For the safety of consumers during the service life and after disposal, material restrictions relating to electronics manufacturing help prevent the excessive buildup of environmental contaminants. While a necessary regulation, this legislation complicates an already intricate and challenging manufacturing process. Maintaining this compliance is important to prevent downstream issues like revisions or costly recalls, so designers will want to be certain their manufacturer can cross their “t”s and dot their “i”s. Collaborating with a manufacturer early in the design process will promote a smooth, straightforward production while observing REACH and RoHS guidelines.
REACH and RoHS – Untangling the Acronyms
REACH and RoHS regulations have the same impact on electronics manufacturing: increased restrictions on chemicals that pose an environmental hazard. While RoHS is geared towards the electronics industry and is mainly known for the ban on leaded solders, REACH is much broader (while still encompassing electronic devices). Depending on the product, the circuit board assembly or electrical system may be only a fraction of the total weight; the enclosure materials can just as easily prevent a device from adhering to safety standards.
RoHS coverage applies to electronics that fall outside of high-reliability requirements, most often associated with medical and aerospace equipment, due to the immediacy of danger in the event of reliability issues. RoHS application also has voltage limits of 1000V and 1500V for AC and DC, respectively. As mentioned, it has a narrow focus spanning six substances with a 1000 ppm limit: lead, mercury, cadmium (ppm < 100), hexavalent chromium, polybrominated biphenyls, and polybrominated biphenyl ethers. Lead has the most defining impact due to its historical use in the eutectic tin-lead alloy, which has remarkable ease of use and forms high-reliability solder joints. Leadless solder alloys have made significant strides to replicate the eutectic tin-lead standard, but gaps (like melting temperatures) remain.
RoHS regulation ensures the limit on materials occurs at the homogeneous material level, i.e., a uniform composition. Homogeneous materials aren’t mechanically separable through unscrewing, cutting, crushing, or grinding. Consider a semiconductor package: it contains multiple homogeneous materials in the substrate, solder, wire bond, and the package of any passive contents. RoHS does carve out certain application-based exceptions due to the inherent safety or reliability concerns arising from unoptimized material selection for performance. For example, high-lead concentration solder in high-current/high-power inductive components and fabrication technologies like flip chip avoid standard RoHS limits.
Covered under RoHS? |
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| Yes | No |
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Organizational Needs for REACH Compliance
REACH scope exceeds RoHS by several magnitudes (note that at the time, it was the longest and most complex EU legislation at over 800 pages long). Despite a much more comprehensive materials list, there are no exceptions; unconditional product compliance occurs if substance thresholds are below acceptable ppm or the manufacturer conditionally accepts further responsibilities. In the latter scenario, the manufacturer must furnish substance information for every article (a term covering all electronic products and parts) to recipients and provide material information promptly upon customer request without cost.
Tracking material information for all the materials and articles used in manufacturing is tedious and time-consuming. Ideally, the mass percentage of all constituent materials and articles should add up to the total mass percentage of the final product. This method gives manufacturers peace of mind that they meet all compliance requirements outright or can easily provide the requisite information to recipients and customers (as needed). However, obtaining this information from OEMs and vendors can take time, depending on their internal record maintenance. Common approaches vary in terms of effectiveness:
REACH Compliance Strategies |
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| Strategy | Pros | Cons |
| Supplier certificate | Manufacturers pass on compliance certificates from suppliers without additional research, optimizing workflows. | Does not provide info on exemptions.
Updates to REACH substances require continuous updates/requests from suppliers. |
| General material declarations | Provides a baseline of substance content that is easier to obtain than a full disclosure. | Lack of complete disclosure means REACH declarations may be incomplete. |
| Full disclosure | Comprehensive tracking and evaluation of article substances which is easy to compare against any updates to REACH list. | Extremely time and labor-intensive, some suppliers may be unable or unwilling to supply the necessary info. |
Manufacturers will naturally devise their best solution to reaching REACH compliance. Still, it may help to ask potential manufacturers some questions to gauge their present and future ability to abide by REACH requirements:
- Ensure designer and manufacturer goals align – While compliance is the responsibility of all industry members, some are more committed to maintaining this responsibility. REACH is somewhat open-ended in execution, which can lead to cost differences; it’s worth considering the value of a production that ensures adherence from the get-go instead of relying on post hoc solutions that become prohibitively expensive.
- Don’t shy away from expert help – Navigating REACH is a complex task, and whether that’s industry tools or personnel, an authority on the subject is invaluable. Sorting through material declaration sheets and associated databases is a full-time position due to the sheer breadth of the regulation.
- Stay ahead of compliance – Building a robust supplier information database involves consistent communication and information upkeep. Proactive manufacturers ensure updates continue regularly and continuously to prevent gaps in declarations that endanger compliance and require additional time to rectify.
Your Contract Manufacturer Extends The Reach of Your Designs
While REACH and RoHS requirements can be daunting, an experienced manufacturer can simplify and streamline this process, especially for NPI designers who haven’t yet become acquainted with PCBA production. Engaging the manufacturer early in the design process ensures that production does not require continuous “back-and-forth.” The design rules and materials comply from the get-go, so there are no late surprises. Here at VSE, we’re a team of engineers committed to building electronics, and that extends to staying on top of regulation to ease our customers’ burden every step of the way.
