One month to go: are we ready? Key questions about true costs, reliability and enforcement remain unanswered as the July deadline approaches.

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The RoHS Directive goes into effect in the EU next month, and the big question is, Are we ready? Since January 2003, when the directive was passed, the industry has worked feverishly to prepare for its requirements, with a particular focus on the transition to Pb-free processing (undoubtedly the most challenging aspect of the legislation). Industry is for the most part ready but much work remains for the next few years to reduce the ongoing costs of maintaining RoHS compliance, address additional legislation and changing regulations around the world, and complete and optimize the conversion from eutectic solder.

Holly Evans, president of Strategic Counsel LLC ([e-mail]), a consultant to electronics manufacturing companies on RoHS and WEEE environmental compliance issues, says that larger companies seem to be well-prepared to comply with RoHS but many small and mid-sized companies are lagging.

This viewpoint is borne out by recent research. A December 2005 survey (1) of 162 OEMs and EMS providers found disparity in preparedness between large and small companies (Table 1). The poll found that 80% of responding companies with sales exceeding $1 billion expect to comply with RoHS by July 1. However, only 47% of companies with sales under $100 million expect to be ready. Among mid-tier companies (sales between $100 million and $1 billion), 55% said they expect to be in compliance by the deadline.

A benchmarking study by Technology Forecasters Inc.'s TFI Environment on behalf of one of its members provides more in-depth discussion of RoHS compliance issues. This study, conducted in January and February, included interviews with 11 telecommunications OEMs and five of their suppliers (EMS providers, component suppliers and solutions vendors). All but two of the OEMs interviewed plan to take the Pb-free exemptions for networking/telecommunications products and four plan to take the spare parts exemption.

The decision to take the permitted Pb exemption--by the companies surveyed and others that manufacture high-reliability products--is leading to a dual technology and supply chain structure, which poses additional challenges. The U.S. military has recently recognized that, in spite of being exempt from RoHS, they are impacted because of the difficulty in purchasing Pb-bearing components.

Reducing costs of RoHS compliance. Nearly all companies surveyed in the TFI study plan to perform due diligence in declaring their products compliant and intend to take the same compliance approach for China RoHS. Most of the OEMs surveyed are using third-party software to track and report materials contents, while a few have developed and implemented proprietary tools. The recently released IPC-1752, Materials Declaration Management, establishes uniform electronic data formats and standardized forms to simplify collection, tracking and disclosure of material content information.

"The entire electronics supply chain is concerned about being able to establish the information necessary to demonstrate compliance," says Richard Kubin, vice president of E2open Inc., and chair of the IPC and iNEMI committees that developed the standard. "IPC-1752 allows companies to utilize a consistent format both for collection of data as well as its distribution. The associated XML schema and standard forms allow for the automation and direct integration of this information into key internal systems, greatly reducing the manual effort required in managing compliance."

This initial standard is but the first step in working to reduce the financial impact of RoHS on the industry.

Addressing regulations and legislation. The past 18 months were extremely active from a legislative viewpoint in the EU. All 25 member states have now implemented RoHS through national legislation, and several member states (e.g., the U.K., the Netherlands, Poland and Germany) have detailed regulations and guidance in place.

Maximum concentration values for the substances controlled by RoHS were established in August 2005 (up to 0.1% by weight in homogeneous materials for Pb, mercury, hexavalent chromium, PBB and PBDE and up to 0.01% by weight in homogenous materials for cadmium).

Bob Pfahl is vice president of operations for the International Electronics Manufacturing Initiative (inemi.org); [e-mail].

Kurt Goldsmith is general manager, systems manufacturing technology development, for Intel Corp. (intel.com) and a member of the iNEMI Technical Committee; [e-mail].

Table 1. Ready, or Not?

Co. Sales                 % Compliance by July 17

  >$1 billion             80%
 $100 million-$1 billion  55%
<$100 million             47%

Source: ES & M and Design Chain Associates, December 2005