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The RoHS Directivean answer to your questions

Geert Willems

■ www.rohsservice.be ■ [email protected]

Pb

contents 2

preface 3

part 1: the legislation, interpretation and implementation 4

part 2: technical realization 24

references 39

RoHS service 41

■ contents

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■ www.rohsservice.be

The RoHS Service, a cooperation between SIRRIS and IMEC with the support of IWT, went ahead on 1st July 2005.The aim of this service is to assist companies in implementing the RoHS directive. In the first year of operation over 100companies contacted the RoHS Service with questions concerning the RoHS directive and its implementation.

The ‘Restriction of Hazardous Substances’ or RoHS directive bans Pb, Hg, Cd, hexavalent Cr and the flame retardingfamilies of the PBB and PBDE type from a lot of electrical and electronic products that are put on the European market from1st July 2006. Because lead is a basic component of the as yet generally used tin-lead solder and no lead-free ‘drop-in’replacements exist, the impact of this directive is exceptionally great on the electronic industry and extends over the entiresupply chain. Hence, a lot of companies have questions as to both legal and technical matters. This handbook provides a number of answers to frequently asked questions concerning the RoHS directive. The first partcomprises 25 frequently asked questions as to the interpretation of the directive. The second part answers 13 frequentlyasked questions about the technical reality within the directive.

Our thanks go to the ICT department at Agoria.

■ preface

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■ [email protected]

A cooperation between

With the support of

■ Interpretation and implementation of the RoHS directive

We have gathered the 25 most frequently asked questions and answers as to the legal aspects of the RoHS directive inthis document. It answers important questions like: ■ Does our product fall within the scope of RoHS?■ Are there RoHS exemptions applicable to our products?■ Is RoHS applicable to electronic components only or to the whole product?

■ 25 FAQ on the legal aspects of the RoHS directive

The most relevant questions as to the legal side of the RoHS directive have been gathered in this chapter. The questionsare answered generically to clarify the principles to be followed. These principles may be applied according to the specificsituation of your company and/or your specific products.

1. Does our product fall within the scope of RoHS?2. Are there RoHS exemptions applicable to our products?3. Is RoHS applicable to electronic parts alone or to the entire product? 4. Our products fall under IT and telecom, category 3 and may use the ‘lead in solder’ exemption.

So we do not need to be concerned about RoHS?5. How can I find out whether my product falls within the RoHS scope or not?6. How can I obtain a RoHS exemption?7. Our products are lead-free, then surely they comply with RoHS?

Our products comply with RoHS, then surely they are lead-free?8. Must replacement parts conform to RoHS?9. How must we demonstrate RoHS compliance?

10. How will RoHS compliance be verified?11. What are the penalties for breaching the RoHS directive? 12. The electronic assembly of our products is carried out by a subcontractor whom we asked to manufacture in

compliance with RoHS from 1st July 2006. RoHS compliance is consequently the responsibility of the subcontractor and not our responsibility as OEM?

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13. We have requested RoHS declarations of conformity from our suppliers and requested them to deliver RoHS conforming components. Have we done enough?

14. How much lead can a product complying with RoHS contain? What are the maximum levels of prohibited substances? 15. One of the prohibited substances is still used in the production of a component. Can that component be used in a

product complying with RoHS?16. My product complies 99 per cent with RoHS. Am I safe? What should I do? 17. What about RoHS outside the EU? 18. I have one of our products here. Can you do some tests and deliver us a certificate of compliance with RoHS? 19. Which tests must I carry out to find out whether my (lead-free) product complies with RoHS?20. I, an OEM, still have 1000 units of non-RoHS compliant equipment in my warehouse. Can I still sell them?

(after 1st July 2006)21. My distributor still has 1000 units of non-RoHS compliant equipment in his warehouse. Can he still sell them?

(after 1st July 2006) 22. Must products I export outside the EU also comply with RoHS? 23. My customer is asking me for a declaration that the part I deliver conforms to RoHS. What is my position?

What should I do? 24. Is a RoHS label obligatory? Should RoHS compliance be certified?25. What should I do to make a non-RoHS compliant product compliant with RoHS?

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■ 1. Does our product fall within the scope of RoHS?

This is undoubtedly the question asked most frequentlyto the RoHS Service and, moreover, a question that inmany cases cannot be answered very easily. Apersistent misunderstanding must certainly be resolved:the RoHS directive is NOT limited to consumer goods.A lot of professional and industrial equipment do fallunder the RoHS directive. Electrical or electronic products that fall under specificenvironmental directives such as batteries (batterydirective 2006/66/EC) fall outside the scope of RoHSand are not considered in more detail here.In order to be able to answer the above question, threesubquestions must be answered:

Question 1: Is your product a finished product or apart of a larger whole that has been put on themarket as a finished product, or is it a part of a fixedinstallation that is not put on the market as a finished,functional unit?■ If the product is a part of a larger whole that is

placed on the market as a finished product, then nodirect RoHS obligations are involved as to this part.This all depends on what kind of product the part willbe used for. If it is a product that falls under the RoHSdirective, then the part must also comply with RoHSconditions.If this is not the case, then other or no restrictions maybe applicable. As a manufacturer of this part you are bound by the

specifications (contractually) imposed by yourcustomer, whether or not related to RoHS restrictions,but you have no direct RoHS obligations.You are, after all, not putting any finished productsubject to RoHS on the market. In fact, there is noquestion of a RoHS compliant part, only of a productcomplying with RoHS, composed of RoHScompatible parts and assembled by means of aRoHS compatible assembly process. The RoHS obligations are consequently only validfor producers/importers of electrical or electronicequipment and only indirectly for manufacturers ofparts of this equipment.

■ If the product is a part of a fixed installation, thesame is true as above. A fixed installation is defined as a combination ofdifferent devices, systems, finished products and/orcomponents assembled and/or set up by aprofessional installer at a specific location to worktogether in a predefined environment to carry out aspecific task and not intended to be put on themarket as a single functional or commercial unit. The fixed installation falls outside the scope ofRoHS as this does not relate to one of the productcategories put on the market as a finishedproduct.

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■ The product is only eligible to fall within the scope ofRoHS if it is put on the market as a finished product.At the moment, clarity is still lacking at a Europeanlevel as to what is precisely meant by a fixedinstallation. Further explanation is expected in thisregard from the European Commission.

Justification and marginal notes:If the obligation should relate to non-finished products suchas parts (e.g. electronic components), then each productcontaining electronics should by definition be made of RoHScompatible parts, and consequently also products that falloutside the scope of the RoHS directive without discussion,such as cars, airplanes and military equipment. The latter isan explicit exemption. Moreover, the WEEE directive – to which the RoHS directive

refers for the definition of product categories falling within thescope of RoHS – explicitly states in Article 2.1: “ThisDirective (the WEEE directive) shall apply to electrical andelectronic equipment falling under the categories set out inAnnex 1 A, provided that the equipment is not part ofanother type of equipment that does not fall within the scopeof this Directive.” Unfortunately, the RoHS directive does notcontain such a specification. The EU commission explicitlystates in its Frequently Asked Questions on p. 5 that the sameformulation is valid for the RoHS directive. However, the FAQlist is not a legally binding document.The discussions have not yet been completed in this regard,in particular relating to components for fixed installations. The reasoning above, also propagated by Orgalime, isapplied to electrical installations in residences and otherbuildings, whereby all electrical and electronic componentssuch as cables, switches, sockets and fuse boxes, are notsubject to RoHS (or to WEEE). Some RoHS enforcementauthorities think this is going too far. Prudence isconsequently required if your products fall in the category ofdomestic electrical installation components. If in doubt concerning the RoHS compliance requirements foryour product, it is advisable to check with the enforcementauthorities in the member states in which your products aremarketed. For Belgium this is the “Federale Overheidsdienst– Volksgezondheid, Veiligheid van de voedselketen enLeefmilieu” [Federal Public Service - Health, Food ChainSafety and Environment], DG Leefmilieu. Contact: Maya De Groot, +32 2 524 96 79,[email protected]

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Question 2: Is your product an electrical orelectronic product designed to be used at a voltagebelow 1,000 V alternating current or 1,500 V directcurrent?It is essential that this relates to the main function of theproduct that must be dependent on electricity as theprimary source of power or is directly dependent onthe electrical currents or electromagnetic fields.Without electricity the product cannot fulfil its basicfunction.If electricity is only required for supporting or controlfunctions, then this is not an electrical or electronicproduct, even if the product cannot operate withoutthese functions in practice. To clarify: an electricradiator is an electric device. A heater that operateswith fossil fuel with electronic adjustment of the air andfuel supply, however, is not an electrical or electronicproduct.

Marginal notesSome grey areas still remain. E.g.: an air conditioningunit that uses fossil fuels for heating and electricity forcooling or an electrical product that can be used bothbelow and above 1,000 V alternating current.

Question 3: Does your product fall under one of theproduct categories defined in the WEEE directive 1,2, 3, 4, 5, 6, 7 or 10 or does it relate to luminairesor light bulbs?If so, then the product is subject to RoHS.The difficulty in answering this question lies in theinterpretation of the indicative product descriptions as

indicated in Annex 1B of the WEEE directive.Consequently, the list is certainly not exhaustive. The Belgian government has already stated that theseindicative descriptions must be interpreted very broadlywhen related to bringing products within the scope ofRoHS. However, it is unclear whether this is also true whenit relates to keeping products outside the RoHS scope,specifically with regard to the interpretation of category 8(medical equipment) and category 9 (measurement andinspection instruments). Hence, prudence is called for.The exception to category 6 products – Electrical andElectronic tools – “with the exception of large-scale,stationary industrial tools” – requires the necessaryattention. This exception to category 6 products is tooeasily cited to “argue” an industrial machine as outside thescope of RoHS. However, in the description of thisexception neither ‘large’ nor ‘industrial’ are of majorimportance, but the stationary character of the equipmentis. As stated in the FAQ from the EU this must relate tomachines or systems, consisting of a combination ofequipment, systems, finished products and/orcomponents, each of which is designed to be used inindustry only, permanently fixed and installed byprofessionals at a given place in an industrial machineryor in an industrial building to perform a specific task. (seealso the definition of ‘fixed installation’). It is essential thatthis installation is not intended to be marketed as a singlefunctional or commercial unit. Consequently, an industrialmachine that is marketed as a whole and can operate asa functional unit, no matter how large and difficult tomove, must comply with RoHS. In this regard the exampleof the drilling machine as a “large, stationary, industrial

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installation” given in the Orgalime guide ‘A practicalGuide to understanding the scope of RoHS and WEEE’ onp.25 is incorrect. If the finished product cannot be categorized into one ofthe product categories subject to RoHS, it does not haveto comply with RoHS. A fixed installation that is notmarketed as a functional, finished product by definitionfalls outside the product categories of RoHS/WEEE andconsequently also the parts thereof, unless the part isexplicitly mentioned, such as luminaires.As previously mentioned, the conclusion based on this, thatparts of such installations do not have to conform to RoHS,are still under discussion.

In summary, if the product is a finished product for whichquestions 2 and 3 are affirmative, then the product mustcomply with RoHS.

■ 2. Are there RoHS exemptionsapplicable to our products?

The reason for this question not being considered underthe previous one is that the RoHS exemptions are verydifferent to the product definitions and interpretationrequired to define the scope. The exemptions describevery specific applications of the prohibited substancesthat are allowed in all or some product categoriessubject to RoHS. Consequently, there are no RoHSproduct exemptions: a product either falls within oroutside the scope of RoHS. There are only exemptionsas to the use of the prohibited substances for

applications for which there are currently no propertechnical alternatives. Exemptions – as with a lot ofother aspects of the directive – should be considered tobe temporary in nature. The directive states that theexemption must be reviewed at least every four years.In the majority of RoHS compliant products one or moreRoHS exemptions will be applied. Just think of the ‘leadin ceramic components’ exemption. Which electronicproduct does not contain ceramic resistors orcondensators? The majority of exemptions are appliedat the component level. Consequently, it must beverified whether the application of the prohibitedsubstances at a component level conforms to the RoHSregulations. The regulation may be product dependent.In this way ‘lead in solder’ and hexavalent chromium(temporary until 1.7.2007) are permitted for some ofthe product categories subject to RoHS. A rareexemption is situated at the assembly level of theelectronic product: the ‘lead in solder’ exemption for ITservers and telecommunications infrastructureequipment. The impact of this exemption is great andrequires an adapted product design and productionstrategy if applied. RoHS5 products are sometimesmentioned (RoHS compliant with the exemption of leadin solder) versus the RoHS6 products (RoHS compliantfor the 6 prohibited substances).

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■ 3. Is RoHS applicable to electronic parts alone or to the entire product?

The RoHS limitations on the use of the prohibitedsubstances are valid for the complete, finished product,not only the electronic parts. This consequently alsomeans that mechanical parts, such as casing, frame,bolts and nuts and even the labels stuck to the productmust conform to RoHS. All these components must bechecked on the presence of prohibited substances. A fewtricky issues in relation to RoHS are: Pb and Cd inplastics, Pb in Al and steel parts, Cr6+ finishing on metalcomponents like nuts and bolts, but also on electronicconnectors, flame retardants in recycled plastic, etc.

■ 4. Our products fall under IT and telecom, category 3 and may use the ‘lead in solder’ exemption. So we do not need to be concerned about RoHS?

This statement is not true. You even have a lot of RoHSwork to do. Firstly, are you certain that your productcan claim the ‘lead in solder’ exemption? Thisexemption is after all not valid for all IT andtelecommunications equipment but only for “servers,storage systems and multiple storage systems, networkinfrastructure equipment for switches, signalprocessing, transmission and network management fortelecommunications.” Hence, you must first verifywhether your product falls under this category ofproducts. The ‘lead in solder’ exemption is only valid for the useof the solder and the solder finishing used on thecomponent terminals, which become an integral partof the solder in the finished product. For the rest, theproduct must fully comply with the RoHS directive. The ‘lead in solder’ exemption is certainly not ageneral exemption for the use of lead in IT andtelecom equipment. You are only allowed to solderwith tin-lead solder. You must draw up a RoHScompatible Bill of Materials for all your products. At atechnical level you must ensure that the new RoHScompatible components are metallurgicallycompatible with the SnPb soldering process. Theavailability of suitable ‘backwards’ compatiblecomponents will become problematic in the nearfuture.

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The application of the ‘lead in solder’ exemption maybe very useful but does not make the RoHScompliance implementation easier. Moreover, thetemporary nature of this exemption, based on the lackof sufficient information on the reliability of lead-freesolder joints, should not be forgotten.

■ 5. How can I find out whether my product falls within the RoHS scope or not?

In the first place you should become familiar with thedescriptions of the product categories as described in AnnexI of the WEEE directive 2002/96/EC.Then you can start from the description of the scope in theFAQ from the European Commission. This is regularly beingrevised and can be downloaded free of charge from theEuropean Commission website:http://ec.europa.eu/environment/waste/weee_index.htmFor additional advice contact the RoHS Service.If you are an Agoria member you can also contact FilipGeerts, department of Electrical engineering and ICT atAgoria.The European Court of Justice is solely competent for alegally binding judgment. The European Commission statesthat it is the task of the producer to establish whether or nota product falls within the scope of RoHS as the producer isthe best placed to assess the characteristics of his product.RoHS enforcement is a national matter: when in doubt youmust contact the enforcement authorities of the variousmember states. In Belgium this is the “Federale

Overheidsdienst – Volksgezondheid, Veiligheid van devoedselketen en Leefmilieu” [Federal Public Service - Health,Food Chain Safety and Environment], DG Leefmilieu. Contact:Maya De Groot, +32 2 524 96 79,[email protected] RoHS directive is an Article 95 of the EU treaty, whichmeans that the scope of the RoHS directive must be the samein all member states. Practice will indicate to which extentthis will effectively be the case.

■ 6. How can I obtain a RoHS exemption?

Obtaining an exemption is a long process which is notalways successful. The application must be sent to theEuropean Commission. A detailed description of theuse of the prohibited substance must be elaborated withan explanation in accordance with Article 5(1) of theRoHS directive of the lack of a valid technical alternati-ve. Cost arguments are not taken into account. No exemptions are allowed for specific products, onlyfor specific applications of prohibited substances, pos-sibly restricted to certain product categories. Exemptions borne by multiple companies have the bestchance. For that reason it is best to submit applicationsfor exemptions via a professional federation, such asAgoria, as it disposes of a European network.

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■ 7. Our products are lead-free, then surely they comply with RoHS? Our products comply with RoHS, then surely they are lead-free?

The answer is negative to both questions or at least “notnecessarily”. A RoHS compliant product and a lead-freeproduct are two completely different things. A lead-free product does not necessarily comply withRoHS because it may contain other prohibited substances. An example of this is a lead-free product that contains ahexavalent chromium mechanical part. On the other hand,a RoHS compliant product may contain a lot of lead as aresult of the many exemptions existing for the use of lead.So do not use a lead-free label just like that for a RoHScompliant product. You might be guilty of misleadingadvertising! Moreover, it should be noted that a lead-freeand/or RoHS compatible component would notnecessarily be lead-free solderable. RoHS compatible,lead-free, lead-free solderable are three completelydifferent things. As to RoHS compliance, the ‘lead-free’characteristic is in fact irrelevant. Being compatible withthe RoHS regulations and lead-free soldering areconsequently relevant and the definitions of the two arenot the same.

■ 8. Must replacement parts conform to RoHS?

As recycling electrical and electronic devices is good forthe environment, the RoHS directive is not applicable to

second-hand equipment. Repairing and even upgrading the devices marketedbefore 1st July 2006 may also be realized with non-RoHS compatible components, insofar as this product isnot marketed as new. Products marketed as new productsfrom 1st July 2006 must be repaired with RoHScompatible components.

■ 9. How must we demonstrate RoHS compliance?

The text of the RoHS directive does not stipulate howRoHS compliance should be demonstrated. Nocertification or RoHS label is provided. Theassumption is that if a product must be RoHScompliant from 1st July 2006, this will be true for allproducts put on the EU market from 1st July 2006. Ofcourse, the aforementioned does not answer thequestion of how this will be verified and what must besubmitted for a verification. In order to give an answer that is as uniform aspossible throughout the entire EU, the EU RoHSEnforcement Authorities Information Network wasestablished. They published the first edition of the‘RoHS Enforcement Guidance Document’ in May2006. Again, this is only an informative and advisorydocument without any legally binding force. However,there is a broad consensus among the RoHSEnforcement Authorities – including the Belgian RoHSauthority – concerning the principles stipulated in thisdocument so that we can consider this document as a

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guideline.According to this document the RoHS enforcementmust be based on three principles:■ A common interpretation across EU member states

regarding these products that are considered to fallwithin the scope of the RoHS directive.

■ A presumption that products falling within the scopeof RoHS conform to its requirements.

■ Self-declaration by producers.The self-declaration must comprise a RoHS overviewdocumentation and compliance documentation. Theoverview documentation must specify the RoHScontact within the organization, give relevantcompany information, describe the RoHS complianceapproach applied in the company and ensure anoverview of the data quality systems implemented topreserve the correctness and quality of the RoHSrelevant data. Two routes are provided for RoHS compliance.Route A is a process-oriented route in which RoHScompliance is guaranteed with a ‘ComplianceAssurance System’ or CAS (see also ISO9000). RouteB is a product/component-oriented route based onmaterial declarations for the components used.However, this is insufficient. It must also be shown thatthe necessary actions, such as audits and tests, areand have been carried out to guarantee that theinformation obtained is reliable. Route B is mainlyaimed at SMEs. Large companies are expected to setup a RoHS CAS. (More details about this can befound in the ‘RoHS Enforcement Guidance Document’.)The industry is also active in this field. For setting up a

RoHS CAS, reference can be made to the IECstandard IECQ QC 080000: Electrical and ElectronicComponents and Products Hazardous SubstanceProcess Management System Requirements (HSPM).This describes the embedding of a RoHS CAS in theexisting ISO9000-2000 platform. For materialdeclarations, the IPC, the original American butinternationally operating Association ConnectingElectronics Industries, has formulated a set ofstandards (IPC-175X: Declaration ProcessManagement Standards), including electronic formsfor applying for and providing material declarationsfor components. Setting up such a CAS is not an unnecessary luxury,considering the severe penalties related to breachingthe RoHS regulations, the dynamic of RoHS matters,

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the complexity of the electronic supply chain and otherdirectives such as the EuP (Energy Using Products) andREACH (Restriction, Evaluation, Authorisation ofCHemicals). Possible additional declarations of non-RoHS substances may be necessary for thesedirectives. Having an efficient and operational CASwill certainly be a competitive advantage in the future,or even a necessity.

■ 10. How will RoHS compliance be verified?

The ‘RoHS Enforcement Guidance Document’ alsoenlightens the approach here. The RoHS enforcementauthorities do have a lot of options in setting thepriority of inspection actions. The Belgian state hasindicated that it will give priority to high volumeproducts and products with a high RoHS risk. Thelatter products include all types of soldered electronicassemblies due to the solder. It is expected that reportsof RoHS infringements by third parties (possibly acompetitor) could play an important role in theenforcement policy.A first step of the enforcement is the request for thenecessary RoHS compliance documentation for theproduct. However, it has not been excluded that someRoHS authorities will proceed directly to theapplication of XRF analyses (X-Ray Fluorescence) todetect prohibited substances. Note: the detection of lead in an electronic productusing an XRF analyser is absolutely no proof of the

non-compliance with RoHS for that product due to themany exemptions in relation to the use of Pb. Thisrelates to exemptions that can also be found in themajority of electronic products, such as lead inceramic components, lead in finishing of compliantpin connectors, lead in flip-chip connections, lead inhigh melting point solder (>85 per cent lead), lead insolderable finishes of fine pitch components, … Dueto the dimensional resolution and characteristics of theXRF measuring technique, this technique usually doesnot make it possible to distinguish betweenpermissible and prohibited uses of lead. Moreadvanced techniques are required for this such asSEM-EDX or a chemical analysis.In case the documentation submitted is not sufficientfor the authorities, additional documentation may berequested and sampling may be proceeded to. If abreach is established, the RoHS authority mayproceed to enforce penalties and/or demandremedial actions that must be carried out within anagreed period.

■ 11. What are the penalties for breaching the RoHS directive?

The enforcement of the RoHS directive is under thejurisdiction of the various EU member states. In somecountries breaching the RoHS directive is a criminal act. Fines range from € 500 (Italy), € 1500 (France) to € 50 000 (Germany) per non-compliant product,general fines range from €100 000 (Italy) to

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€15 000 000 (Ireland) and even to €22 000 000(Belgium). Prison terms from 1 to 10 years (in Belgium,Ireland, the Netherlands and Sweden) are possible. The measures indicate both the severity and variation ofthe penalties imposed when breaching the nationallyimplemented RoHS directive. In addition, the seizure ofproperty and profits and publication of the judgment arepossible additional penalties. The Belgian penalty policy is based on the act of 21stDecember 1998: this is the ‘act relating to productstandards for the promotion of sustainable production andconsumption patterns and for the protection of theenvironment and public health,’ to which the RoHS RoyalDecree of 20th October 2004 refers in article 6. This actstipulates that: “Art. 17. § 1. Is penalized with a prisonsentence from eight days to three years and a fine of(€160) to (€4 000 000) or with one of the penaltiesalone (W 2003-03-28/42, art. 11, 003; Effectivedate: 09-05-2003): 1° a party infringing the regulationsstipulated by or pursuant to articles 5, 7, 8 and 9 of thisact, when applicable to the prohibited products orsubstances, preparations or biocides that are classed ashazardous”. The fines stated must be increased by 45 surcharges –factor 4.5, which increase the fines to a minimum of € 720 and a maximum of € 22,000,000.It is clear that the RoHS directive should not be takenlightly.

■ 12. The electronic assembly of our products is carried out by a subcontractor whom we asked to manufacture in compliance with RoHS from 1st July 2006. RoHS compliance is consequently the responsibility of the subcontractor and not our responsibility as OEM?

This statement is certainly incorrect. The OriginalEquipment Manufacturer (OEM) who markets theproduct bears full responsibility for the RoHScompliance of the product, even if the name of theOEM company is only stuck on the product bycommission. This is also true for importers into the EU ofthe product, whose name is not even mentioned on theproduct. The importer is considered to be the producer on thebasis of the RoHS directive. The subcontractor has nolegal obligations except to comply with the contractualagreements between customer and supplier and toprovide correct, truthful information, which complieswith normal business practice. The OEM is responsiblefor carrying out the necessary formalities to ensure thatthe subcontractor delivers a product compliant withRoHS. The simple order “deliver RoHS compliant products” willcertainly not be sufficient here. Clear instructions on thesoldering materials to be used, the supply ofcomponents, the stock management and inspection andevaluation of the logistics and production managementmethods with the subcontractor are necessary here.

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Verify whether the subcontractor is able to produce incompliance with RoHS. Being able to distinguishbetween RoHS and non-RoHS conforming components,materials and products on the production floor and in thelogistical systems is essential but not necessarily obvious.

■ 13. We have requested RoHS declarations of conformity from our suppliers and requested them to deliver RoHS conforming components. Have we done enough?

No, this is necessary but not sufficient. As indicated inthe ‘RoHS Enforcement Guidance Document’ you mustalso be able to show that the certificates provided arereliable and that the components supplied correspondwith the certificates. It is also not sufficient to make the one-off switch to thesupply of RoHS compatible components. It should beverified whether the RoHS supply remains inconformity. When components are taken fromcomponent brokers this is certainly not guaranteed. Thecomponent coding practices of some componentmanufacturers (no separate codes for RoHS and non-RoHS compatible components or even thereintroduction of the old non-RoHS compatible codesafter the RoHS transition) make the control of the RoHScompatibility of components anything but obvious butall the more essential. In addition to the RoHS compatibility of thecomponents the RoHS compatibility of the Printed

Circuit Board must also be verified. Moreover, theelectronic assembly may not be forgotten. Verifywhether the production is realized in conformity withRoHS. Especially the logistical aspect of the productionis complex and requires the necessary attention andverification.

■ 14. How much lead can a product complying with RoHS contain? What are the maximum levels of prohibited substances?

The question of the quantity of the lead that a RoHScompliant product may contain cannot be answered ingeneral: 1 kg may be acceptable, 1 ng may be toomuch. The answer depends on where the lead islocated. The limitation refers to the presence of lead(and of other substances prohibited by RoHS), specifiedas a weight percentage of the HOMOGENOUSMATERIALS present in the product, not as a maximumquantity per product or even per component. Thedefinition of homogenous materials and the maximumconcentration of prohibited substances in thehomogenous materials is defined in the amendment2005/618/EC to the RoHS directive. The maximumconcentrations are 0.1 percentage of weight for Pb,Hg, Cr6+, PBB, PBDE and 0.01% percentage ofweight for Cd for all homogenous materials for whichno RoHS exemptions are applicable.Homogenous materials are defined as materials thatcannot be separated mechanically. In practice, the term

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‘homogenous materials’ means materials with uniformphysical characteristics, distinguishable from otherhomogenous materials with their own uniformcharacteristics. In this way the zinc chromate coating isa homogenous material distinguishable from thesubstrate (steel or aluminum) on which it is applied. The Cr6+ restriction is consequently valid for thechromate layer but not for the chromate layer plus thesubstrate.

■ 15. One of the prohibited substances is still used in the production of a component. Can that component be used in a product complying with RoHS?

Yes, as long as this prohibited substance does notexceed the maximum concentration in any of thehomogenous materials present in the end product. TheRoHS restriction relates to the product, not theproduction process. In this way the use of hexavalentchromium in chromates is still permitted as long as theend product does not exceed the limit of 0.1 per centin the homogenous materials. Note that some RoHSenforcement authorities go one step further and inaddition to the maximum concentration limits also takeinto account the aspect ‘intentionally added’ as anincriminating aspect. A production process that usesone of the prohibited substances may then result in apossible discussion concerning the aspect of intentionaladdition.

■ 16. My product complies 99 per cent with RoHS. Am I safe? What should I do?

No, you are not safe because your product does notcomply with RoHS. A product either complies with RoHSor it does not. There is no grey area or margin, nor isthere a method for defining the percentage of RoHScompliance. Such a percentage can only indicate thatyou have done your best to obtain a RoHS compliantproduct. Strictly speaking you have not succeeded andyou may not market this product. It is extremely important that there is a documentedmethod available whereby you guarantee the RoHScompliance of your products. The quality of this method

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will determine to a significant degree the consequencesof a conclusion of non-compliance of your product. ‘Duediligence’ must be apparent from this. You have taken allthe necessary measures to comply with the regulationsand to market a RoHS compliant product. It is also worthmentioning that in some countries, like Ireland, there is areporting obligation for non-RoHS compliance. If you donot report this, you are not only guilty of an infringementof the RoHS regulations by marketing a 99 per cent RoHScompliant product but also of circumventing the reportingobligation.

■ 17. What about RoHS outside the EU?

RoHS has become a worldwide issue. Variouscountries outside the EU have introduced comparableRoHS legislation or are in the process of preparingthis. This is a very dynamic event, of which the statusis changing daily. A number of EU neighbouring countries likeSwitzerland and Norway have implemented the EURoHS regulations. In the United States, where this environmental matterfalls under the jurisdiction of the individual states,California has introduced a RoHS regulation that hasbecome effective since 1st January 2007. However,the Californian RoHS is much more limited in scopethan the EU RoHS directive and, for example, doesnot stipulate any limitations regarding flameretardants. The type of products to which theregulation relates is also much more limited and

mainly relates to products with a monitor. Over thirtyAmerican states are supposed to be working oncomparable RoHS regulations. The important Chinese regulation similar to the RoHSlegislation has become effective since 1st March2007. There are a lot of similarities with the EU RoHS,but also major differences. A few features of theChina RoHS:■ The same six hazardous substances are regulated

in electronic products. However, a seventh isadded to these: “the substance defined ashazardous by the Chinese government.”

■ China RoHS is not based on self-declaration. AChina RoHS certificate from the Chinesecertification organization CCC is required tomarket products on the Chinese market from 1stMarch 2007.

■ China RoHS does not work with descriptions ofproduct categories, but with an explicit list ofproducts that fall under the regulation. This alsoincludes products that fall outside the scope of theEU RoHS, such as car radios, medical equipment,etc.

■ Being effective since 1st March 2007 thehazardous substances stated in China RoHS arenot yet prohibited. From that date there is a duty toregister. At a later stage restrictions will be imposedon certain products.

■ China RoHS does NOT provide for anyexemptions.

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■ 18. I have one of our products here. Can you do some tests and deliver us a certificate of compliance with RoHS?

No, this is not possible. If you have the necessary expertiseit is not so difficult to demonstrate that a product does notcomply with RoHS. The reverse - proving that a randomproduct does comply with RoHS on the basis of ananalysis of the materials - is impossible in practice. Thiswould entail the inspection of all homogenous materials forthe presence of the six prohibited components and this withan accuracy level that would make it possible to test at alimit of 0.1 or 0.01 per cent. As even a simple electronicproduct may contain many thousands of homogenousmaterials, the time required to carry out this analysis and

the cost would be phenomenal. RoHS compliance must beshown on the basis of the RoHS compatibility of thecomponents. Material analyses are useful to carry outinspections in a controlled way on materials at risk, suchas the soldering of an electronic assembly, the solderablefinish on a component terminal, the coating on amechanical component, the lead content in plastic, etc.This supports significantly the RoHS compatibilitydeclarations of the components used.

■ 19. Which tests must I carry out to find out whether my (lead-free) product complies with RoHS?

The RoHS compliance of a product is guaranteed bya correct RoHS compliant design of the Bill ofMaterials, correct control of the supply chain and acorrect, unequivocal control of the production wherecorrect lead-free materials must be used. The mostrelevant test is consequently the audit of the productrealization chain for its capacity to deliver RoHScompliant products. On request from the governmentto demonstrate the RoHS compliance of the product, awell-documented and audited product realizationchain would be much more convincing than a fewfragmentary material analyses of an individualproduct. Material tests on a product cannot ever guarantee thatthe product complies 100% with RoHS. In case ofdoubt of the compliance with RoHS of a product, itmay be useful to carry out a number of tests. Preferably

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these are non-destructive and low cost. This certainlyexcludes quantitative chemical analysis techniques, asis required for establishing for example hexavalentchromium concentration. Methods like the ‘Leadcheck’indicator, X-Ray Fluorescence (XRF) and ScanningElectron Microscopy (SEM) may be used to detectlead content in soldering joints, metals and plastics.

Contact the RoHS Service (www.rohsservice.be) formore information about the options.

■ 20. I, an OEM, still have 1000 units of non-RoHS compliant equipment in my warehouse. Can I still sell them? (after 1st July 2006)?

As the products were not marketed before 1st July 2006by placing them in the distribution chain, you cannot sellthese products in the EU. You may, however, use themin the EU as replacement parts. You can sell theproducts outside the EU, taking into account the nationallegislation of the countries to which you export. A lot ofcountries have similar RoHS regulations or are in theprocess of developing them. In a rare case it is possible to make the products complywith RoHS and still market them on the EU market.

■ 21. My distributor still has 1000 units of non-RoHS compliant equipment in his warehouse. Can he still sell them? (after 1st July 2006)?

By transferring your products to your distributor youhave placed the products on the market and madethese available for purchase by the end customers. Ifthis transfer took place before 1st July 2006 then yourdistributor may still sell these products withoutlimitation. However, some countries, like Italy have regulationsthat deviate from the standard in the EU. For thatreason it is important to find out about the nationalpractices in the various member states. In Italy sale

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was only possible until 31.10.2006, on condition thatthe goods were registered before 1st July 2006.

■ 22. Must products I export outside the EU also comply with RoHS?

No, the EU RoHS regulations only relate to products puton the EU market. However, you must also take intoaccount that a lot of countries are working on their ownRoHS legislation or have already introduced suchlegislation. Moreover, these regulations may deviatefrom the EU RoHS regulations. In this way an EU RoHScompliant product cannot be put on the Chinese marketfrom 1.3.2007; nor can other electrical/electronicproducts on the China RoHS list as these must first becertified.

■ 23. My customer is asking me for a declaration that the part I deliver conforms to RoHS. What is my position? What should I do?

You have no direct legal responsibility in relation tothe RoHS directive. However, you must ensure thatyour written declaration is truthful so that you are notguilty of fraud. When drawing up a declaration youmust certainly verify that your components effectivelyconform to the RoHS directive. This will in mostcases mean that you must request declarationsyourself from your suppliers with regard to the RoHS

conformity of the materials, components, etc.supplied to you. Moreover, taking the necessaryactions to show the reliability of the informationprovided is recommended. This is possible byrequesting detailed technical information and bycarrying out targeted analyses on samples. As RoHSconformity should be guaranteed on thehomogenous material level, demonstrating RoHSconformity is a complex matter that entails a certainrisk of error. Consequently, it is advisable toimplement a proper formulation of the declarationthat limits your liability for this RoHS conformity. TheIPC 175X standards can help in the formulation ofRoHS declarations.The Orgalime guide ‘A practical Guide tounderstanding the specific obligations of RoHS’ alsogives a number of recommendations for RoHSconformity declarations.

■ 24. Is a RoHS label obligatory? Should RoHS compliance be certified?

The RoHS directive stipulates neither the certification nor theapplication of a RoHS label. There are a few labels in use.However, you must use these carefully. The use of a label that indicates RoHS compliance may beconsidered as misleading advertising. You thereby give theimpression that you want to distinguish your products fromother products in relation to RoHS compliance, while thisrelates to a legal obligation to which all products mustcomply.

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Using a lead-free symbol must also be done with care. ARoHS compliant product is after all in many cases not lead-free at all. The use of a lead-free label on a RoHScompliant product may constitute misleading advertising.Hence, the use of such labels is not recommended onproducts for end customers. For B2B-products andcomponents labels may be useful to distinguish theseproducts from non-RoHS conforming components andproducts present in the supply chain. The use of industrystandards like JESD97 and IPC-1066 for labeling isrecommended here.

■ 25. What should I do to make a non-RoHS compliant product compliant with RoHS?

If the product has already been manufactured, theoptions are limited because a lot ofelectrical/electronic components must be replaced byRoHS compatible versions. The traditional SnPb soldermust also be removed, which is usually not feasible inpractice. The transformation of existing products toRoHS compliance is only a realistic option in specificcases. When it relates to an existing design that must beadapted to the RoHS directive, then the followingshould be realized (here we only consider the generalcase, not the ‘lead in solder’ exemption for some IT andtelecom products):

1. The Bill of Materials for the product must be checkedcompletely on RoHS compatibility of the components.

2. Non-RoHS conforming components must be replacedby RoHS conforming versions. Ensure reliable RoHSconformity declarations.

3. Register the changes between the RoHS versions ofthe components and the non-RoHS versions. This mayresult in the mandatory re-qualification of thecomponent and even a re-qualification of theproduct. Sn-whiskering of lead-free, Sn-basedsolderable finishes on components are in this regardone of the most eye-catching aspects of the RoHSconversion, but not the only aspect!

4. Printed Circuit Boards must also be compatible withRoHS. Usually this means the replacement of theSnPb solderable finish of the PCB by a lead-freeversion. There are a number of alternatives, eachwith their advantages and disadvantages. Ensure aRoHS declaration of conformity.

5. Because the Bill of Materials has been made RoHSconforming, this does not mean that it is lead-freesolderable. Can all components and the boardwithstand the higher soldering temperature? Verify and replace any unsuitable components andthe board with lead-free solderable versions.

6. Instruct your assembly unit (internal or external) withregard to the need for lead-free soldering on theproduct. Establish permissible alloys and solderingmaterial requirements. Specify any additional requirements for maximumsoldering temperatures if temperature sensitivecomponents are present.

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7. Verify that your assembly unit is able to work RoHSconforming and to solder lead-free, both on alogistical and process-technical level.

8. Lead-free soldering joints have other characteristicsthan SnPb solder joints. Generally speaking thisresults in a need for the re-qualification of products.

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■ The technical reality of the RoHS directive

The technical side of the RoHS directive is as important as the legal interpretation. The technical aspects of the directivehave a direct impact on the quality and reliability of RoHS compliant products and even on products that fall outside thescope of RoHS as a result of changes made at a component level.

Due to the large impact of the directive on the soldering process, we focus on lead-free and non-lead-free soldering in thesecond part of these FAQs. A few questions that will be dealt with:

■ What are the alternatives for the classical SnPb solder?■ What must I do to switch to lead-free soldering?■ Do lead-free and lead-free soldered components cost more? ■ 13 FAQ on the technical reality within the RoHS directive

■ 13 FAQ on the technical reality within the RoHS directive

There are a lot of books and other publications about lead-free and SnPb solder. It is still the subject of a lot of research.Hence, the answers to the questions are more intended as guidance. An in-depth study of the technical issues lies outsidethe scope of this brochure.

1. What are the alternatives to traditional SnPb solder?2. What must be done to switch to lead-free solder?3. I (OEM) have asked the supplier of my electronic assemblies to use lead-free solder from 1st July 2006. Should I do

anything else?4. My products fall outside the scope of RoHS. I will continue to produce as previously with SnPb and need not take any

further action.5. Can all components be soldered lead-free? Which can, which cannot? 6. Do lead-free and lead-free solderable components cost more? 7. Does lead-free soldering cost more?8. My components are RoHS compatible. They can consequently be soldered lead-free?

■ technical realization: 13 FAQ

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9. Should I change anything to the Printed Circuit Board (PCB) of a product to be soldered lead-free?10. Is a lead-free product as reliable as a SnPb soldered product?11. Which tests must I do to find out whether my lead-free product meets the quality standards? 12. Which tests must I do to find out whether my lead-free product is reliable? 13. Which design measures should I take to design a good lead-free soldered product?

■ technical realization: 13 FAQ

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■ 1. What are the alternatives to traditional SnPb solder?

There are a lot of possible alternative lead-free solderalloys. All these alloys are based on Sn as the activeelement in the solder, as is the case for the SnPbsolder. Sn is the element that forms the inter-metallicchemical bond with the metal of the Printed CircuitBoard (PCB), of the component terminal or the wire tobe soldered. In most cases the material to be solderedis copper, nickel or the iron-nickel alloy Alloy 42.Unfortunately, there is no practical ‘drop-in’ alloy forthe generally applied eutectic Sn63Pb37-solder,which has a melting point of 183 °C. The solder alloymust comply with a lot of demands, specifically withregard to the melting point, the solderingcharacteristics, processability in soldering materialslike solder paste and solder wire, metallurgicalcompatibility, strength, ductility, fatigue resistance,corrosion resistance, toxicity, cost, …Within the electronic industry a consensus has grownover recent years concerning SnAgCu (SAC) alloy asa generic applicable solder alloy.The concentration of silver (Ag) is in the range of 0 to5 per cent, of copper (Cu) in the range of 0 to 0.9per cent. The eutectic SnAg3Cu0.5 – also calledSAC305 – has been put forward as the standard bythe IPC - Association Connecting ElectronicsIndustries. For some time this was the SAC alloy with3.8 or 4 per cent Ag. However, the high Ag levelproves to be more costly, but does not contributemuch to the characteristics of the solder. Due to the

suboptimal combination of characteristics of theSAC305-solder in comparison with the traditionalSn63Pb37-solder various alloys are effectivelyapplied within the group of the SAC alloys.In this way, due to the cost, ‘improved’ SnCu-alloysare used, primarily in wave soldering. No or onlyminimal quantities of the expensive silver are addedto the SnCu alloy. SAC alloys with a lower silvercontent are also used because of their bettermechanical characteristics. The disadvantage of thesealloys is their higher melting point or their non-eutecticsolidification behaviour that is expressed in asolidification trajectory of approx. 10 °C. Besides the group of SAC alloys there are also a lotof other alloys with interesting characteristics. Theseare actually used for specific applications. SnAgBi isan interesting alloy but requires that no leadcontamination may occur. Lead contamination cannegatively influence the mechanical characteristics ofthe SnAgBi solder. Exotic and expensive alloys wereused especially in Japan to lower the solderingtemperature, and thereby to be able to lead-freesolder components adapted to the traditionaltemperature requirements of the SnPb solder. SnZnand SnZnBi alloys are also used as cheapalternatives. However, these zinc-based alloys have afew major disadvantages, as a result of which theyare not eligible as generic solder alloys. This all results in a changed situation in comparison tothe SnPb age. From now on it is no longer obviouswhich solder alloy has to be used and the solder alloymust be specified in the product design.

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The eutectic SAC305-alloy has a melting point of 217°C. This is 34°C higher than the eutectic SnPb. As aresult, the solder processing temperature must beincreased by 20 to 30 °C. This requires anadjustment of the surface mount and othercomponents, as well as the PCBs that are solderedusing the reflow-soldering process. Reflow solderingmeans soldering using soldering paste in a hot airoven. The reflow soldering process is the workhorse ofthe electronic assembly industry. The increased reflowsoldering temperature is the reason for the RoHSdirective having such a great impact on the electronicindustry. Millions of component types must beadapted to the increased soldering temperatures, aswell as all the products that use these components.This is primarily a huge logistical task in addition to atechnical challenge.

■ 2. What must be done to switch to lead-free solder?

First and foremost you must specify which lead-freesolder alloy you want to solder with. In most cases thisrelates to a solder alloy of the SnAgCu-alloy group. Ingeneral, the switch to lead-free SnAgCu-solderingrequires an adjustment of the Bill of Materials of theproduct. The components in the Bill of Materials mustbe replaced by versions that can withstand theincreased soldering temperature. In cases where no lead-free solder compatible SMD(Surface Mount Device) component versions are

available, a switch might be necessary to a through-hole version that can be wave soldered. This requiresan adaptation of the PCB design. The alternative tomanually solder the SMD component, may, for reasonsof costs and primarily quality, only be considered as atemporary solution for small volumes.Products that must comply with high standards ofquality and reliability require further analysis andadaptation. The mechanical characteristics of the SACsolder differ from those of the SnPb solder. This mayresult in component-PCB combinations that are nolonger acceptable for soldering with SAC due to theunfavourable thermo-mechanical load of the solderjoint. Solder joints that are subjected to shock must beadditionally secured because SAC is much less shockresistant than SnPb.The PCB is also negatively influenced by the increasedsoldering temperatures. Especially thicker (1.6 mmand more) and multi-layer cards (six or more) requirethe use of thermally enhanced laminate materials. In addition to the thermal requirements there are alsometallurgical aspects on which components and PCBmust be screened. In order to keep componentterminals and PCB soldering areas solderable, a thinsolderable layer is applied to the copper or Alloy 42to be soldered. There are many options for this. Oneof the most common until now was SnPb solder with alead content between 3 and 10 per cent. Nothingsolders as well as solder itself. In the majority of caseseutectic SnPb solder was used as the finish on thePCB. Apart from the exemption for some IT productsand specific applications (fine-pitch components,

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compliant pin connectors) the RoHS directive inpractice no longer allows the use of these SnPb-basedfinishes. Even if it is allowed on the basis of the RoHSdirective to use SnPb as a finish, it is greatlyrecommended to avoid the combination of lead-freesolder and a SnPb finish. In a number of cases thismay result in weaker solder joints. The combination ofSnPb soldering balls of the Ball Grid Array BGA-typecomponents and lead-free solder is generallyunacceptable and should only be considered in veryexceptional cases. The lead-free solder finishes also result in a number ofproblems. Pure Sn is sensitive to Sn-whisker formation,that may cause short circuits. NiAu may result in goldembrittlement, ‘black pad’ phenomena, “skip-plating’and phosphor-related interface weakening. Thephenomenon of the creation of a porous layer on theinterface between the SAC solder and the solderedCu-substrate was also observed in some cases. Tofurther elaborate on this would take us beyond thescope of this document. In any case, it is important toevaluate the solder finishes critically for high reliabilityproducts. As the switch to lead-free solder means a significantchange in the materials and the components used, thesolder joint characteristics and the assemblyconditions, the switch to lead-free soldering generallyentails the need to re-qualify and thoroughly test theelectronic assembly. In addition to the aspects of product design andqualification, the switch must be planned carefully.The entire supply chain must be aligned in order to

ensure that products are switched to lead-freesoldering at the right time with the correct Bill ofMaterials.

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■ 3. I (OEM) have asked the supplier of my electronic assemblies to use lead-free solder from 1st July 2006. Should I do anything else?

As the reply to the previous question shows, there is stilla lot of work to be done. Only in a few exceptionalcases – e.g. simple products that only use THcomponents with the correct solder finish – can beswitched to lead-free soldering without any adaptationsof the design or Bill of Materials. The switch to lead-free soldering is not only a concern for the assemblydepartment or contractor but also to a great extent atough job for the design department and thepurchasing and planning departments. For details onthe switch to lead-free soldering reference is made tothe answer to the question: “What must be done toswitch to lead-free soldering?”.

■ 4. My products fall outside the scope of RoHS. I will continue to produce as previously with SnPb and need not take any further action?

This statement is incorrect. The RoHS directive also hasan impact on electronic products that fall outside thescope of RoHS. Component manufacturers areswitching their production en masse to RoHSconforming components. This usually means thereplacement of a lead-containing soldering finish witha lead-free finish, which in many cases means the use

of pure Sn, in the Far East also of SnBi. In addition, theplastics of the packaging are adapted to the increasedsoldering temperatures. As it is not economicallyjustifiable to produce multiple types of componentswhen the market becomes too small, the availability ofthe old component types used in products not subject toRoHS shall be threatened in a relatively short period oftime. The replacement of the SnPb solder finish mainlyconstitutes a problem for non-RoHS products. The risk ofSn-whisker formation arises and that hazards thereliability. The incompatibility of SnBi with SnPb,through the creation of SnPbBi phase with a meltingpoint below 100 °C also leads to reliability risks. Thechange of the packaging materials used in the newRoHS and lead-free solder compatible componentsmay require a re-qualification for some applications.In addition to the availability of SnPb finishedcomponents the availability of SnPb-based assemblycapacity at an acceptable cost will also be a problemin the long term. As lead-free soldering with SnAgCu is becoming thenew standard, a lot of non-RoHS products will beforced on economical grounds to switch to lead-freesoldering.

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■ 5. Can all components be soldered lead-free? Which can, which cannot?

No, not all components can be soldered lead-free. Atleast not in an economically justified, high quality andreliable way. The problems relate to the temperaturecompatibility with the increased soldering temperatureor the metallurgy used on the component terminals. The following component types have problems withtemperature compatibility: ■ All ‘old’ types of non-hermetic (plastic) packed

active components. These comply with the J-STD-20standard and are qualified for a maximum (reflow)soldering temperature of 235 °C for the smallertypes, 220 °C for the larger types and the Ball GridArray (BGA) components. This is inadequate forSAC lead-free soldering.

■ For the passive components there is littlestandardization in relation to the solderingtemperature conditions. Various component types may lead to problems:■ Polymer film condensators■ Aluminum condensators (ELCO)■ Tantalum condensators■ Plastic casings for connectors■ LEDs (discolouration)■ Crystal oscillators■ …

Passive components must consequently also bescreened thoroughly for their temperature compatibility.Conforming to RoHS and/or being lead-free is

absolutely no guarantee of being lead-free solderable.Components that conform to the lead-free solderqualification requirements of J-STD-20C or subsequentversions can be lead-free soldered with respect to thethermal requirements. At a metallurgical level, the following must be takeninto account:■ Ball Grid Array components have solder balls as

terminals spread over the bottom of the components.These solder balls must be made of the samematerial as the solder used. Limited concentrationdifferences of the alloy elements are acceptable.This means the use of SnPb solder balls for SnPbsoldering, SAC balls for SAC soldering. Deviatingfrom this may in general lead to severe quality andreliability problems.

■ Generally speaking, the use of SnPb solderingfinishes must be avoided with lead-free soldering.With the elements tin and silver, lead can form theSn62Pb36Ag2 phase, with a melting point of 179°C, which is significantly lower than the meltingpoint of 217 °C of the SAC alloy. The presence ofPb in a SAC alloy entails the risk of local weakeningof the solder joint.

■ A lead-free solderable finish already used for a longtime is a nickel (Ni) layer on which a thin layer ofgold (Au) is deposited. Already during the SnPb agea number of problems with this finish were known.If the gold is too thick, this can result in the formationof extremely brittle SnAu inter-metallic regions in thesolder, which results in embrittlement of the solderjoint. This is the reason, for example, that no Au-

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finish is permitted in military products. Due to the riskof Au embrittlement, Immersion Au on Electroless Ni(ENIG) is primarily used for solder applications. Thistechnology then again has the disadvantage ofrequiring high concentrations of phosphor (P) in theNi, which may give rise to a weak interfacebetween the Ni and the solder. Due to the higherconcentration of Sn and the higher strength of theSAC alloy these problems occur more frequentlywhen soldering with SAC. Prudence is consequentlyadvised in the use of NiAu in high reliabilityproducts.

■ 6. Do lead-free and lead-free solderable components cost more?

The intrinsic cost of lead-free, lead-free soldering andRoHS conforming components is higher than that of theoriginal components for the following reasons: ■ The development costs for new component

versions.■ The qualification costs of the new component

versions.■ The higher material costs of the solderable finish.

Almost all lead-free solder finishes are moreexpensive than the original SnPb finish. The addedcost is limited for the switch to pure Sn or SnBi. Theswitch to NiPdAu means a significantly highermaterial cost.

■ The cost of the production switchover: engineering,investments and implementation.

■ The higher material costs due to the use of higherquality plastics for the packaging. As thecomponent purchasers are not readily prepared toaccept an added cost and the component market isvery competitive, this added cost is often notcalculated in the price of components. Finally,someone will have to bear this additional cost. It isdoubtful whether the component suppliers with theirsmall margins are willing to accept this fully.

■ 7. Does lead-free soldering cost more?

Of course. The lead-free SAC solder alloy costs no lessthan a factor 2 to 3 more than the SnPb solder. This isnot only due to using the expensive silver but alsobecause of the tin content being 50 per cent higher inthe solder alloy, which replaces the much cheaper leadto a great extent. For soldering bars this gives a one-to-one increase in cost. The cost of filling a wavesoldering machine and the material costs of thisprocess has consequently greatly increased. For thisreason there is significant interest in the somewhatcheaper alloys of the SnCu type especially for theseprocesses. For other processes, soldering materials likesolder wire and solder pastes are used. For thesesoldering materials the alloy is only one of the costelements. The impact on the solder material cost of thealloy is lower as a result. The added cost due to the solder alloy, for example fora solder paste, amounts to about 10 to 20 per cent. In addition to the higher material costs there is also the

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increased energy consumption resulting from the highersoldering temperatures. This is significant in reflowsoldering. An increase in the soldering processingtemperature by 20 to 30 °C means an increase inenergy consumption of about 20 to 40 per cent. Lead-free soldering leads to a reduction of theprocessing window at a higher temperature. This has anegative effect on the production yield, with morefaulty products and higher repair costs as a result. These intrinsic higher costs must be borne by someone.Electronic assembly plants work with very smallmargins. The additional cost cannot be borne solely bythese plants. Therefore, an increase of the assemblyprice is necessary.

■ 8. My components are RoHS compatible. They can consequently be soldered lead-free?

This statement is incorrect. RoHS compatible – notcontaining the prohibited substances – and lead-freesolderable are two completely different matters. Theremoval of the prohibited substances from components tomake them usable for RoHS compliant products does notmake it possible to solder these components lead-free.The higher soldering temperature requires drasticmeasures apart from making the component compatiblewith RoHS to give the component the increased thermalload resistance, required for lead-free soldering. RoHScompatibility and lead-free soldering ability are twocharacteristics of components to be evaluatedseparately.

■ 9. Should I change anything to the Printed Circuit Board (PCB) of a product to be soldered lead-free?

This aspect must certainly be evaluated. The layout ofthe PCB may need to be changed if no lead-freecompatible alternative with the same solder padconfiguration for a specific component is available.Except for simple electronic assemblies the use ofthermally improved laminates is also recommendedbecause of the higher thermal load when soldering.This higher thermal load may lead, for example withthe standard FR4 PCB laminates, to via-cracking,

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delamination, the creation of Conductive AnodicFilaments (CAF), warpage and discolouration. Thereare various alternatives with different levels ofperformance and, obviously, cost. Importantcharacteristics of the laminates relevant in thisframework include: the decomposition temperature, thetime to delaminate, the thermal expansion coefficientperpendicular to the board surface, the ‘curing’mechanism and the glass transition temperature.Finally, the solderable finish must also be lead-free. Thewidely used eutectic SnPb finish, applied using the HotAir Solder Leveling (HASL) process, must be replacedby a lead-free alternative. There are various options,each with advantages and disadvantages: lead-freeSnCu HASL, immersion Sn, immersion Ag, immersionAu on electroless Ni (ENIG) and organic passivation(OSP) are the most important. All these solutions solderless well than SnPb HASL, even though the SnPb solderability is almost achieved by some types. For more information about PCB alternatives, contactthe RoHS Service (www.rohsservice.be).

■ 10. Is a lead-free product as reliable as a SnPb soldered product?

The reliability of a lead-free product primarily dependson the working conditions to which the product issubjected and the build-up of the product.As the mechanical and fatigue characteristics of thelead-free solder differ from those of SnPb, the reliabilityof a lead-free soldered product will, by definition, be

different from that of a SnPb soldered product. It couldbe better, but also worse, depending on the factorspreviously mentioned. In the further discussion we have limited the scope toSAC (SnAgCu) soldered products. In general, thehigher melting point of the SAC alloy, with the resultingincreased soldering temperature, has a negativeimpact on the reliability of the lead-free solderedproduct. The higher thermal load to the componentsand PCB during the production process accelerates thedegradation mechanisms and increases the likelihoodof damage to these components.A correct selection – and if necessary correctqualification – of components and PCB minimizes thenegative impact of higher thermal load on the reliabilityof the lead-free soldered product.With regard to the characteristics and reliability of thesolder joint, the story is a little more complex. TheSnAgCu is a stiffer, stronger and less plasticallydeformable alloy than SnPb. This entails that the samelevel of deformation of the solder joint – e.g. imposedby a difference in thermal expansion between thecomponent and the PCB – causes a much highermechanical stress level in a SAC solder than in a SnPbsolder. Moreover, the higher melting point of the SACalloy results in an additional stress component if thereis a difference in thermal expansion coefficientbetween the component and the PCB.This increased mechanical stress must not only beborne by the solder joint, but also by the elementsconnected by the soldering: the (brittle) inter-metalliclayer, the solder pad, the component terminal, the

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interface of the pad or terminal with the board orcomponent body, … All these elements are now,depending on the construction of the product, exposedto significant higher mechanical loads than in the SnPbage. Where the solder joints previously were theweakest spot and failed first or deformed strongly (as aresult of which the stress on the surrounding elementsremained limited), this is no longer the case.Consequently, an increasing amount of failures of theinter-metallic layer or in the elements adjoining thesolder joint is observed. Actually, the interfacereliability of lead-free solder balls in the production oflead-free Ball Grid Array (BGA) packaging is a seriousproblem.The SAC solder joint is more resistant to fatigue thanSnPb when the mechanical load is low, which isusually the case. With high mechanical loads thefatigue resistance is not as good as SnPb.SAC soldering is also significantly less resistant toshock than SnPb, e.g. if the product falls. The same istrue for strong vibrations. All this may be linked to thelower ductility of SAC solder compared to SnPb. Byreducing the Ag content, an attempt is made in thoseapplications where the high rigidity and strength of theSAC alloy causes serious problems (e.g. for BGAs) toobtain an alloy with more optimal characteristics. A lot of the characteristics of the SAC alloy are still notor insufficiently known. At this moment we do not knowthe acceleration factors required to extrapolate theresults of the solder fatigue tests to the workingconditions of a product. Consequently, we cannotmake life time predictions for a lead-free product. This

forms the basis for the ‘lead in solder’ exemption forsome IT and telecom equipment. Establishing theacceleration factors is consequently also the subject ofscientific research. All this makes that for products thatare subjected to high reliability requirements the aspectof reliability must be approached with the necessarycare and prudence. As a general rule it may be statedthat configurations that lead to large thermal expansiondifferences – e.g. a large ceramic passive SMDcomponent soldered on an FR4-substrate – must beavoided.

■ 11. Which tests must I do to find out whether my lead-free product meets the quality standards?

When answering this question we will limit ourselves tothe quality of the Printed Board Assembly (PBA) producton leaving production. The quality aspect ‘intrinsicreliability in the long term’ is the subject of a separatequestion. The following evaluations are relevant to thequality control of a lead-free soldered product:■ The PBA must comply with the industry standards for

PBA acceptance. The most commonly used standardfor this is IPC-A-610D (or later versions) Acceptabilityof Electronic Assemblies. An IPC-A-610D-auditshould preferably be carried out by an IPC-certifiedauditor.

■ The lead-free product should be subjected to therequired production fault detection tests andfunctional tests as implemented in the assembly unit

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and if applicable supplemented with additionalproduct tests, if the test coverage is insufficient.

■ A transmission X-ray analysis gives a good view ofthe quality of the solder joints but also of the entirequality of the product. It is an important supplementwith (and partly a component of) the IPC-A-610D-audit. It may replace this and is consequentlyrecommended.

However, testing alone is never sufficient to guaranteethe quality, as 100 per cent testing coverage is notpossible in practice. A good Design-for-Manufacturingpractice, good quality components and PCB, amongother things with respect to the solderability (which is notobvious!), and good assembly instructions, especiallyregarding the selection of soldering materials, arefundamentally important to obtain a quality product.

■ 12. Which tests must I do to find out whether my lead-free product is reliable?

This is an obvious but extremely difficult question toanswer. There are no generic tests that can answerthis question easily. In addition, even the mostextensive battery of reliability tests cannot offersufficient guarantees without the necessary attentionbeing paid to aspects of ‘Design-for-Reliability’. For aproduct subject to high reliability requirements acombination of a correct ‘Design-for-Reliability’practice and a well thought-out testing strategy arerecommended. In order to ensure that reliability testsprovide relevant and usable results, the testingconditions must be very similar to the conditions towhich the product will be subjected. As an alternativeand if the necessary technical-scientific support ispresent, accelerated testing conditions may be linkedto the working conditions of the product viaacceleration factors. The first type of tests are suitablefor testing a product on the short, high loadconditions that the product must be able to withstand.Hence, it may not be subjected to this for long.Examples include drop tests, thermal shock, transporttests, etc. However, the greatest difficulty is toevaluate the resistance to long, relative low loadconditions that the product will have to withstand forthe entire predefined life span (a few to tens of years). As these tests are intended to evaluate the entire lifespan of the product, a high test acceleration factor isnecessary. A sufficiently accurate definition of this

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acceleration factor is an especially difficult andlaborious task. To this day we still do not know theacceleration factors for testing SnAgCu-lead-freesolder joints for fatigue failure with sufficientprecision. The acceleration factor depends on thefailure mechanism, the testing conditions and theworking conditions. In an average electronic productan uncountable number of possible failuremechanisms is present, each with its ownacceleration factor and its own set of optimal testingconditions. Therefore, it is impossible to cover allpossible failure mechanisms with a limited set ofaccelerated tests. In practice, only a limited numberof mechanisms are critical for the life span of theproduct if the correct ‘Design-for-Reliability’ practiceis applied.The real art is then to identify precisely thosemechanisms that are critical and to carry out targetedtests on these to identify the impact on the life span. Considering the complexity of the reliabilityevaluation a ‘Divide and Conquer’ strategy isrecommended. Each component of the assembly(components, PCB, mechanics) - including things likethe soldering materials used - must each in itselfconform to carefully selected specifications and betested correctly for this before being used in theproduct. Specifying component requirements is anessential aspect of a good ’Design-for-Reliability’practice. Product tests can then target the evaluationof the assembly. Specifically in relation to the lead-free product, it must be taken into account thatgenerally the failure mechanisms present in a SnPb

soldered product are still there but that the criticalvalues are different and consequently also the mutualratios. In this way, a number of failure mechanismswill occur at a reduced rate in lead-free solder. Forexample at low mechanical loads SAC has a higherfatigue resistance than SnPb. On the other hand,other failure mechanisms are accentuated. The highersoldering temperature, for example, more easilyresults in Conductive Anodic Filament (CAF)development in the FR4-material of PCBs. In addition,new failure mechanisms are added, e.g. the Sn-whiskering issue. This determines the type of life spantests that need to be selected. A good qualification procedure consists of defining arelevant set of operational environmental tests thatevaluate the range of high load conditions for theproduct, supplemented by a set of life span testsbased on failure mechanisms. The latter must often becarried out on specifically designed testing structures,not on the end product. This must be supported by a good ‘Design for-Reliability’-practice. It is obvious that this approachrequires thorough knowledge of the physics of theelectronic product.

■ 13. Which design measures should I take to design a good lead-free soldered product?

A good design of a lead-free soldered product requiresa basic knowledge of the lead-free soldering processes

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that will be used for the assembly of the product.Metallurgical knowledge of the solder to be used andthe surfaces to be soldered is also a requirement forarriving at effective ‘Design-for-Reliability’ rules thatguarantee the reliability of the product. This knowledgecombined with the product requirements maysubsequently be translated into concrete design rules. The two clearly distinguishable matters of ‘Design-for-RoHS’ and ‘Design-for-Lead-free soldering’ are primarilya Bill of Materials design activity. Soldering paddimensions and mutual distances on the PCB used withSnPb soldering can still be used. Primarily, it must beestablished which components may be used and whichnot. The selection criteria are based on the RoHScompatibility of the component, the temperatureresistance in relation to the solder joints, the terminalmetallurgy of the component and the thermo-mechanical load on the soldering joints. The selectioncriteria depend on the product specifications, theproduct application, the intended life span of theproduct and the priority setting by the producer. Inaddition, the specifications of the PCB must be defined.More and more detailed instructions are also requiredfor the assembly compared to the SnPb age. Becausethere are more variables – for example, now there is achoice of soldering alloys – whereas the processingwindow has become significantly smaller and this at ahigher processing temperature, i.e. under more criticalconditions.

A detailed discussion of the design rules and PCB/PBAspecifications falls outside the scope of these FAQ. For

more information please contact the RoHS Service:www.rohsservice.be.

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The texts of these legal articles can be consulted atwww.rohsservice.be

■ Legislation

■ RoHS directive (Restriction of Hazardous Substances)2002/95/EC concerning the restriction of the use ofcertain hazardous substances in electrical and electronicequipment. Amendments:

■ Maximum concentrations of hazardous substancesCommission Decision 2005/618/EC establishingthe maximum concentration values for certainhazardous substances in EEE.

■ Corrections to the RoHS directive CommissionDecision 2005/717/EC amending for the purposeof adapting to the technical progress the Annex toDirective 2002/95/EC.

■ Publication of exceptions 11 to 15. CommissionDecision 2005/747/EC amending for the purposeof adapting to the technical progress the Annex toDirective 2002/95/EC.

■ Publication of exceptions 16 to 20. CommissionDecision 2006/310/EC amending for the purposeof adapting to the technical progress the Annex toDirective 2002/95/EC as regards exemptions forapplications of lead.

■ Publication of exceptions 21 to 27 CommissionDecision 2006/691/EC amending for the purposeof adapting to technical progress the Annex toDirective 2002/95/EC as regards exemptions forapplications of lead and cadmium.

■ Publication of exception 28 Commission Decision2006/692/EC amending for the purpose ofadapting to technical progress the Annex to Directive2002/95/EC as regards exemptions forapplications of hexavalent chromium.

■ Publication of exception 29 Commission Decision2006/690/EC amending for the purpose ofadapting to technical progress the Annex to Directive2002/95/EC as regards exemptions forapplications of lead in crystal glass.

■ The Belgian penalty policy in relation to RoHS isbased on the act of 21st December 1998, the ‘actrelating to the product standards for the promotion ofsustainable production and consumption patterns andfor the protection of the environment and publichealth’, to which the Royal Decree of 20th October2004 refers in article 6.

■ WEEE directive (Waste Electrical and ElectronicEquipment) 2002/96/EC contains the definition ofproduction categories.

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■ Non-EU RoHS legislation

■ California: ■ California’s restriction on the Use of Certain Hazardous Substances in Some Electronic Devices

■ Electronic Waste from California’s Department of ToxicSubstances Control.

■ China: ■ Administrative Measures on the Control of Pollution

Caused by Electronic Information Products.■ Management Methods for controlling Pollution by

Electronic Information Products – Ministry ofInformation Industry Order #39.

■ Electronic Information Products Classification andExplanations.

These documents are unofficial translations from Chineseand are consequently only for information purposes.

■ Implementation guides (not legally binding)

■ Frequently Asked Questions with regard to RoHS andWEEE (source: European Commission).

■ Orgalime guide ‘A practical Guide to understanding thespecific obligations of RoHS’: aanbevelingen voorRoHSconformiteitsverklaringen (source: Orgalime –European Engineering Industries Association).

■ RoHS Enforcement Guidance Document (source: EURoHS Enforcement Authorities Informal Network).

■ Standardization organizations

■ IPC: originally American, internationally operatingAssociation Connecting Electronics Industries(www.icp.org).

■ JEDEC Solid State Technology Association: the originalJoint Electron Device Engineering Council is thestandardization body for the semiconductor producingindustry (www.jedec.org).

■ IEC: International Electrotechnical Commission(www.iec.ch).

■ Relevant standards regarding RoHS/ lead-free soldering

■ IECQ QC 080000: Electrical and ElectronicComponents and Products Hazardous SubstanceProcess Management System Requirements (HSPM).This describes embedding a RoHS CAS in the existingISO 9000-2000 platform.

■ IPC-610D: Acceptability of Printed Board Assemblies.■ IPC 1066: Marking, Symbols and Labels for

Identification of Lead-Free and Other ReportableMaterials in Lead-Free Assemblies, Components andDevices.

■ IPC-175X: Declaration Process Managementstandards.

■ IPC-9503: Moisture Sensitivity Classification for Non-IC Components.

■ IPC-9701: Performance Test Methods and QualificationRequirements for Surface Mount Solder Attachments.

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■ references

■ JIG-101: Material Composition Declaration forElectronic Products.

■ JESD 97: Marking, Symbols, and Labels of Lead (Pb)Free Assemblies, Components, and Devices.

■ J-STD-020C: IPC/JEDEC Moisture/Reflow SensitivityClassification for Nonhermetic Solid State SurfaceMount Device.

■ J-STD-033B: Handling, Packing, Shipping and Use ofMoisture/Reflow Sensitive Surface Mount Devices.

■ JP002: JEDEC/IPC Current Tin Whiskers Theory andMitigation Practices Guideline.

■ JESD201: Environmental Acceptance Requirements forTin Whisker Susceptibility of Tin and Tin Alloy SurfaceFinishes.

■ JESD22A121.01: Test Method for MeasuringWhisker Growth on Tin and Tin Alloy Surface Finishes.

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RoHS Service is a non-commercial service with the aim of supporting companies in the implementation of the EuropeanRoHS directive 2002/95/EC.The RoHS Service can carry out industry specific studies and projects. The execution is realized by SIRRIS or IMEC experts,if necessary supplemented by the expertise of third parties. Price-setting is realized on the basis of a tender after notification of the company request. The RoHS Service intends to offer the fullest support possible.■ Interpretation of the directive.■ Lead-free soldering■ Component and card specifications■ Product specific design problems■ Quality specifications and test procedures■ Definition, selection and evaluation of machines■ Solder alloys and solder materials■ Processing problems, processing inspection and quality■ Logistical organization■ After Sales Service■ Alternatives for hexavalent chromium

■ Contact: Geert Willems, Tel: +32 498 91 94 64E-Mail: [email protected], Web: www.rohsservice.be

■ RoHS service

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A cooperation between

With the support of

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■ Colophon

A joint realization by SIRRIS - IMECwww.sirris.be - www.imec.be - www.rohsservice.be

Coordination: Marketing DepartmentEditorial team: Geert Willems, Pieter Kesteloot, An Van DenhouweLay-out: Sleurs Prepress, Overpelt Print: Sleurs Printing, OverpeltResponsible publisher: Herman Derache

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