Retronix Blog

Apr 30, 2019

Update to RoHS Dispensation – exemption validity until July 2021

Retronix Op-ed

What is the RoHS Directive?

The RoHS (Restriction of Hazardous Substances) Directive states that – All components and sub-assemblies of EEE placed must contain less than the maximum prescribed levels of lead, cadmium, mercury, hexavalent chromium and two specified flame retardants.

The regulations do not apply to – 
  • Products for military use or designed to be sent into space
  • Products integral to equipment that is out of scope
  • Large scale industrial tools and fixed installations
  • Photovoltaic (solar) panels produced for permanent use at specific locations.
  • Means of transport (apart from certain two-wheeled electric vehicles)
  • Non-road mobile machinery for professional use
  • Products for research and development available on a business-to-business bases
  • Active implantable medical devices

Source – Gov.UK

What impact did this have on different sectors?

  • Component Distributors were left with excess stock of ‘Leaded’ products, which were required to be converted to ‘Lead Free’ to comply with the directive​
  • Companies in High Reliability Sectors including Defence, Aerospace, Automotive who qualified for exemption could only source ‘Lead Free’ stock from their distributors. This stock had to be converted to ‘Leaded’ for their applications.​
  • In 2017 heavy industrial/automation companies such as ABB, Siemens, Thermo Fisher etc. – dispensation of the RoHS directive came to an end, so they had to convert all of their ‘Lead Stock’ to ‘Lead Free’​

A recent update to the RoHS Dispensation states –

“The applications concerned in categories 1 to 7 and 10 – if no reliable alternatives are available on the market or are unlikely to be available on the market in the near future, a renewal of the exemption with a validity period until 21 July 2021 is justified.”

RoHS Dispensation
Click to access the full document

Exemption for “Lead in high melting temperature type solders (i.e. lead-based alloys containing 85% by weight or more lead)”

Summary – ​

The exemption was already listed in the Annex of directive 2002/95/EC (RoHS 1) as Ex. 7 with the exact same wording when RoHS 1 entered into force in 2003. The exemption was reviewed once in the past in 2008/2009.2 1 Contract is implemented through Framework Contract No. ENV.C.2/FRA/2011/0020 led by Eunomia Exemption evaluation under Directive 2011/65/EU 2 ​

The reviewers stated that “Exemption 7a, contrary to other exemptions in the annex of the RoHS Directive, is not application, technology or use specific, but material specific. It generally allows the use of high melting point solders with 85% of lead (HMP solders) and more in electrical and electronic equipment wherever manufacturers want to use it.

Source – Click Here

What does this mean?

Retronix reball components with high melting point spheres to BGA’s and QFN’s/LGA’s for customers that qualify for exemptions.

“With the renewal of the RoHS dispensation this allows other companies that would previously have avoided using HMP due to Pb content to also take advantage of this exemption.”

As long as companies can prove that there is no viable alternative to using HMP solder, then they will qualify for the exemption; meaning they can utilise Retronix services like lead tinning and ball attach.

The addition of HMP solder balls to BTC (Bottom Terminated Components) is advantageous in systems that may be at risk of CTE (Co-efficient of Thermal Expansion). This is a problem with components operating in harsh environments and Retronix has carried out several case studies with customers showing ball addition can improve cycles to fail rates significantly. (Click here)

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