Guidance for RoHS (lead-free) and WEEE compliance from Arcom

What does it mean? – some basic facts
These two European Directives directly affect producers of certain items of electrical and electronic equipment. In summary, it affects products included within the following categories of equipment (except where specified):

It is the responsibility of the company placing the electrical or electronic equipment (EEE) onto the market (the producer) to decide if they are covered by the scope of the Directives. The producer is defined as the manufacturer, distributor or importer of the equipment within the European Union. As well as listing the categories of end-user equipment covered by the Directives, there is also a list of specific exemptions.

The WEEE Directive – at a glance
The WEEE Directive is basically environmental legislation designed to reduce the amount of waste electrical and electronic equipment (WEEE) being dumped in landfill sites. It aims to make the producer responsible for WEEE and encourage the recycling and re-use of EEE at the end of its useful life. The WEEE Directive defines 10 categories of end-user equipment (listed above) which are covered by the Directive and provides guidelines for recycling targets. This Directive became EU law on August 13 2005, however many Member States (including the UK) have not yet implemented national legislation or a practical system for handling the Directive. Click here for more details about the Directive, its interpretation and status within European Member States.

The RoHS Directive – at a glance
The RoHS Directive applies to end-user electrical and electronic equipment (EEEE) and sets maximum acceptable levels of 6 substances within the composition of the product – lead, cadmium, mercury, hexavalent chromium and both polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants.

The main issue facing the electronics industry is the use of lead in the manufacture of components and circuit board assemblies. The RoHS Directive applies to 8 of the 10 product categories defined in the WEEE Directive (it does not apply to Monitoring and Control Instruments or Medical Devices). This Directive comes into force on July 1, 2006. Click here for more details about the Directive and its interpretation.

Does it apply to your product?
Both Directives reference a list of product categories and exemptions to be considered by producers. The following information may help you decide whether your product falls within the scope of the Directives.

The two major types of equipment which fall outside the scope of both the WEEE and RoHS Directives are:

a fixed installation - this is defined by the European Commission Frequently Asked Questions document as, a combination of several items of equipment, systems, finished products and/or components assembled and/or erected by an assembler/installer at a given place to operate together in an expected environment to perform a specific task, but not intended to be placed onto the market as a single functional or commercial unit.

a large-scale stationary industrial tool/machine – this is a specific exclusion within product category 6 - electrical and electronic tools. It is defined by the European Commission Frequently Asked Questions document as, a machine or system, consisting of a combination of equipment, systems or products, each of which is designed to be used in industry only, permanently fixed and installed by professionals at a given place in an industrial machine or in an industrial building to perform a specific task.

[The WEEE Directive excludes these items because it is not practical to identify a single responsible party for disposal and recycling. The RoHS Directive excludes them on the grounds of consistency with the WEEE Directive.]

In addition to these, equipment described as monitoring and control instruments (such as industrial control panels and remote monitoring systems) and medical devices (including analyzers, radiotherapy equipment & laboratory equipment) are categories defined in the WEEE Directive which are specifically excluded from the RoHS Directive however, the current view is that this will not change until [at least] 2010.)

Finally, equipment used for servers, storage/storage array and telecommunications infrastructure (switching, routers and gateways) is covered by the RoHS Directive but, may use lead in solder (the limits for the other 5 substances must comply). This exemption has been introduced to allow lead in solders for professional, high reliability applications for which viable lead-free alternatives have not been identified. This category is informally referred to RoHS-5.

You can use the ‘decision trees’ listed below to help review your products – the bottom line is that you must decide whether your product falls within these Directives.

If your product falls outside the scope of the Directives…
If you decide that your product falls outside of these Directives, it is recommended that you record your decision within your internal product documentation. This may be used to demonstrate due diligence in the event that someone questions the product status. If the product is exempt or falls outside the Directive, there is no legal requirement to mark or make a statement on your published documentation or packaging.

What do I do if my product is covered by the WEEE Directive?

The implementation by most European Member States is largely focused on house-hold/consumer WEEE. The essential requirement for business-to-business (B2B) WEEE is as follows:

publish your take-back policy
for product placed on the market before August 13th, 2005 and,

if your customer is essentially making a like-for-like purchase (to replace previously supplied product), then you are responsible for the cost of disposal

if your customer is not replacing the product, the customer is responsible for the cost of disposal

for product placed on the market after August 13th, 2005, you are always responsible for the cost of disposal unless you agree otherwise in your contract with your customer
you must register as a producer with an authorized regulator in each Member State. Alternatively, you can register with a number of agency schemes who will deal with this on your behalf. Generally, the registration must be carried out by the producer or producers representative in each Member State, however, the interpretation of the Directive differs across the EU, so check with your local regulator.
in most Member States you will also need to mark your product with the symbol (shown here) and indicate when the product was placed onto the market. You should consult with the local regulator for each Member State.

A summary of the implementation status for each member state is provided in the latest Perchards report.

WEEE

What do I do if my product is covered by the RoHS Directive?
If you decide your product is covered by the RoHS Directive and you can demonstrate that you comply, you will need to make a self-declaration (similar to the self declaration statements made for the European EMC Directive). To support your self-declaration you will need to maintain a technical construction file (TCF) which records your decision and includes all the supporting information such as material declaration forms for each component, sub-assembly and construction material used within your product.

In addition to the electrical and electronic components and sub-assemblies, it is also necessary to check on the RoHS compliance for the plastic, paints and metalwork surface finishing materials. For example, lead, PBB and PBDE have been used in cable sleeving material while hexavalent chromium is produced when zinc chromate is used in the plating process to create the anti-corrosion finish (for metalwork assemblies). In summary for machine builders, you will need to review every aspect of the material content and obtain material declaration forms from all suppliers in order to compile your Technical Construction File and claim compliance.

For marketing purposes, many countries use a variety of symbols to indicate ‘lead-free’ manufacturing, however, there is no legal requirement to mark the product to indicate compliance with the RoHS Directive.

How is it monitored within the European Union?
The WEEE Directive is monitored formally via the assigned authorities in each Member State. The Directive defines certain recycling and re-use targets, therefore each producer must be registered (separately in each Member State) and report the amount of EEE placed onto the market in each Member State. The producer must also report how much EEE is collected and recycled. The authority will monitor whether you are achieving your targets. In some Member States, the registration, target setting and monitoring are carried out by different organizations.

For the RoHS Directive, there is no formal monitoring process or prescribed method for demonstrating compliance and no specific ‘marking’ required for a RoHS compliant product. If your product is covered by the RoHS Directive, you must make a self-declaration. Non-compliance can only be highlighted by a third party complaint, by an enforcement authority making a test purchase or by requesting non-existing support documentation. The Enforcement Authority is unlikely to be the Customs & Excise for each Member State (the UK has appointed the National Weights and Measures Laboratory for this role), so a Customs officer does not decide whether a product is compliant or not.

Arcom’s Policy for the WEEE Directive
Arcom produces a variety of electrical and electronic sub-assemblies and end-user equipment. Most of the electronic system sub-assemblies produced by Arcom are integrated into end-user equipment by our customers or by someone further along the supply chain. Some products manufactured and sold by Arcom are classified as end-user equipment (such as the rack mount industrial APC, industrial compact enclosure (ICE) systems and ‘Director’ industrial network gateways) and have been evaluated with respect to the ‘decision tree’ for the WEEE Directive.

as part of a fixed installation - this is defined by the European Commission Frequently Asked Questions document as a combination of several items of equipment, systems, finished products and/or components assembled and/or erected by an assembler/installer at a given place to operate together in an expected environment to perform a specific task, but not intended to be placed onto the market as a single functional or commercial unit.

or, is installed by our customers as part of a large-scale stationary industrial tool/machine – this is an exclusion within product category 6 - electrical and electronic tools. It is defined by the European Commission Frequently Asked Questions document as, a machine or system, consisting of a combination of equipment, systems or products, each of which is designed to be used in industry only, permanently fixed and installed by professionals at a given place in an industrial machine or in an industrial building to perform a specific task.

Based on these defined uses, Arcom is not covered by the WEEE Directive. However, to assist our customers, Arcom will accept the return of any Arcom equipment and process this using an approved recycling agent. Arcom may charge a fee for this service.

Arcom’s Policy for the RoHS Directive
Arcom produces a wide range of electronic sub-assemblies (embedded boards and sub-systems) and end-user electrical / electronic equipment. These products are integrated into end-user equipment for a variety of applications or installed with other equipment. Although it is the responsibility of the equipment producer to comply with the RoHS Directive - Arcom will support customers by providing RoHS compliant options for many existing products together with new products introduced from October 2005. In some cases, Arcom is limited by the availability of certain components, however it is anticipated that all RoHS compliant product options will be available from May 2006. We will also maintain normal supplies of lead-based products for customers using our boards in RoHS exempt OEM products and products outside the scope of the RoHS Directive for the foreseeable future – this will avoid re-approving your product with lead-free boards.

Arcom identifies lead-free RoHS compliant products using a unique part number and by adding a –R6 to the product name. Products using lead but compliant with the other 5 banned substances use the suffix –R5; for example;

The status of each product is indicated on the individual web pages and datasheets using the symbols shown below.

Each product is also supported with a complete electronic Technical Construction File (TCF) so that we maintain a detailed record of material declarations for all components. Arcom can provide a Materials Declaration Form for any RoHS compliant product option on request.

You will note that some products are highlighted as suitable for the RoHS listed exemptions which may use lead-based solder – for example, products used for servers, data storage array equipment, network infrastructure equipment for switching, routing and gateways may be supplied with lead-based solder. The other 5 banned substances are within the RoHS limits. This category is informally referred to RoHS-5.

Products compliant with the limits of the 6 banned substances, i.e lead-free RoHS compliant options will be identified with the following symbol. This is also informally referred to as RoHS-6.

Products which use lead in the solder but are compliant with the limits of the other 5 banned substances may still be used in the equipment listed in the RoHS exemptions (servers, storage/storage array and telecommunications infrastructure). These products are identified with the following symbol and informally referred to as RoHS-5.

Information about manufacturing and inspection
Arcom is using a tin-silver (3%)-copper (0.5%) SnAgCu alloy solder material along with electroless nickel/immersion gold (gold over nickel) PCBs for the manufacture of lead-free RoHS compliant board level products. In line with most lead-free solder processes, the reflow temperature has been increased to 250°C.

For those involved with product inspection, it is important to recognize the changes to the ‘product finish’. Lead-free solder and the associated no-clean flux material do not have the same characteristics as traditional tin/lead solder. The most significant difference is that lead-free solder alloys may have a dull or grainy appearance. These differences may be interpreted as a poor or dry solder joint using traditional inspection standards. To address this, the IPC (Association Connecting Electronics Industries) has updated the ‘Acceptability of Electronic Assemblies’ inspection standard IPC-A-610 to issue D. Soldering acceptability standards (section 5.1) specifically addresses lead-free inspection criteria and provides visual comparison of tin/lead and lead-free alloys (see example below). The complete guide is available from the IPC web site (www.ipc.org).

Finally, as part of the assembly of a complete instrument, machine or system, it is necessary that all solder joints are lead-free to declare that the machine is RoHS compliant.

Exclusion and Liability
These Directives are complex and these guidance notes are issued for general information only. Professional advice should always be sought to take account of individual circumstances. Arcom cannot accept responsibility for actions taken on the basis of these notes alone.