Authored By:
Jackie Adams, Terry Godown, Kenneth Lyjak,
Louis Ferretti, Mina Cordioli, Darren Samson, Fabio White
IBM Corporation
Raleigh, NC, USA
Poughkeepsie, NY, USA
Summary
RoHS (Restriction of Hazardous Substances) regulations (1) vary by geography, e.g., EU RoHS, China RoHS Hazardous substance table, individual U.S. states, cities, etc. The information needed to be gathered for material declarations vary as the regulatory requirements change. However, most RoHS requirements focus on a common theme, e.g., removal and/or reduction of hazardous substances
With respect to the European Union (EU) RoHS requirements, various exemptions have been granted, albeit some have an expiration date. On the other hand, EU REACH legislation (2) has no such provision. In either case the ability to readily assess the concentration of substances in articles (SIA) for REACH or in homogeneous materials for ROHS is needed.
When preparing to meet EU REACH requirements for I/T electronic hardware, the focus is on tracking, communication, and notification of certain substances in articles, while RoHS focuses on eliminating or restricting the use of heavy metals and other substances in homogeneous materials. Because of the larger number of potential chemicals involved (Substances of Very High Concern, SVHC, candidates), and the fact that there are no exemptions applicable to hardware products, the REACH requirements can be a challenging task for companies.
With EU REACH, if you exceed the stated concentration level of SVHC candidates in articles (e.g., hardware products), producers and importers in the EU are subject to communication and possibly notification requirements. This drives extensive information requests throughout the supply chain. These regulations drive requirements for quantitative and qualitative chemical data and an increased need for the surveillance of emerging regulations as they are being formulated so that one can design compliance processes that are ahead of what will become firm requirements.
This paper will attempt to outline data collection options that the electronics industry can deploy in connection with their supply chain and with their clients to develop material composition information systems necessary to comply with both RoHS and REACH requirements.
This paper is not meant to be the silver bullet, but rather the start of a brainstorming session to develop options and possibilities that will produce a new and common approach that can enable the electronics industry to collect materialcomposition data for hardware products in a more effective and efficient manner
Conclusions
It is evident with growing legislation, varied data collection methods, and the amount of accurate and accessible data needed, a simple means of data repository would be an advantage to the electronics Industry. For now a service provider as a partner can ease the data collection burden as the industry drives to a suitable solution to this problem. It is, of course, not easy to take such a complex industry and make it simplistic in nature.
To ask an industry with substantive knowledge encompassed with a mix of proprietary and commercial IP, to now entrust an industry council, or an industry team, to design, police and maintain a universal EE data base, may prove challenging. It is suggested in this paper to not look at the immediate answer but let's work to develop a longer term solution for the OEMs, supply chain and business partners.
Initially Published in the SMTA Proceedings
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