European Union Rohs Leaded Solder Exemption Update

ABSTRACT The European Union’s (EU) Restriction of Hazardous Substances Directive 2002/95/EC (RoHS or Directive) [1] took effect on July 1, 2006 restricting the use of six hazardous substances in the manufacturing of electrical and electronic equipment placed on the market in the EU. When the Directive was first announced, there were permitted exemptions to allow the use of these otherwise restricted substances for certain product applications or functions. Exemptions were valid until suitable replacement materials became available, as reviewed on a four year cycle. The recast of RoHS, EU Directive 2011/65/EU, (RoHS Recast or Recast) [2], which took effect on July 21, 2011, changed this procedure by designating a maximum validity period of five years for exemptions that had no set expiration date at that time. As the five-year exemption expiration date of July 21, 2016, approaches, the industry has transitioned away from those exemptions that no longer have technical justification and submitted documentation to support the extension of those exemptions that do not yet have suitable replacement materials. This paper will focus on three lead solder exemptions: 7a, lead in high melting temperature solder; 7b, lead in solder for servers; and 15, lead in solder for flip chips. These three exemptions span the range of anticipated outcomes from: full expiration (7b), division where some sub-categories expire and others are extended (15), and division where all sub-categories are extended (7a). This paper will discuss the strategy to transition hardware for Exemption 7b, including new systems, legacy systems and upgrades. The technical justifications to sub-divide and extend exemptions 7a and 15, as well as the strategy to determine proper supplier assessment of these exemptions, will also be discussed. Where sub-categories of Exemption 15 are expected to expire, the recommended due diligence for approving replacement materials will be included. In addition, an improved business process for managing the end-to-end exemption transition process will be presented.