RoHS requirements worldwide - a brief guide

Restricted substances
The EU RoHS restricts six substances: lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). These are restricted to 0.1% by weight in homogeneous materials except for cadmium which has a limit of 0.01%.

RoHS requirements worldwide
Apart from the EU, Norway, Switzerland, Korea and three US States have imposed restrictions on the same six substances as EU RoHS. The substances restricted are the same but the product scope varies considerably as does the approach required to show compliance. China, Japan and a few US States have marking or information requirements for certain electrical products but no restrictions yet.

Exemptions
Most electrical products cannot be made without small quantities of at least one RoHS substance (usually lead). Where no alternative exists or where the only substitutes are more harmful, exemptions from the use of the RoHS substances are granted by the EC. The exemption application process is very complex and obtaining exemptions is not easy even if they are clearly justified.

ERA can provide unbiased independent technical assistance to prospective applicants and has already helped several manufacturers to obtain favourable decisions.

The existing RoHS exemptions have recently been reviewed and the exemption application process is likely to change so that even more effort will be required from manufacturers.

Product scope
Currently in the EU, eight categories are covered but there are proposals to include two additional categories.

The scope in the EU is not always clear and ERA has assisted many manufacturers to determine the status of their products. Elsewhere, the scope is different. Korea-RoHS currently covers mainly home and office products. California includes only certain types of displays although there are ongoing efforts to broaden the scope.

How to comply
Compliance requirements vary from region to region. The EU currently relies on self-declaration although manufacturers and importers should not accept declarations from suppliers at face value. The UK enforcement body NWML has found that one of the most common reasons for non-compliance is not interpreting materials declaration certificates correctly. Analysis is often seen as a last resort but will be expected if there is a clear risk of non-compliance.

Reliability issues
Whether a manufacturer produces RoHS compliant products or continues to use tin/lead solder but with RoHS compliant components, there are concerns over long-term reliability. This is a particular concern with military and aerospace products.

ERA has reviewed reliability issues as part of a study for the EC and also has many years experience investigating failures to electrical equipment. ERA has assisted many manufacturers with reliability issues and has helped to develop strategies for ensuring high reliability and preventing early failures, for example by introducing tin whisker mitigation strategies.

Products out of scope - what are the implications
All of the electronics industry is affected by RoHS. Most components have changed, many PCB assemblers now offer only lead-free processes and some customers will demand RoHS compliance even if it is not a legal requirement. Also, the scope may change and medical devices and monitoring and control instruments will be included in the scope of EU-RoHS. There are still uncertainties over the status of fixed installations in EU and more countries are planning to adopt RoHS legislation or broaden the scope of their existing regulations.

How can ERA help?
ERA has been supporting industry worldwide, UK government, RoHS enforcement bodies and the European Commission for several years on practical approaches to RoHS compliance and is internationally recognised as being leading experts in this area. ERA can help in the following ways:

All of these can be carried out on an individual or call off contract basis or through our subscriber scheme, AccessERA.

RoHS compliance assessment and analysis
It is impossible to analyse every homogeneous material in all but the simplest electrical products as this would be prohibitively expensive and is also not necessary and so a simple strategy is required to assess components, materials and products based on risk that can be carried out at minimum cost. ERA utilizes this approach to assess components, sub-assemblies and products.
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Troubleshooting product reliability
ERA assesses “lead-free” product quality and can assess reliability (e.g. examination of solder joints, PCBs and components). ERA can also recommend strategies for avoiding problems such as tin whiskers and thermal fatigue and can also give advice on product reliability testing procedures. If failures occur ERA can determines the cause of failures and will recommend corrective action.
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Developing RoHS compliant designs and processes
There is no drop-in replacement for tin/lead solder; each of the alternative solders is different and the implications need to be understood to avoid problems. The use of lead-free solders has implications for component and PCB reliability that also need to be understood if problems are to be avoided. ERA can help you assess product quality, and the suitability and reliability of other alternative materials (e.g. to hexavalent chromium for example) and components.

ERA’s credentials
ERA’s reliability and failure analysis group (RFA) assisted the UK Department of Trade and Industry and European Commission develop a practicable approach to demonstrating RoHS compliance. Much of this flowed through to the UK RoHS guidance and the informal RoHS enforcement guidance on which ERA advised. ERA carried out the first review of RoHS exemptions for the EC and recently completed a study for the EC on the possible inclusion of medical and monitoring and control equipment in the scope of RoHS. ERA advises and lectures widely throughout the world on RoHS and is recognised as an authority on
RoHS issues globally.