We’re only 15 months away from the RoHS lead-free deadline. Do you know where your compliance certification is?

As electronics manufacturers, contract manufacturers and component suppliers move through the conversion to parts that are free of hazardous materials, it’s beginning to dawn on industry executives that the shift to lead-free products carries with it the need to certify the cleanliness of their products. They will need to provide documentation to governments that have passed laws restricting hazardous material content in electronic products.

The Restriction of Hazardous Materials (RoHS), passed by the European Union (EU) in 2002, bans the sale of products containing lead and other hazardous materials. RoHS goes into effect on July 1, 2006, but in order to make that deadline, the electronics industry is moving now to products that doesn’t contain hazardous materials. RoHS regulations apply to all electronic products except those produced by the military and portions of the telecommunications industry.

In addition to revamping their bill of materials to call for lead-free components, manufacturers – and they EMS providers – will have to go to their suppliers and get them to sign off that the components they are using are truly RoHS compliant. Companies need to be ready to provide any number of European governments with compliance documentation. And the fun part is that most of the European Union governments have not yet passed laws outlining the compliance documentation they’ll need from manufacturers.

“There’s a gap – the EU countries have not defined how they expect producers to comply,” Richard Kubin, chair of the business leadership team at the International Electronics Manufacturing Initiative (iNEMI), said. Kubin noted that the United Kingdom has come closer than any country to defining how manufacturers will be expected to certify their products are RoHS compliant.

“The U.K. has put forward the more complete documentations, but even that’s pretty vague,” said Kubin. “Given the fact that they have not released formal documentation, [the U.K. government] will initially assume that companies are complying by the fact that they are selling product in Europe.”

But Kubin expects individual European countries will at some point outline RoHS certification procedures for manufacturers. He expects that most EU countries will likely adopt the U.K.’s documentation requirements, since the U.K. is ahead of the game on developing those requirements. In the meantime, Kubin recommends that manufacturers begin requesting material declaration documents from their suppliers.

One area that remains very muddy is just what form that material certification needs to take. Manufacturers deal with hundreds of suppliers, so the lack of standardization for certification documentation has already become a problem. Suppliers are getting requests for different formats from their OEM and EMS customers. According to Kubin, iNEMI is working on a data standard that manufacturers can provide to their suppliers. He expects the standard to be release this May.

The issue is poised to create a small IT industry of its own. Kubin expects that large manufacturers will have to spend $1 million or $2 million setting up their compliance system. Some of the larger OEMs such as Sony and Nokia are working with RosettaNet PIPs to exchange compliance information with suppliers and interested government agencies. Yet companies that are capable of exchanging data via RosettaNet PIPs constitute less than 5 percent of the electronics industry.

A number of vendors have stepped up to help manufacturers, suppliers and EMS providers manage their compliance data. Kubin, who is VP of product lifecycle management at software provider E2open, noted that his company has developed software and services to support companies with compliance issues. “We launched a product in January that fits this category,” he said.

The Goodbye Chain Group in Concord, Mass., is distributing a product called RoHS-WEEE.net which provides clients with strict processes and controls to create a certifiable audit trail for RoHS compliance documentation.

“We’ve created a material declaration wizard to collect, save and report material composition,” Mark Myles, the group’s services director, said. “It’s a comprehensive management solution for RoHS.”

Myles believes that as well as facing the challenge of collecting and managing RoHS compliance data, OEMs will also face the prospect of delivering the data to various governments in a variety of formats.

The challenge of managing compliance data is a heady one from OEMs. “This data has to be collected at the bill of materials level,” Myles added. He noted that an OEM may have 4,200 vendors involved in a product. And if one of those vendors has a component that is out of RoHS compliance, then the entire product is out of compliance even if the other 4,199 components are RoHS compliant.

I2 Technologies of Dallas has also developed a solution for compliance documentation. The company has partnered with Underwriters Laboratories (UL) to create a certification service that allows i2 customers to access a library of component parts that are periodically verified by UL’s testing network. The database is designed to show the substances in specific components as well as offering substitute components with a lower risk profile.

By: DocMemory
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