The Electronics Source Book
January 26, 2005

Are the military and telecommunications industries off the hook on RoHS?

Do you know if your products are exempt from Europe’s lead-free restrictions? Military components are supposedly exempt from the new lead-free laws…but not all military products are exempt. Telecommunications products have an additional four years to transition over to lead-free products. 2010 is the official date, but that day may come early if leading suppliers begin shipping lead-free components before 2010.

The lead-free laws – The Restriction of Hazardous Materials (RoHS) – coming down from the European Union are already causing confusion in the electronic components industry even though the deadline for compliance is more than a year away. Problem is, the products being designed now will include components that may or may not be RoHS compliant on July 1, 2006, the deadline set by the European Union.

And the European Union isn’t the only government body producing restrictions on hazardous materials. Both California and Maine have enacted laws that require goods sold in those states to comply with RoHS, and similar legislation has been proposed in Massachusetts, Vermont, Hawaii and Connecticut. South Korea’s electronic companies have adopted a voluntary program to comply with RoHS, and Japan has had voluntary green initiatives in place for many years. Finally, China has passed legislation similar to RoHS even though its component suppliers are significantly behind in developing lead-free alternatives.

One of the biggest sources of confusion comes from RoHS exemptions. RoHS and its accompanying WEEE legislation do not cover components and products considered exclusively for military use. The WEEE (Waste from Electrical and Electronic Equipment) rules apply to how a product containing hazardous materials will be processed or recycled at the end of its life. The problem with the military exemption is that equipment connected with national security or military purposes is not exempt from the RoHS directive if the equipment has non-military uses as well.

The UK government produced this statement to help companies determine which military products are exempt and which have to comply with RoHS: “The exemption covers products designed and marketed specifically for national security and military purposes... but not products in the eight categories which can be used in connection with either military or civilian applications.”

This interpretation runs contrary to the view of many in the military who want to continue using leaded parts out of a concern about the reliability of lead-free parts. Their interest in using leaded parts is independent of whether those parts may also have civilian applications.

In the telecommunications industry, the following parts and products are exempted

• Lead in [the] glass of cathode ray tubes, electronic components, and fluorescent lights.
• Lead in high melting temperature type solders (i.e. tin-lead solder containing more than 85% lead).
• Lead in solders for servers, storage, and storage array systems (exemption until 2010).
• Lead in solders for network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunication.
• Lead in electronic ceramic parts (e.g. piezoelectronic devices).
• The restrictions do not apply to batteries.
• Cadmium plating is exempt except for applications banned in other EC Directives, 91/338/EEC and 76/769/EEC.

Yet even these exemptions are not set in stone. Once a significant supplier begins producing a reliable lead-free version on these parts, the exemption may lift before the 2010 extended deadline that has been given to portions of the telecommunications industry.

Another potential concern is the pricing of exempt parts. Many leaded parts have been produced in high volume, which ensures low prices. As suppliers shift to lead-free versions, the exempt parts will be produced in smaller quantities. Many suppliers have indicated that they don’t expect the production of smaller quantities to prompt price increases, but it certainly wouldn’t be surprising if suppliers edge prices upward when they lose the efficiencies that come with volume production.

Most distribution executives expect 2005 will be a year of market confusion over the conversion to lead-free components. However, they believe the confusion will be transitional, and most expect the unknowns associated with the conversion to sort themselves out by the end of 2005. But until then, you can expect ongoing confusion about what’s exempt, what’s not exempt and what products are (or are not) ready for the lead-free prime time.

This is Part VI in a series of articles.

Part I: Industry braces for the lead-free conversion

Part II: Progress on lead-free components spotty

Part III: IDT: 99 percent lead free already

Part IV: Actel goes green on 100% of its FPGA products

Part V: Lead-free parts: Welcome to the messy supply chain

Part VI: Are the military and telecommunications industries off the hook on RoHS?

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