RoHS: Compliant or merely capable

As the clock ticks, reputable electronics companies are
doing all they can to ensure their products, processes
and business activity are ready for 1 July 2006, when
RoHS legislation transforms lead-free in Europe from
a marketing message to legal obligation. Naturally, the UKs EMS companies, with their broad manufacturing portfolios and thousands of components and products to approve, are doing as much as anybody to prepare.

However, are they really RoHS compliant? For Jalteks director of technology, Leon Dixon, the answer, unfortunately, is probably not.
Dixons affirmation comes not from competitive jostling but from hard, systematic work over many months, during which time he and his team have painstakingly examined every aspect of their supply chain, processes and activities to discover that achieving RoHS compliance is no easy task. Also, its not the same as being RoHS capable.

Dixon explained: RoHS capability, is the theory. Its knowing what materials and components can be sourced and how they need to be treated in production. That in itself is time consuming, and is not helped by the fact that not all components with a lead-free label are, in fact, lead-free.

The real differentiator, though, is compliance. That means taking all the theory and talk and putting it into practice. Compliance means having a history in lead-free manufacture and clear resourcing, financing, scheduling, evaluation, testing and legal statements in place.

Compliancy: myth or reality?

At the beginning of 2005, Jalteks management team made a strategic business decision to become a lead-free vendor of complex electronic assemblies. According to Dixon, at that time, apart from Japan, where lead-free has been a standard since 1999, and a few continental European EMS providers who had been manufacturing some lead-free products for a couple of years, RoHS compliancy was probably more myth than reality.

Dixon said: By the beginning of 2005, wed done all the theorising and had a capability. Wed also run some lead-free trials. However, we werent compliant because that requires lead-free manufacturing experience, data, history and metrics. Customers had, perhaps, not appreciated the timelines involved or felt the urgency for RoHS compliant products.

Jaltek had an added problem: the complexity of its products. Dixon elaborated: We serve demanding niche markets with complex boards. Few of our products have less than 12-layers and some go up to 36-layers. Even though there is know-how in Japan regarding lead-free manufacture, this typically describes processes for simpler four to eight-layer boards. These do not translate over to the complex boards we manufacture, so we couldnt piggy-back anybody elses work. We had to create our own path forward.
That meant designing a compliancy project plan and finding a client who was ready to invest in the move to RoHS compliance.

ARM and RoHS

The most receptive of Jalteks customers was UK semiconductor IP supplier, ARM, a key client for Jaltek since 2000. ARM licenses its IP to a network of partners that use ARMs processor designs to create their own processors, peripherals and SoC solutions. To support its processors and IP, ARM offers its partners a range of development tools to assist them in integrating the ARM architecture into their own applications: this is where Jaltek comes in.

Dixon explained: Although ARM is known as an IP company, a proportion of its turnover comes from the sale of system boards which are used by ARMs partners, OEMs and system companies, as development platforms for their own products. We manufacture some prototypes and development platforms for ARM.

ARMs need for lead-free came thanks to its activities in mobile communications (its biggest market) and the demands of its biggest geographical market, Asia, where consumers typically change their mobile telephones every four to five-months. The decision was taken in February 2005. This gave Jaltek little time, as it involved transitioning over 20 products to compliancy.

Five steps to compliancy

Jalteks compliancy for ARM, which started in earnest in May 2005, consists of five phases: analysis of target product design; PCB redesign; prototype PCB assemblies; analysis; and compliancy statements.

1) Analysis of target product design:
completion July 2005

Jaltek examined ARMs 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 Dixons conviction that RoHS compliancy is more fiction than fact.

Dixon said: Forget the chat, with the level of non-compliancy in the suppliers we talked to, and we talked to a lot of them, its incredibly difficult for electronics manufacture to be compliant.
In many cases, Jaltek remained unconvinced that sourced materials were as compliant as their suppliers declared. Dixons team found an astounding 46 per cent of part numbers that had not changed although suppliers declared that the parts themselves had been changed for RoHS compliancy.

Dixon explained: For us, that message is ambiguous. Its possible that the items in question have indeed been changed, but we cant 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) PCB redesign:
completion December 2005

The boards that are to go forward are re-engineered for lead-free components and parts.

Dixon said: Where clients do not have the resources to do this in-house, Jaltek takes this on through its 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: ongoing

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

Boards are analysed for joint integrity and RoHS compliancy, encompassing metallurgy and other detailed analysis to check whether components really are lead-free as claimed.

5) Compliancy statements:
completion April 2006

All phase 1 statements and analysis results are pulled together and the legal compliancy statements are prepared.
At the end of each of the first four stages there is a reality-check based on Jalteks findings and recommendations for each product.

The cost of compliance and non-compliance

It is clear that nothing can be taken for granted. Compliancy takes time, difficult decisions are necessary and the whole process is expensive.

Dixon is thankful that Jalteks 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. For Jaltek, there were no significant capital expenditures necessary to move to lead-free. At the beginning of 2005 we already had the equipment we needed to go forward. Independent 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 EMS companies in the UK are following Jalteks example, preferring to base decisions on product data sheets.

b>Does that matter?

For Dixon, it most certainly does. He said: 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. Dont forget there is a lot of anti-competitive behaviour in the market with 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.

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.