SMTA International Conference Proceedings

EU RoHS Exemptions, Technology And Trends Since Promulgation

Authors: Jackie Adams, Marie Cole, Mary Beth Fletcher, George Galyon, Curtis Grosskopf, John Quick, and Sophia Lau
Company: IBM Corporation
Date Published: 10/16/2011   Conference: SMTA International

Abstract: The European Union's (EU) Restriction of Hazardous Substances Directive 2002/95/EC (RoHS) took effect on July 1, 2006 [1] and restricted the use of six hazardous substances in the manufacturing of electrical and electronic equipment sold in EU. When the Directive was first published in 2003 there were permitted exemptions to allow the use of these otherwise restricted substances in certain product applications where no suitable replacement technology was available. Several Commission Decisions amended the Directive for the purpose of adapting to technical progress and granted several new exemptions. The RoHS Directive at that time required the EU Commission to review allowed exemptions every four years to determine whether a suitable replacement substance or alternative technology had been developed that would allow the EU Commission to phase out and eliminate the allowed exemptions..

In 2008, an independent consultant group was commissioned by the EU Commission to review the industry’s technical progress for the elimination of each of the allowed exemptions. During the stakeholders review period, industry representatives submitted position statements to the EU Commission consultants that outlined the technical progress applicable to approximately 29 exemptions. In 2009 another set of exemptions was proposed in addition to subdividing some of the original exemptions, raising the total number of exemptions to 39. In September of 2010 the EU commission voted and approved the new list of exemptions and revised the exemption expiration dates [2].

This paper will discuss the exemptions that are set to expire by year end 2012 which are used in server and storage systems. It will also provide an outlook and analysis of some exemptions that will be reviewed by the EU Commission in the 2016 timeframe and that may be rescinded or narrowed in scope. The most critical of these exemptions to be reviewed in 2016 are the uses of leaded solders associated with exemptions 7a, 7b, and 15, since viable solutions for many applications are either available now or are expected to be available by that time. In addition, this paper will discuss the necessity for co-development efforts between users and suppliers to phase out terminating exemptions, and will suggest a method to tackle technology transition concerns across the stakeholder, development, and supply chain communities. The paper will also discuss industry initiatives to eliminate other substances not currently on the EU banned substance listings, but which are targeted by environmental non-government organizations.

Key Words: 

RoHS, exemptions, environmental regulations

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