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Misconception 1:
Company is not affected Many suppliers and manufacturers think they are not affected by the EU’s RoHS legislation because they do not sell products directly in the EU market. They may not be affected by RoHS directly – but what happens when a customer needs compliant product? Even if no customers need RoHS compliant products now, the company should be aware there are several other legislative bodies enacting environmental restrictions around the world. As more and more communities, countries, and legislative bodies are working on implementing environmental directives restricting and banning substances, being ready for RoHS would allow an easier transition to meeting legislation which directly affects the company. Among the world communities working on implementing environmental legislations or directives are: China, Taiwan, Thailand, and several states in the USA. China is currently emulating the EU’s RoHS directive, but with have tighter restrictions. Starting this year, thirteen states in the USA are planning on implementing environmental restriction legislation and/or recycling laws; California, Massachusetts, and Maine have already set implementation dates. | Substance | Limit | | Lead | Up to 0.1% by weight of Homogenous Substance | | Mercury | Up to 0.1% by weight of Homogenous Substance | | Hexavalent Chromium | Up to 0.1% by weight of Homogenous Substance | | Cadmium | Up to 0.01% by weight of Homogenous Substance | | PBB | Up to 0.1% by weight of Homogenous Substance | | PBDE | Up to 0.1% by weight of Homogenous Substance | | Maximum concentration levels for restricted substances: Compliance with the RoHS directive is much more than making products“lead-free.” Lead is one of the six substances banned by the directive. The other five substances: mercury, cadmium, hexavalent chromium,polybrominated ethers, and polybrominated diphenyl ethers are also banned to limits stated in the chart. | Misconception 2:
Spreadsheets = Compliance documentation Many companies are completing spreadsheets with various columns listing material amounts for a component or product. The company then believes this spreadsheet is proof that the product or part is compliant. Simply filling in a spreadsheet will not prove “due diligence” in complyingwith the directive. A spreadsheet can be manipulated, falsified, and changed by anyone with access to an editing program. A spreadsheet is not a stand-alone auditable document. A spreadsheet may work in conjunction with otherdocumentation. If the spreadsheet is accompanied by other supporting documents – such as testing reports, certificates of compliance, roadmaps, and process records – then due diligence may be proved. Therefore, a spreadsheet is only part of a compliance strategy. All documents mentioned canbe considered part of a technical compliance file (TCF). Several industry standards organizations are working on introducing standardized reporting methods. For instance, IPC is working on IPC 1751 & 1752 which give direction on a standard format for reporting material composition by using a materials declaration sheet, or MDS. JEDEC, EIA, and JGPSSI published in April 2005 the Joint Industry Guide 101 Material Composition Declaration for ElectronicsProducts; commonly referred to as JIG A&B. Misconception 3:
Company compliance team = Compliance In the EU’s view, it is the product which will be selected for a market analysis or product audit, not the company. Therefore, a company’s readiness is not directly reflective of a product’s readiness. The compliance team may assist in proving due diligence actions, but it will not pass as a guarantee of compliance on its own. Be aware, if a Member state finds a product to be noncompliant, it has the abilityto make an example of the company. “As far as RoHS is concerned, a company must demonstrate that it has taken all reasonable steps to comply with the Directive’s requirements, if the company feels it has done that (but the national enforcement body disagrees), then it would be up to the court to decide if that really was the case or not.” If the RoHS Readiness team is fully implemented, they will be responsible for documenting the compliance of each product. They will also be responsible for documenting a procedure to follow for proving products are compliant. For a large corporation or company, formation of a team will not be an issue. They have the resources available to provide people power to the project. People can bereassigned or take on additional tasks. For a small or mid-sized company, the task of forming a team may be overwhelming; it may also not be practical. Companies offer several RoHS-related services; from guidance on creating a team, assisting in creating roadmaps and procedures, to creating documentation for a specificproduct. Having TCF for a product is an insurance policy. The documentation in the TCF is easily accessible and availablefor authorities if a product selected for market analysis. Misconception 4:
Definition of “Homogenous Substance” Many companies do not realize the definition of homogenous material has been updated. Many still think the definition means the total amount in the final product. The European Commission’s publication from May 2005,“Frequently Asked Questions … on … RoHS & … WEEE,addresses the definition of homogenous substance.Homogeneous material means a material that can notbe mechanically disjointed into different materials. Definitions: The term “homogenous” means “of uniform composition throughout.” Examples of “homogenous materials” are individual types of: plastics, ceramics, glass, metals, alloys, paper, board, resins, coatings. The term “mechanically disjoints” means that the material can, in principle, be separated by mechanical actions such as: unscrewing, cutting, crushing, grinding and abrasive processes. For clarification, the UK’s DTI included the examples below in its draft guidance. • … A plastic cover (for example) would be a ‘homogenous material’ if it consisted exclusively of one type of plastic what was not coated with or had attached to it (or inside it) any kinds of materials. In this case the maximum concentration values of the RoHS Regulations would apply to the plastic. • … An electrical cable that consisted of metal wires surrounded by non-metallic insulation materials would be an example of something that is not ‘homogenous material’ because a mechanical process would separate the different materials. In this case the maximum concentration values of the RoHS Regulations would apply to each of the separated materials individually. • A semiconductor package (as a final example) would contain many homogenous materials, which include the plastic moulding material, the tin-electroplating coatings on the lead frame, the lead frame alloy, and the goldbond wires. In this case the maximum concentration values of the RoHS Regulations would apply to each of the separated materials individually. EM | Krista Botsford is Co-Founder & Chief Executive Officer of 5-Trees LLC. She can be reached at kbots@5-Trees.com. | 
