Monitoring and control instruments
(10) Automatic dispensers
The laws also specifically exclude a group of products as listed
below:
- Electronic products intended to protect national
security and/or for military
- Automotive
- Aerospace and aeronautical
- Electronic products where electricity is not main
power source
- Electronic products where electronic products are
not needed to fulfil the primary function
- Electronic products that are part of another type
of equipment (not confirmed)
- Electronic products that do not have a direct function
outside that equipment
- Batteries
- Electronic products covered under battery regulations
The lists for the most part are clear with a few overlaps that
will have to be clarified. These include dual use products such
as car radios, and computing equipment used in aerospace. Clarification
of the scope should be published by the end of 2004.
One of the major questions to be answered is how the courts will
interpret the definition of "lead free". The law states
lead can not be present at a concentration greater than 0.1% by
weight per homogeneous material. Homogeneous material is defined
as “a material that can not be mechanically disjointed into
different materials”. Mechanically disjointed means that
materials can be, in principle, separated by mechanical actions
such as unscrewing, cutting, crushing, grinding and abrasive processes.
Previously, it was assumed that this meant the component including
the solder would be a homogeneous material. The industry experts
now interpret homogeneous to mean the actual solder joint alone.
It also means the solderable surface on the component lead. This
will require companies to maintain a maximum lead content in their
wave solder pot of 0.1% which will require closer monitoring then
previously anticipated. This may end up being one of the more costly
wave solder process control steps in converting to lead free until
all tin/lead coated components are no longer in use. It will be
critical that all component lead finishes are lead free to eliminate
solder pot contamination and to comply with the regulations. One
of the questions then becomes whether tin/lead leaded components
can be retinned with a lead free solder.
There is some good news in all of the expert opinions. Previously,
it was thought that the deadline of July 1, 2006 meant products
could not be sold after this date. The experts now interpret the
law to mean that “put on the market” will most likely
be the time the product leaves the manufacturing site. This interpretation
allows lead-containing stocks on the shelf and in warehouses of
distribution to be sold after July 1, 2006.
Another concern is how will the law be enforced? Every state (country)
in the European Union is required to establish their own laws to
meet the requirements of RoHS and WEEE. The RoHS laws can not be
more restrictive but the state’s laws to cover WEEE can be
more restrictive. It may be possible that each country has a different
set of regulations that producers must meet. From a compliance
standpoint, there are draft guidance measures being issued by some
states. As an example, the UK Government recommendations are shown
below.

Some of the recommended steps to meet compliance to the regulations
may include:
- Prepare for self-declaration under ‘due diligence’
- Gain assurance from suppliers in standard format
suitable for auditing
- Carry out analysis to check accuracy of declarations
- Ensure traceability. Keep records and make use of
part number changes
- Take all ‘reasonable steps’
Many questions still remain unanswered concerning interpretation
of the law and how the laws will be enforced and very little
time is remaining. It will be critical for assembly processes
to be working towards a lead free process now in order to meet
the requirements if their products are being offered for sale
into the European Union in 2006.
CUSTOMER INTERVIEW
OMRON CORPORATION
SN100C Proves It’s High Reliability Even for Industrial
Equipment Used Under Severe Conditions
Industrial Automation Business Company (IAB) of Omron Corporation
has declared their policy to change its control equipment to lead
free for the first time in the industry, which are used for industrial
automation equipment. As of early 2003, 26 new products had been
converted to lead free. The plan was to have all new equipment
converted by April 2003. Moreover, their current products will
be adapted to lead free by the end of March 2005.
In the Mishima factory, where they manufacture PLC’s (Programmable
Controllers) and similar products, they started to study the change
to lead free in 1998. The requirements for these control instruments
for industrial use are much more severe than typically required
for consumer products. If and when some troubles occur, the influence
can be enormous. Thus, the soldering materials must offer better
reliability under these sever conditions. Thermal stress cycle
testing to as much as –40°C /+105°C for more than
2000 cycles is required.
IAB collected lead free solders from the major solder manufacturers
in Japan, and tested them under the same conditions. After testing,
IAB chose SN100C as one of the standard lead free solders for wave
soldering.
“The key of the decision”, said Mr. Ken-ichi Kusui,
the production group manager of Mishima System Factory, “is
its finish status after soldering. In a nutshell, we loved its
beautiful face.” They adopted it for commercial use in May
2001. Accumulated shipment of the products with SN100C reached
5000, “but no circuit failures of the products have yet been
reported.”
“On top of that, with the experience of the use of SN100C
for over 2 years,” he noted, “there are less dissolved
impurities in the solder bath with SN100C than any other leads
free solder, after impurities in the molten solder are checked.
It means the easiness of maintenance of solder in the bath.”
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. |