RoHS - Changing Products to Conform

George Galyon, Marie Cole, Jacklin Adams
John Quick, Fabio White, Lou Ferretti, Sophia Lau
IBM Corporation

In February 2009 the consultant for the European Union's Directorate General responsible for the environment recommended that over 30 RoHS (Reduction of Hazardous Substances) exemptions be phased out starting in December 2009 through July 31, 2014[1]. Some exemptions were for narrow applications used in special products, but most have been widely used throughout the electronics industry. Due to the critical nature of some of these exemptions and the varying dates for their phaseout, the logistics for compliance with the new requirements will be considerably more complex than it was for the original 2006 RoHS regulations.

A strategy has been implemented within IBM to tackle the challenges associated with converting data systems, product design, and supply chains to meet the revised RoHS regulations. Considerable attention has been given to ensure that clear distinctions are made among parts/products that are compliant with differing expiration criteria. For example, a given part can be compliant to the 2006 regulation while another part may be compliant to an expiration date effective Dec 31st, 2009, and so on. Data management systems must mirror these differing part compliancies and ensure that product environmental compliancy data is current. Suppliers must be well-informed and familiar with the new EU requirements and must agree to differentiate their products in step with the new regulations. This differentiation can be accomplished by either a part number change or some other agreed to method between the Original Equipment Manufacturer (OEM) and the Contract Manufacturer (CM) or raw material supplier. A product compliance approach will be outlined and presented here using the proposed EU RoHS exemption phase-out dates as stated in the February 2009 consultant report.

Strategies must consider product life cycles so that unnecessary changes are not made to products that will be withdrawn from the market before the exemption phase out expiry dates are effective. In some cases, it will be necessary to withdraw products from the market because the costs necessary for compliance conversion are not practical based on the remaining product lifecyle. Particular attention must be given to those situations where new compliant parts and their "usage" applications are coupled with product performance and reliability. For example, timing circuitrysignal integrity is susceptible to device parasitic impedance changes which may not be evident in the device specifications but which may become evident in the "usage" application.

Finally, some 2013-2014 exemptions are not certain to be phased out and will be continued until the next exemption review period. It may not be possible or practical to eliminate these particular exemptions for a variety of reasons. For example, alternative material or part solutions are not available at all or alternative solutions are limited to prototype or beta level parts with very high reliability risks associated with implementation. Each exemption phase out approach and solution must be evaluated on its own merits

This article has described a recommended overall implementation and management methodology in anticipation of the elimination of many of the current RoHS exemptions. Considerable investment in part number parametric databases and analysis tools infrastructure has been made to support RoHS (and other) environmental regulations needed to provide an auditable data set and a set of engineering controlled procedures. Some of the proposed exemption phase outs will require significant resources for effective implementation and some exemptions will require technical invention.

Supplier involvement throughout the change processes is essential and so is world-wide employee awareness throughout the OEM system producer. The authors hope that this article will be useful to others facing the same management challenges in the IT industry