As the RoHS July 1, 2006 deadline gets closer, OEMs are asking their component suppliers for statements on the contents of RoHS-compliant parts. Governmental bodies in the European Union have indicated they will turn to OEMs for some unspecified paper trail substantiating RoHS compliance. But the info OEMs are getting from their parts suppliers is arriving is a disturbingly wide range of formats, and some of the data is downright false.
The Association Connecting Electronics Industries (IPC) has issued a standard format for communicating the materials content of components – IPC-1752 – but the standard is still in a draft state. Industry members are presently voting on adopting the standard. The National Electronics Distributor Association (NEDA) has issued a stripped-down spreadsheet that can be used as a standard for communicating the contents of components, but is it not being widely used. Consequently, OEMs are stuck with finished products that don’t have coherent compliance paperwork in place.
According to Michael Kirschner, president of Design Chain Associates, LLC in San Francisco – a company that helps OEMs and suppliers manage their compliance data – OEMs have collected an average of 70 to 80 percent of the materials declaration they need. “It’s a risk to go forward with a product that doesn’t have all its materials declaration,” says Kirschner. “OEMs have to decide whether to accept that risk.”
Even that 70 to 80 percent of materials declaration is itself at risk. “The materials declaration is strewn with errors,” says Kirschner. “About 20 percent of the declaration data contains errors of one sort or another.” He notes that one declaration statement listed epoxy as a metal.
Many of the declaration statements come as a simple negative statement: “This product doesn’t contain any of the banned materials.” Or it may state that the component contains x amount of lead. In some cases, the level of lead declared to be in the product is actually above the tolerable level described by RoHS rules.
As for the IPC and NEDA standards, Kirschner is not seeing them widely used. “Neither standard is getting use in the industry. The IPC standard is not available now, since it’s just a draft.” He believes the IPC-1752 will pass its voting procedure and become a standard, but in the meantime, materials declaration is coming in multiple flavors. “Every supplier is doing its own format,” says Kirschner. “That’s causing a real problem.”
Part of the difficulty for the industry is that the European Union countries have not clearly stated what they want to see in compliance documentation. “Generally the governing bodies have not specified what they want to see,” says Kirschner. “Some countries have a concept of what they want, and the UK has good guidance, but it there’s a problem with compliance documentation in that we don’t know what constitutes good due diligence.”
Meanwhile, many OEMs are taking a relaxed attitude toward compliance documentation. “I don’t see a lot of concern about not having all the details,” says Kirschner. “They’re just accepting their supplier’s word, trusting that their suppliers know what they’re doing.” He notes that many OEMs that run into trouble with European governing bodies will have little to back up their claims that their products are compliant.