Until recently, the industry was sharply focused on producing the latest and greatest products - meeting consumer demand for the newest models of cellphones, PDAs, DVD players and a host of other electronics products. In this business, getting to market with a cutting-edge technology is not just good for business; it is necessary for survival.
As a consumer, a technology executive and a home-electronics enthusiast, I have seen my share of "here today, gone tomorrow" technologies. Until recently, however, neither consumers like myself nor the makers of electronics products were acutely conscious of the environmental impact that electronic devices can have when they reach end-of-life and are sent to landfills. Times are changing - along with our collective attitudes toward environmental responsibility.
The European Union's RoHS and WEEE directives are a clear indication of this shift in awareness. Like any significant industry change, however, these laws, along with other global initiatives, will take some time to gain traction.
RoHS, which bans six toxic substances from electronics equipment shipped into the EU after July 1, 2006, has received a great deal of industry attention. This is primarily because of the complex technical challenges driven by the removal of lead. To overcome these obstacles and mitigate business risk, most electronics companies have spent the past few years preparing their organizations for this transition. And while most are anxious to return to "business as usual" after the deadline for compliance, in reality, the impact of this legislation and rapid emergence of other environmental directives means that the industry's migration toward a green future will require a more long-term commitment.
The key areas of industry focus as we move past the July 1st deadline include:
The industry has relied on lead in solder for half a century. An abundant supply of field data is available, as are a variety of models by which to derive acceleration factors and extrapolate test results to service conditions. With lead-free solder, however, we have only five years of experience and limited field reliability data. There is no proven life prediction model in the public domain and we cannot reliably extrapolate current test cycle-to-fail data.
Although consortia, educational institutions and individual companies have taken great strides to prepare the industry for RoHS, it would be unrealistic to expect an immediate and seamless transition to life without lead. In fact, the first real wave of technical issues are now beginning to show up as we move past the July 1st deadline. These challenges will be more prevalent for companies that:
The latter group will be hardest hit as they attempt costly and time-consuming "band-aid" fixes under a very compressed schedule.
Companies that manufacture high-reliability products such as network infrastructure and high-end computing equipment are able to leverage an exemption from lead in solder. It is important to note, however, that the EU plans to revisit the exemption at a minimum of every four years. When these exemptions are deemed no longer necessary, the EU will set a target date for compliance and the next flurry of industry activity will surround the transition of more mission-critical, complex product sets.
Said companies will need to quickly overcome assembly challenges, carefully manage the phase-in and phase-out of inventory, and ensure that they are able to source an adequate supply of lead-free parts. To ensure a successful future transition, these organizations should start planning now.
In the meantime, companies planning to leverage the exemption for lead in solder, or whose products fall outside of the scope of RoHS (such as defense and medical electronics), may find it increasingly difficult to procure leaded and other noncompliant components. The resulting challenges will be threefold:
Studies have indicated that the latter scenario may actually pose more reliability issues than dealing head-on with RoHS compliance.
Technical and sourcing challenges may inadvertently act as a catalyst for exempt and out-of-scope companies, driving them to move their compliance schedules forward or reconsider transitioning to compliance. Fortunately, organizations that reconsider their approach will have a greater pool of reliability and field data to leverage. They may also reap the benefits of being first in their peer group to introduce a compliant product.
Now that RoHS has been enacted, EU member states enforce the law. They will no doubt make examples of the first companies to be caught with banned substances in their products. This may result in negative press coverage and even damage to brand image. Such actions may have the potential to drive instances of competitive analysis, where companies analyze competitors' products to determine if they are fully adhering to the regulations. According to a recent report from the U.S. Commercial Services, a division of the U.S. Department of Commerce, Germany's National WEEE Registrar has been inundated with reports from companies "blowing the whistle on competitors" that have not registered. This type of behavior is expected to be commonplace from now on. Indeed, in some instances, environmental groups may be positioning themselves to become unofficial watchdogs.
European companies in the high-reliability space that opted for full compliance instead of exemption may also add some fuel to the fire. Having spent the resources necessary to make the full transition, they will not look kindly upon noncompliant product being shipped into the EU and may lobby the government to restrict the flow of products into their region.
The EU's RoHS is not the only environmental legislation to impact the future of the electronics industry. Other regulations are quickly gaining momentum in Europe, China, Korea and some U.S. states. This is worth noting for companies that did not worry about RoHS because they do not place products on the European market.
The most pressing of these legislative initiatives is quickly ramping in China. Similar, yet not identical, to the EU's RoHS legislation, the Ministry of Information Industry's (MII) Cleaner Production Promotion Law, often referred to as "Chinese RoHS," is scheduled to take effect March 1, 2007. The Cleaner Production Promotion Law not only sets out to ban six hazardous substances from electronic products, it also includes requirements outlined in the EU's WEEE and EuP (Energy Using Products) legislation surrounding take-back and energy efficiency. Considering the more encompassing nature of Chinese RoHS and the fact that no product exemptions have yet been mentioned, this law is likely to generate even more industry anxiety than its EU counterpart.
Meanwhile, in the EU, the WEEE directive will begin having a deeper impact on producer-polluters as member states begin enforcing take-back regulations. EU member states require that producers take back, free of charge, any product that was placed on the EU market after Aug. 12, 2005. The first collection targets are scheduled to be attained by December 2006.
To date, only the U.K. and Malta have not transposed the WEEE Directive into law. In Ireland, signs are already posted in retail stores detailing product costs and the associated charges for recycling. This country also recently saw the first European fine for nonconformance with WEEE. These initiatives will soon become widespread across Europe and OEMs must have comprehensive plans or partnerships in place to comply with take-back regulations.
Until recently it was believed that only the producer would be financially responsible for "take-back" activities. However, in most cases the end-user will bear the brunt of these costs either through increased prices or agreements with the producers at the time of purchase. In business-to-business transactions, it is believed that when a business plans on replacing electronic or electrical equipment, it will negotiate a deal with the producer to consider the costs of recycling.
Various estimates exist for the quantity of WEEE waste generated annually. For example:
Another key piece of environmental legislation is the European Union's EuP Directive. Due to be enacted in 2007, this law will require the producers of electronic products to manufacture more energy efficient products and mitigate negative environmental impact throughout the entire product lifecycle. Through EuP, products must be designed, manufactured and operated with a focus on reduced energy consumption and ease of end-of-life management. This law will put a higher level of emphasis on electronics components and low-power circuit design.
Also on the horizon is REACH - the EU's regulatory framework for the registration, evaluation and authorization of chemicals - scheduled to come into law in 2007. The overall impact to the electronics industry has yet to be determined.
These and other global environmental initiatives, along with increasing demand for "green" products, is currently laying the groundwork for a massive shift in industry thinking. In the future, the environmental impact of the entire product lifecycle will be considered - from design for ease of disassembly and energy efficiency to numerous alternatives to landfills such as redesign, refurbishment and recycling. PCD&M
Dan Shea is chief technology officer at Celestica (www.celestica.com).