EUROPEAN UNION RoHS EXEMPTION REVIEW CASE STUDY

摘要

The European Union’s Directive for the Restriction of thernuse of certain Hazardous Substances (RoHS) has beenrnapplicable to new electrical and electronic equipment put onrnthe EU market from 1 July 2006 [1]. When the Directivernentered into force in February 2003, provisions were madernin the Annex to exempt certain uses of otherwise restrictedrnsubstances in specific cases where the negative effects werernlikely to outweigh the environmental, health and/orrnconsumer safety benefits of the substitution. As required byrnthe Directive, a review must be conducted every four yearsrnto determine whether there is valid scientific data to supportrnthe continuation of each exemption. With the previousrnreview of exemptions conducted in 2004 that included therninitial ten exemptions and the first group of modifications /rnadditions, 2008 brought the first full review of the portfoliornof exemptions after the Directive came into force.rnDuring the exemption review, representatives of individualrncompanies and those affiliated with industry associationsrnpresented the technical progress applicable to approximatelyrn30 exemptions and submitted position statements for reviewrnby a consultant selected by the European Commission. Thisrnpaper will share a case study of activities undertaken torndevelop and submit a position on the exemption allowingrnthe use of lead in solders for servers, storage and storagernarray systems, network infrastructure and similar equipment,rnexemption 7b. It will also provide some brief highlights ofrnthe exemption reviews of the ‘lead used in compliant pinrnconnector systems’ and the ‘lead in solders for flip chiprnpackages’ exemptions, also critical to high reliability serverrnsystems.rnIn addition, the paper will present an exemption transitionrnstrategy that could be applied to the phase out of anyrnexemption. With technical advances in many areas ofrnmaterials development and the goal of the EuropeanrnCommission to reduce the scope and number of exemptions,rnit can be expected that the electronics industry will facernseveral years of change management as RoHS materialsrnallowed today by an exemption are replaced. Developing arntransition roadmap throughout the supply chain andrnmaintaining an accurate materials content database torndocument compliance are an essential but complex taskrngiven the scope of expected modifications. This complexityrnis multiplied by the many other worldwide regulatoryrninitiatives affecting hardware and environmental compliancernmaterial tracking needs.rnLearning from this exemption review should be applied nowrnto assure adequate industry preparations for the next review,rneven while the industry transitions away from severalrnexemptions slated for near-in expiration.