Environmental Compliance -

Q: What is the RoHS Directive?
A: The RoHS Directive is properly known as the Directive of the European Parliament on " The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment ". It establishes limits for the content of six types of hazardous material in electrical and electronic equipment placed on the market in Europe after July 1, 2006.

Q : What are the six substances?
A: The substances are lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers. This includes both metals and compounds of lead, cadmium and mercury. The RoHS Directive sets maximum concentration levels allowable of these substances in the "homogenous materials" of electrical and electronic equipment covered by the legislation. The proposed maximum concentration levels in homogenous materials for lead, mercury, hexavalent chromium, polybrominated biphenyls , and polybrominated diphenyl ethers is 0.1 percent by weight, and 0.01 percent by weight for cadmium.

Q: What does "homogenous material" mean?
A: Homogenous material is defined as material that cannot be “mechanically disjointed” into different materials. ”Mechanically disjointed” means that the materials cannot in principal be separated into other materials by mechanical methods such as unscrewing, cutting, crushing, grinding or abrasive processes. A clean separation is not a requirement and this definition is intended only to indicate that materials such as plastics, metals, and coatings, etc., should not contain the restricted substances. Therefore, a semiconductor component is not homogenous, as it is made up of many other homogenous materials such as the case (plastic moulding), the leadframe alloy and the leadframe coatings, etc., each of which must separately comply with the RoHS restrictions.

Q: What does the RoHS Directive require affected companies to do?
A: RoHS requires companies who place electronic or electrical goods on the market after 1 July 2006 to ensure that they do not contain above permitted levels of the six specified hazardous substances.

Q: If the RoHS requirements are only restricting six substances, why are some companies attempting to control nearly 100 substances, to detailed and specific percentages?
A: While many companies could have their own initiatives and directives, RoHS clearly pertains to the six stated substances. There is also a dangerous substances directive in the EU, which bans many other substances that may be included in some companies' questionnaires.

Q: Is it true that an electronic assembly with less than 0.1% lead by weight would be non-compliant if any components on it have solder plating that contains more than 0.1% by weight itself?
A: Yes, because the concentration limits apply to homogeneous materials and the solder plating is one material.

Q: Design engineers deal with many parameters per component as it is. Can't we consider this as just a one-bit field that we have to add to all components--RoHS Y/N?
A: Yes! It is a best practice to add a parameter for RoHS compliance. That is one of the ways we at Arrow are managing our business and the transition.

Q: Are we obligated to document the amount of lead in each homogeneous substance of the components?
A: No, there is no legal requirement for this.

Q: What methods do you think regulators will use to detect violations?
A: Various methods will likely be used. Holland has decided that customs will spot check product as it is imported. XRF testing is only likely method.

Q: Are there any good books outlining a compliance plan for a small company?
A: ERA has published a guide, there is info at http://shop.era.co.uk/products.asp?recnumber=573. There is also a Transition Planning guide on http://www.arrow.com/green.

Q: Will current suppliers' parts go end-of-life because of the RoHS deadline?
A: We do not yet have enough data to estimate the percentage of parts obsoleted due to RoHS, but we have seen an increased number of end-of-life parts over the past several months and quarters.

Q: If my company is WEEE compliant, do we still need to be RoHs compliant?
A: It depends on what you make. If your products are within the scope of the RoHS directive, the answer is yes.

Q: Are spare parts for end of life/ obsolete product exempt from compliance?
A: Spare parts for repair of equipment placed on the market before the deadline are excluded, otherwise, they must be compliant.

Q: What about dedicated military products, there seem to be applications that insist on lead?
A: Products made specifically for military applications are excluded from the WEEE and RoHS Directives.

Q: What about batteries and RoHS?
A: Batteries are excluded from RoHS because the separate batteries directive in the EU covers them.

Q: Do fasteners such as screws or washers need to be RoHS compliant too?
A: Yes, if they are used in RoHS compliant equipment.

Q: Would one IC in a 8umax package which contains lead cause the whole product to fail compliance?
A: RoHS bans anything over a .1% concentration of lead in a homogeneous material. The Department of Trade and Industry (DTI) in the UK in a draft guidance document describes homogeneous as follows: "'Homogeneous material' means a material that cannot be mechanically disjointed into different materials." An IC contains multiple homogeneous materials. Detailed analysis is required to determine the concentration of a restricted substance in any material. Here is a link to the document referenced: http://www.dti.gov.uk/sustainability/weee/RoHS_Regs_Draft_Guidance.pdf.

Q: Will new products need to be identified outside with a label to say that are RoHS compliant?
A: There are not, as of yet, any RoHS requirements for marking or labeling to indicate compliance. JEDEC has issued a standard, JESD97, which outlines identification standards for lead-free assemblies, components and devices, which can be found at http://www.jedec.org/download/search/JESD97.pdf.

Q: Please clearly define "put on the market".
A: The EU definition is found on pages 19 and 20 in the document, Guide to the Implementation of Directives Based on the New Approach and the Global Approach http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/legislation.htmon

Q: Should we change our part numbers?
A: We recommend changing internal component level part numbers to indicate that an item is RoHS compliant. Depending on your supply chain, industry and end market, indicating RoHS compliance at a finished product level with a part number change may also be a best practice.

Q: Can member states can ask for "better than" requirements. As an example, can Germany be more stringent on a limit than the UK?
A: For RoHS, all member States must have the same requirements. However, with WEEE, States can add requirements although so far, none appear to have added any significant requirements.