Circuits Assembly Online Magazine

RoHS exemptions are a stay of execution, not a commuted sentence.

“Send lawyers, guns and money, the sh-t has hit the fan.” – Warren Zevon

Last year I presented the Five Stages of Lead-Free (sidebar). Now, with less than 10 months before RoHS kicks in, it is interesting to see how the industry is coming along. It depends upon where you look.

Phil’s 5 Stages of Pb-Free

Denial. Upon learning the implications of RoHS, the first response can best be described as shock. The shock resulting in Denial is usually a temporary defense.

Anger. When denial can no longer be maintained, it is replaced by anger, rage and resentment.

Bargaining. This is an attempt to postpone the unavoidable. Exemptions are sought out. However, the majority of products will have to comply.

Depression. Rage and anger are eventually displaced by fear of the work ahead. “Pb-free is a logistical nightmare. How will we ever make the conversion?”

Acceptance. We will overcome the overcome the obstacles and adapt, where appropriate, to Pb-free.

It is not likely that the next hit reality TV show will be based on our industry. The next best thing, however, is the IPC-sponsored, Internet listserv called TechNet. It has everything – entertainment, anecdotes, pathos and occasional wisdom amid the conspiracy theories and misplaced political commentary. While there is what could be called a regular cast of characters (emphasis on “characters”) there is no casting call; this international juggernaut of opinion and controversy is free and open to everyone. While the advice is free – and you get what you pay for – TechNet serves another important purpose: it is indicative of the pulse of the industry, at least in regard to North America and Europe. Market forecasts serve a purpose, but the listserv members are the men and women actually designing and building boards and assemblies.

Every now and then, someone will introduce a topic that will spark a virtual forest fire on the Net. A year ago, about 10% of the content on TechNet dealt with Pb-free or RoHS. Now, I would say about 60 to 80% of the listserv’s queries and comments are on such subjects. Of particular interest were recent threads questioning whether we are “just a bunch of lemmings” and more specifically, “Why not just say no to RoHS?” Alas, latent Denial.

My first reaction: Where were you eight years ago when this dastardly plan was conceived? The horse has long bolted the barn, blowing the doors off their hinges. Meanwhile, on TechNet, numerous responses revealed that most of its constituency is in the Anger phase – big time. Let’s burn down City Hall!

Let’s look at this in a calm, collected manner. Although the media have plastered us with articles on the upcoming Pb-free Apocalypse for the past four years or so, the marketing folks of the companies distributing product in the E.U. seemed oblivious to it and never rang the alarm, as in, What are we doing to prepare for this eventuality? Outside our industry, when was the last time you saw an article on the subject? It has not made CNN, BBC, Sky, Fox or USA Today (though I did hear recently a story about Pb-free ammunition on NPR, of all places). Still, if you are a design or process engineer, you had to be aware of the situation from all those articles in the magazines piled on the bathroom toilet or company library.

But can you say “No” to RoHS? The answer is, Yes – and blow off your E.U. market. While some companies may be willing to do that, it is not that simple. To paraphrase Paul Simon, “RoHS like a cancer grows.” Copycat legislation is afoot. For example, China and Korea, both places long renown for their environmental awareness, reportedly have legislation pending that mimics RoHS. Obviously, this is an accommodation (code for “suck up”) to the E.U. But closer to home, several states in the good ole U.S. of A. are looking at similar bills. In California, the e-Waste Collection and Recycling Act has more than a whiff of RoHS (and I doubt the governor will be terminating it). It follows, perhaps not quite to reason, that other states will implement aspects of RoHS within the next few years. We can guess the usual suspects: Oregon, Massachusetts, Vermont, Wisconsin and Minnesota, among others. So sure, go ahead, take a stand and just say “No.” Your competitors will love you for it, especially your friends in Asia.

By the way, I have been in PCB assembly facilities in Southeast Asia that have been 100% Pb-free for over two years. Granted, the majority have been building products (particularly consumer electronics) for Japanese companies. The Japanese have had a Pb-free roadmap in place since 1998 but it was industry driven, not government mandated. So let it be known that some electronics assemblers are well into the Acceptance phase.

Another alternative actively being sought, and representative of the Bargaining phase, is an exemption. Is your product among those that are currently exempt from compliance? Quite a few products are – for now. In the majority of cases you do not want to hang your hat on an exemption. Do you really think that the fathers of the RoHS legislation (or “mothers” as many call them) really intended to cover perhaps just half of the world’s electronics products? Think again. Those exemptions will be reviewed at least every four years and will have to be defended, vigorously. In other words, most will be fleeting. In the meantime, the Green Party in Europe is decrying the exemptions presently in place.

If the vast majority will have to comply with RoHS, what do you think will happen to components containing lead? As demand drops, so will supply. Where will you purchase Pb-finished components and PCBs? It strongly echoes the situation of through-hole parts as SMT kicked in. Except this will happen a lot faster because it is mandated by legislation with deadlines for compliance. It will not happen overnight, but change is occuring already. Those lovable rascally component manufacturers are already changing to Pb-free lead finishes and in many cases not telling us via changes in nomenclature, so you can be sure they are going to go with the masses. Want to stick with Pb-bearing components? Can you say end-of-life buy?

Needless to say, the truly wise engineers at companies that have exempt products are looking to transition to Pb-free as well as meeting the rest of the RoHS requirements. They know that exemptions are not a commuted sentence but just a stay of execution.

There are definitely those in heavy Denial, who feel that RoHS and Pb-free just cannot and will not happen. Twenty-five years ago some felt that SMT was just a fad, not a trend. Where are those naysayers now? Retired or dead and certainly glad they do not have to deal with RoHS. As for the rest of us, remember that we’re all in this together.

Au.: Special thanks to the truly wise Dave Hillman of Rockwell-Collins for our discussions a number of months ago regarding exemptions.

Phil Zarrow is president and SMT process consultant with ITM Consulting (itmconsulting.org); phil_zarrow@itmconsulting.org.