Latest Updates | RoHS Explained | Exemptions | Official Documents

Complying with the RoHS directive is not as simple as identifying pin-for-pin replacement parts or picking a date to start manufacturing a newly designed product. A host of issues beyond the control of individual OEMs or EMSs make compliance a complex undertaking:

• Part nomenclature rules don't exist. The majority of the industry agrees that the most effective way to manage the transition from non-compliant to compliant parts is to identify different versions through part nomenclature changes. However, there are no agreed-upon guidelines and suppliers are devising their own prefixes, suffixes, or symbol combinations to indicate differing versions. Read more about supplier part numbering policies.

• Compliant parts are not yet widely available from all manufacturers. Component manufacturers are phasing in compliant parts with demand and as raw materials and manufacturing resources become available. Some suppliers are even choosing to break the level of compliance down into phases, such as releasing a version of a component that is lead-free but not fully RoHS compliant and then releasing a fully RoHS compliant version of the same part at a later date. View more detail on Varying Supplier Roadmaps.

• A large number of lead-bearing components will become obsolete. Even if your company's products fall into an exempt category, as with some automotive or defense products, it is unlikely that all suppliers will continue to produce both non-compliant and compliant versions of the same component. Everyone in the industry will need to pay close attention to end-of-life notices and carefully plan life-time-buy inventory levels. Life-time buys of non-compliant parts will not help, however, if the equipment is within the scope of the RoHS directive. According to the Directive, all parts used must be compliant in equipment placed on the market after the first of July 2006, unless exemptions apply.

• As OEMs transition to RoHS compliant parts, they need to ensure compatibility and solderability with existing products and manufacturing methods. Some components may not have been designed to tolerate higher temperature soldering. Lead-free solder pastes typically require higher solder temperatures, but individual components and printed circuit boards are not all designed to tolerate the higher temperatures. Also, the use of lead-free solder on a lead-bearing component could contaminate the joint and research has shown that this combination can affect its reliability and shorten field life.

• The performance of compliant parts and solders may not be identical to their lead-bearing predecessors. In products where safety and reliability are imperative, retesting and recertification of the products should be done. This will increase both time to market and manufacturing costs.

• Electronics manufacturers should have a transition plan in place now. Arrow recommends a responsible, LEAN approach that is scalable and flexible to accommodate final regulations while avoiding the dangers of building excess cost into your long-term model. With the regulations going into effect in July of 2006, and some design cycles extending to 18 months, companies not already developing their transition plan will find it increasingly difficult to meet the deadline for some types of products. Review Arrow's suggested Action Plan.

The directives do not provide specific guidance on the documentation that end product manufacturers need to create to prove compliance. There are no registration or submission requirements to establish compliance as EU Member States have indicated that the concept of “self-declaration” will apply. If challenged by authorities however, manufacturers are required to demonstrate that they have used due diligence to comply with RoHS. It has been suggested that proof of “due diligence” should be based on information or materials declarations obtained from their suppliers unless the manufacturer has good cause to question the accuracy of the information provided.

Please visit the Oxfordshire Trading Standards home page to review general guidance as it relates to the requirements of due diligence as well as examples of previous court cases involving the use of "due diligence" as a defense.