Already the present RoHS directive had serious impact on the Swedish electronic manufacturing SMEs. The higher melting temperature of the lead-free alloys demanded major investments in soldering equipment and higher energy costs as well as uncertainty of long term reliability in harsh environments.

The proposal from Öko-Institut for a ban of a number (or all) organochlorine and organobromine compounds will include such vastly different substances as TBBP-A, PVC, Epoxy resins (adhesives, coatings and resins) and Flux activators.

Nearly all laminates contain an epoxy resin reacted with the flame retardant TBBP-A, which is regarded as non-toxic and OK for use according to REACH. As no substitute substances are drop-in replacements a ban will require redesigning, requalification and recertification of all products which would cost billions of Euros in Sweden alone, not to mention the sums in the rest of EU and globally. This without any environmental or health benefits, but with a number of uncertainties regarding environment and health impacts as well as regarding product reliability as the substitute substances are not tested.

The higher soldering temperatures needed for lead-free soldering combined with the maximum allowed temperature set by the components results in a narrower process window compared to pre-RoHS. Fluxes used for soldering most often contain organohalids as activators. A ban of these organohalids will reduce the process window even further and probably requiring an inert soldering atmosphere (which once again demands investment in new soldering equipment). A too narrow soldering process window will increase the number of unsatisfactory solder joints jeopardizing the reliability of the joint and hence the finished product.

Like the first ROHS implementation, an expanded RoHS will be spread into industries outside the scope of the ROHS directive. Manufacturers of long life, high reliability products, e.g. in the energy (both old and renewable) and transportation sectors, needs to run a RoHS compliant process (and stock) in parallel with their mature, well established process. The suppliers in those sectors have to guaranty the operation and cannot afford to use untested processes and materials, especially for products used in the harsh environment existing in different transportation applications.

For SMEs it is unachievable to control the whole supply chain for e.g. plastic parts manufactured in Asia. Imported parts and products can be analyzed but this has to be done for every produced batch and not just for every shipment increasing lead time and cost.

If the proposed bans will be a reality it will cause an enormous cost increase, amplify end user price, cause severe financial problems for SMEs (putting a lot of companies out of business and consequently increasing unemployment), decrease competition on the market and also severely slow down product development and all this without achieving any environmental benefits whatsoever.

Author: EIF