WEEE AND ROHS DIRECTIVES TO ACCELERATE OBSOLESCENCE PROBLEMS
25 October 2004 - Component Obsolescence Group (COG)

Lead, which is used in soldering on the vast majority of electronic circuit boards, is due to be banned in July 2006 under the Restriction of the Use of Certain Hazardous substances in Electrical and Electronic Equipment (RoHS) Directive.

Comments Michael Trenchard, Chief Executive of COG: 'The increasing pace of technological change is already causing component obsolescence problems for an increasing number of industry sectors which rely on equipment lasting for 10, 20 or even up to 40 years. This could be anything from an expensive medical device, to a train, an aircraft or equipment in a power plant. The ban on lead is going to step this up a gear. Looking at the bigger picture, as the problem gets worse, public scrutiny of how our national infrastructure is maintained could become much more intense.'

According to COG, although similar components could be made without using lead, there could be several significant problems. Firstly, the performance may not be identical, and so in some sectors where reliability and safety are paramount, it will not be possible simply to substitute parts. Their performance will need to be verified by retesting, and if necessary, requalifying, the entire piece of equipment.
This could have significant cost implications.

Secondly, equivalent parts could be very difficult to trace and source. As there is currently no industry standard on how components should be labelled, manufacturers may or may not change part numbers or markings when they change their products. Adding to the potential confusion, not all components will change to lead-free, because there will be exemptions for some equipment used - specifically by the military.

Thirdly, even where exemptions apply, finding the same lead-containing part could prove difficult because components containing lead could become completely unavailable as demand drops, or the labelling may have changed.

Fourthly, the market for counterfeit or substandard products is likely to grow as unscrupulous operators in the supply chain try to fill the gap in the market. As, in many cases, the accompanying paperwork can also be falsified, those purchasing such products are often unaware that they are not what they should be until they fail or find that they do not offer the required performance.

Finally, the simultaneous implementation of the Waste from Electrical and Electronic Equipment (WEEE) Directive could also raise obsolescence issues.
This is because, if rules on the separation and collection of waste products are too onerous or costly, the WEEE may act as a disincentive to use certain materials. Adds Trenchard: 'Obsolescence aside, there is still a huge amount of uncertainty in the Electronics industry as to what companies' obligations and liabilities will actually be under RoHS and WEEE. The proposals are currently still quite vague: a situation which is not made any easier by the fact that we are now on the third consultation on the UK rules, which are overseen by three separate Government organisations.'

DEFRA, the DTI and the Environment Agency share responsibility for implementing the RoHS and WEEE Directives. The third consultation, to which COG has made a submission, is due to close on 29 October 2004. 'Organisations that deal with other EU member states have the added concern of whether their rules are going to be the same as ours,' says Trenchard. 'At the moment, it looks as though the only way to find out for sure if companies are compliant is going to be by testing it in law.'

COG and the National Physical Laboratory plan to publish a joint guidance booklet to help companies through the 'lead-free minefield'.

http://www.cog.org.uk

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  • For October 2004
  • From Component Obsolescence Group (COG)
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