Executive comment: RoHS compliance and industry standardization

With the deadlines approaching for implementation of the European Community's directive on the Restriction of Hazardous Substances (RoHS) in less than 18 months, manufacturers are grappling with the details of complying with this complex change that is projected to cost in the billions of dollars.

Effective July 1, 2006, the six substances banned by the EU's RoHS regulations, along with similar legislation in the U.S. and other regions, will affect the way that semiconductor suppliers and their customers do business. Today, most of the technical hurdles of developing products free from lead and other restricted substances have been solved, but many issues remain regarding tracking and reporting compliance.

The following discussion of RoHS compliance reporting from a semiconductor supplier perspective provides an overview of the issues involved in compliance reporting.

Toshiba, for one, is urging industry-wide involvement with standards organizations to adopt standard definitions, testing methodology and reporting formats to help streamline the process of RoHS compliance, thus minimizing associated costs and reporting time for all involved.

Among the challenges for RoHS compliance reporting are the following:

*Different interpretations of the RoHS directive.
*No standard survey format.
*No standard reporting format.
*Lack of standardization in material declaration forms.
*High costs associated with supporting different reporting formats for nearly every customer.

As a result of different customer interpretations of RoHS compliance, Toshiba, for example, is not able to provide a broad RoHS compliance statement for all semiconductors to our customers. Instead, we check for RoHS compliance on an individual part number basis, in response to customer requests.

The scope of this challenge is becoming more significant as the number of requests escalate. Worldwide requests related to lead-free and RoHS-compliant devices have increased from 570 per month in November 2003 to 2,150 per month in November 2004.

Many companies have developed different reporting formats that vary widely in their levels of detail. As a result, the reporting requirements to document RoHS compliance vary greatly from customer to customer, and from region to region. Furthermore, some formats include queries about additional chemicals that may be banned in the future. As a result, most inquiries must be handled on a custom or semi-custom basis.

On one hand, a simple declaration form typically asks for materials used, material weight and percentage of the content for major parts of the component, including mold resin, die, leadframe, and bondwire. At the opposite end of the spectrum, other customers have asked for more detail for all materials used in the components. This includes material designation, Chemical Abstracts Service (CAS) number, specific gravity, manufacturer of the material, material weight, and percentage of the content — as well as a list of all substances used in each material, with CAS number, weight and whether the substance was intentionally added.

Many consulting firms are also offering their own solution to companies that are not active or aware of the RoHS/WEEE Directive. As a result, additional formats and chemical lists have been developed, further complicating the reporting requirements for suppliers.

Toshiba was one of the first to develop RoHS-compliant products with an ongoing transition to lead-free manufacturing that began in 2002, and other ongoing initiatives to reduce or eliminate other banned substances. The company has taken an active role in IPC/JEDEC conferences on lead-free manufacturing, and has been an early advocate of industry standardization in testing methodology and reporting.

To help address the issues related to RoHS compliance, we encourage open communication among all industry participants (OEM, ODM, EMS, distributors, suppliers and compliance consultants) and participation in standards organizations and the Technical Action Committee of the European Union's RoHS Directive (TAC/EU). We also urge companies to make inquiries more efficient by focusing only on legally banned and restricted substances.

An encouraging step at the present time is a standardized materials declaration and data model under development by a joint NEMI and IPC/JEDEC working group. We encourage industry participants to promptly review and comment on proposed standards, such as this, to assist in the rapid adoption of a standard methodology in order to help smooth the transition for all.