RoHS Exemption Review Case Study

Marie Cole, Jacklin Adams, Steve Bushnell, George Galyon
Curtis Grosskopf, Mark Hoffmeyer, Jim Wilcox
IBM Corporation

The European Union's Directive for the Restriction of the use of certain Hazardous Substances (RoHS) has been applicable to new electrical and electronic equipment put on the EU market from 1 July 2006 [1]. When the Directive entered into force in February 2003, provisions were made in the Annex to exempt certain uses of otherwise restricted substances in specific cases where the negative effects were likely to outweigh the environmental, health and/or consumer safety benefits of the substitution.

As required by the Directive, a review must be conducted every four years to determine whether there is valid scientific data to support the continuation of each exemption. With the previous review of exemptions conducted in 2004 that included the initial ten exemptions and the first group of modifications / additions, 2008 brought the first full review of the portfolio of exemptions after the Directive came into force.

During the exemption review, representatives of individual companies and those affiliated with industry associations presented the technical progress applicable to approximately 30 exemptions and submitted position statements for review by a consultant selected by the European Commission. This paper will share a case study of activities undertaken to develop and submit a position on the exemption allowing the use of lead in solders for servers, storage and storage array systems, network infrastructure and similar equipment, exemption 7b. It will also provide some brief highlights of the exemption reviews of the 'lead used in compliant pin connector systems' and the 'lead in solders for flip chip packages' exemptions, also critical to high reliability server systems.

In addition, the paper will present an exemption transition strategy that could be applied to the phase out of any exemption. With technical advances in many areas of materials development and the goal of the European Commission to reduce the scope and number of exemptions, it can be expected that the electronics industry will face several years of change management as RoHS materials allowed today by an exemption are replaced. Developing a transition roadmap throughout the supply chain and maintaining an accurate materials content database to document compliance are an essential but complex task given the scope of expected modifications.

This complexity is multiplied by the many other worldwide regulatory initiatives affecting hardware and environmental compliance material tracking needs. Learning from this exemption review should be applied now to assure adequate industry preparations for the next review, even while the industry transitions away from several exemptions slated for near-in expiration.

Considerable advances have been made in the reduction and elimination of lead (Pb) from electrical and electronic equipment throughout the supply chain and in a range of product market segments since the RoHS directive was initially enacted in 2003. Even in areas initially exempted from certain requirements, such as the allowance for the continued use of lead in solders for servers and other high reliability systems, advances have been made.