Guessing game in ROHS

ROHS has been a tricky issue for designers for two reasons. First, though most countries in the world have opted for the EU directives, some countries, notably China, have their own directives, thereby creating confusion for designers on how best to implement the directives so that both the categories of markets can be served at minimum cost. Second, designers have been forced to continuously watch their BOM because exemptions to ROHS implementation have been reducing.

New regulations
Three new regulations, numbered 764/2008, 765/2008, and 768/2008, adopted in 2008 but implemented in 2010, and new regulations coming up this year call for extra vigilance on the part of designers. These regulations will withdraw exemptions that have permitted limited use of lead, lead oxide, and lead alloys in some electronic and electrical products. It is still not clear whether substitutes are available for the materials the regulations seek to ban. Oko Institute and Fraunhofer IZM, the technical consultants of European Commission, have said that exemptions could be given only where there are no technical alternatives. I think this is not the best approach. Even if technical alternatives exist, the industry will not be benefitted if these are significantly costlier than the current materials used. EC explains that compulsory ban on the use of materials whose technical alternatives are available will stimulate industry efforts to find economically viable alternatives. I believe that the industry battered by the recession should have been treated more sympathetically. How many companies have the resources to invest heavily in finding such substitute materials? When we have worked with conventional materials for decades, we could have continued with these for some more time till the economy booms again.

From the designer perspective, some equipment are designed for a short life cycle, while others, for a long one. When designing components, designers will need to keep in mind for which category of equipment the component is likely to be used. For instance, the cell phone has a short life cycle. BOM can he changed and managed quickly. But the situation is different for products with a long life cycle, such as those in the automotive, aerospace, and medical segments. Components designed today in conformity with current ROHS directives may become unlawful to sell, even if they are at the leading edge of technology, after one year when ROHS directives become more stringent. This will lead to resource wastage.

Thus, the designer is caught in a cleft stick. It is not easy for him to choose how to design components, when ROHS is in a fluid state. It is not practicable for him to design new components that will continue to be useful when ROHS directives change. Worst of all, he is not sure whether the designed components will be compatible with the ROHS directives of all geographical markets. The designer today is in a guessing game as to how best he can cope up with changing ROHS environment. Some designers are turning to consultants for estimating how safe components will be made from ROHS-related changes. Some are seeking help of distributors to hedge them against BOM by predicting the changes sufficiently in advance.

Legislation
Designers and manufacturers have resigned themselves to the fact that more and more materials will be restricted. They are constantly monitoring the legislation. However, this has not necessarily helped them in successfully implementing the directives. The rejection of Sony’s PlayStation cables by the Dutch government for too much cadmium in 2001 is a case in point, causing a huge loss to Sony. This is not an isolated case. Chinese companies too have faced similar problems. While governments in their over-enthusiasm for preserving environment may go fast in implementing ROHS, they should not lose sight of the fact that the industry is not in a position to bear the kind of losses Sony had to bear in 2001. A more cautious approach is called for.