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Leon Dixon columns | February 27, 2006

Lead free - are you compliant, or merely capable?

Jaltek Systems Director of Technology Leon Dixon is put under spotlight to reveal his thoughts about the RoHS compliance work.
As the clock ticks on, any electronics company worth its salt is doing all it can to ensure that its products, processes and business activity are ready for July 1 2006, when RoHS legislation transforms lead-free in Europe from a nice marketing message to a legal obligation. Naturally, the UK's EMS companies, who, like their fellows the world over have broad manufacturing portfolios and thousands of components and products to approve for their lead-free processes, are doing as much as anybody to prepare for the big day. But are they really RoHS compliant? For Leon Dixon,
his entails.

Five steps to compliancy
Jaltek's compliancy for ARM, which started in earnest in May 2005, consists of five phases:

1) Analysis of target product design - completion July 2005
Jaltek examined ARM's new products from the point of view of their electronic, electrical, mechanical and packaging characteristics and checked for Bill of Materials compliancy to RoHS. Involving hours on the telephone to suppliers of components, electrical materials and cables, this is the root cause of Dixon's conviction that RoHS compliancy is more fiction than fact. "Forget the chat - with the level of noncompliancy in the suppliers we talked to, and we talked to a lot of them, it's incredibly difficult for electronics manufacture to be compliant". In many cases, Jaltek remained unconvinced that sourced materials were as compliant as their suppliers declared. Dixon's team found an astounding 46% of part numbers that had not changed although suppliers declared that the parts themselves had been changed for RoHS compliancy. "For us, that message is ambiguous", says Dixon. "It's possible that the items in question have indeed been changed, but we can't always be sure enough to recommend that our clients use them in their products, which they must legally warrant to be RoHS compliant". Furthermore, and more worrying, was the fact that many suppliers of mechanical parts and cables had never even heard of RoHS, and a lead-free standard for cables has yet to be defined. This begs a question: If this is the true state of parts supply, how can electronics manufacture possibly be compliant? At the closure of this phase the data collected indicated the level of RoHS compliancy across the products.

2) Redesign of PCBs - completion December 2005
The boards that are to go forward are re-engineered for lead-free componentry and parts. Dixon: "Where clients do not have the resources to do this in-house, Jaltek takes this on through their design house, Abra Cad, redesigning boards to the IPC7351 standard. In this case, ARM took this phase in-house, but also had the option to leverage our support".

3) Prototype PCB assemblies - completion January 2006

This has not been done to date. Jaltek manufactures prototype boards according to the new designs, and defines final logistics support and purchase, bare PCB sourcing and assembly.

4) Analysis - completion February 2006
The boards are analysed for joint integrity and RoHS compliancy, encompassing metallurgy and other detailed analysis to check whether components really are leadfree as claimed.

5) Compliancy statements - completion April 2006
All phase 1 statements and analysis results are pulled together, and from this, the legal compliancy statements are prepared. At the end of each of the first 4 stages there is a reality check based on Jaltek's findings and recommendations for each product.

The cost of compliance - and non-compliance

A quick scan of the above makes it clear that nothing can be taken for granted; that compliancy takes time; that difficult decisions are necessary; and that the whole process is expensive. Dixon is thankful that Jaltek's complex products command a premium price: "I am afraid that smaller client companies will not be able to afford compliance - its cost is a factor that few think about until they get to grips with the process", he says, adding that for Jaltek, there were no significant capital expenditures necessary to move to lead-free: "Already at the beginning of 2005 we had the equipment we needed to go forward; independently of RoHS, we had invested in increased capacity and better heat capabilities at reflow and rework - investments that certainly help our compliancy".

From his findings throughout 2005, Dixon is now convinced that few, if any, EMS companies in the UK are following Jaltek's example, preferring to base decisions on product data sheets.

Does that matter?
For Dixon, it most certainly does: "Companies must go through the process, must be able to demonstrate that they have done their due diligence. There is no doubt that the RoHS legislation will be policed in one way or another, and the fact that companies must warrant legally that their products are compliant puts the onus squarely on their shoulders to ensure for themselves that the statement is true. Don't let's forget too that there is a lot of anti-competitive behaviour out there even now - companies tipping off border controls about non-conforming competitor products. We should all ensure that we are as well-protected as possible in this fiercely competitive world".

Applying the learning curve
Having started the compliancy process for ARM, Jaltek is currently taking other key clients through the project, which most agree is unique among UK EMS providers. "At the end of phase 5, Jaltek will have a wealth of knowledge about what is and is not compliant, what production processes to use, the temperature profiles to apply, sourcing, financing, costing, logistics, supply chain, the legal aspects and a host of other issues that are currently being dealt with in depth, " observes Dixon.

Lead-bearing applications - the issues
So that's lead-free. But there's a small postscript to the story, and it concerns what happens to applications that will continue to require lead-bearing parts - Jaltek's thought about that too. Not surprisingly, since it supplies high-reliability complex boards to industries such as defence and aerospace, that to some measure will be exempted from the RoHS legislation. Dixon explains that it is just important to ensure a continuing supply of lead-bearing products for these extremely sensitive applications as it is to ensure lead-free parts for the rest. Accordingly, his team is analysing this question in depth. "As a business, we will maintain both lead-free and lead-bearing processes, as defence contracts require that you are able to supply to a project for 15 years".

Conclusion
As this article amply demonstrates, there is a vast difference between RoHS capability and RoHS compliance. The responsibility for being truly compliant rests with the supplier of the electronic product, whether it is manufactured in-house or by an EMS provider and whatever datasheets may say. Whatever the case, all companies involved in electronics manufacture need to take compliancy seriously - there's no more time for chit chat.

Leon Dixon

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