5.3: Implementing the Directive

Level of Compliance

For their initial efforts at RoHS compliance, technology companies primarily made use of two exemptions mentioned earlier:

• lead in solders for servers, storage and storage array systems (exemption granted until 2010),
• lead in solders for network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunication.

The terms "RoHS-6" and "RoHS-5" came into use with the following meanings:

• RoHS-6 is required (being under the threshold concentrations for all of the six substances), unless an exemption applies
• RoHS-5 involves invoking the Directive's legal exemption for lead in solder, where compliance is being under the threshold concentrations for all of the six substances except for lead.

Applications for exemptions are reviewed by the EU Technical Adaptation Committee that reports to the EU Commission. Requested and granted exemptions are published. The duration of a granted exemption is approximately 4 years. It is also driven by what happens in the market (what is demonstrated to be technically feasible).

The technical literature at the time was filled with analysis of replacements for lead solder and the risks involved. As a result, most initial compliance was at the RoHS-5 level.

Self-declaration

Compliance with the EU RoHS Directive is a “self-declaration” process, meaning that the company putting the product on the market in the EU is responsible for making the declaration of compliance.

Determine Scope

At the time of the RoHS Directive, a tech company likely had many products for sale in the EU. A key activity driven by Product Management and Sales organizations was to determine which of the organization’s products would be certified as RoHS-compliant. This required examination of product sales history, inspecting contracts with customers, reacting to technical feasibility assessments by Engineering, among other things.

Some products might require certifications-only work to demonstrate compliance. Other products might require engineering changes need to be made, necessitating engineering development work and re-validation.

At the end of this analysis work, some products would be non-compliant. The disposition of non-compliant products could be:

• Non-compliant products could still be sold in regions other than the EU
• Non-compliant products are potential candidates for product retirement.

Create a RoHS-compliance Process

To attain RoHS compliance, the following were elements of the process:

• Request and collect certifications from suppliers
• Ensure the validity of certifications, possibly testing composition of some parts via an outside lab, at some expense.
• Collect certifications via the organization's official Engineering change control management process using Engineering Change Orders (ECO) and Manufacturing Change Orders (MCO), attaching proof of certification to parts.
• Monitor the compliance level of product Stock Keeping Units (SKUs) through Bill of Material (BOM) roll-up of compliance information associated will all parts.
• Do not throw the “OK to ship” switch until 100% covered.

Regarding that last item, the RoHS Directive imposes a very high standard to achieve compliance. Essentially every single part in a product must be compliant. Thinking of this as receiving a grade in a course would yield this:

• Grade for being 99.99% compliant or less: F (“Fail”). Often a grade of 99.99% would earn a student an A+, but not so here!
• Grade for being 100.00% compliant: A (actually, more like a “Pass”)

Certifications

The types of evidence of compliance from part suppliers at the time varied greatly. In addition to end-product companies starting late with their compliance efforts, such was often the case with electronic component suppliers. The types of information available included:

• Certificates of Compliance/Conformance
• A binary “yes/no” compliance statement on the supplier's company letterhead, signed by an appropriate company representative.

These may or may not have detailed data on restricted substance concentrations.

As time went on, more formal methods became available such as the following IPC forms:

• IPC-1751 Generic Requirements for Declaration Process Management
• IPC-1752 Materials Declaration Management
• IPC-1752-1 and 1752-2 PDF forms, covering six classes of declaration
• IPC-1752-3 Users Guide for Material Declaration Forms

IPC-1752A is an XML based standardized framework for materials declaration management for exchanging material composition information in the supply chain. It was standardized in 2010 and subsequently amended, including in 2014.[6, 7]

Determine compliance classifications

To get started, an organization needed to define compliance classification tags in the parts database. These might include classifications such as:

• Compliant (perhaps further refined as RoHS-5 or RoHS-6)
• Non-compliant
• Not Applicable or “Waived”
• Unknown or “Missing Information” (used for parts initially before certificates of compliance became available)
• Exempt

Bill of Materials Roll-ups

A major objective was determining whether the product being sold or to be sold was RoHS-compliant or not. To do this, it was necessary to inspect the Bill of Materials (BOM) for the product and look at the compliance status of the constituent parts, being aware of the following:

• Overall Stock Keeping Unit (SKU) status is a roll-up of lower-level child parts
• The status of a parent part is determined by the status of the Manufacturer parts reporting to it
  • Replace non-compliant parts with compliant ones, possibly with a new part number (P/N)
  • If the status of manufacturer parts is mixed (e.g., some are compliant, some are non-compliant), the Approved Manufacturers List (AML) or Approved Vendors List (AVL) needs to be checked
    • Remove non-compliant parts
    • Continue to pursue certifications

AML/AVL Clean-up

As mentioned above, in certain circumstances the Approved Manufacturers List (AML) or Approved Vendors List (AVL) needed to be cleaned up to render the overall BOM to be compliant.

Let's look in detail at the AML/AVL clean-up examples in Figure \(\PageIndex{1}\).

Example 1: In this example, each of the parts from the four suppliers has been determined to be RoHS-5 Compliant, so the part 12345-00 (Screw) rolls up as RoHS-5 Compliant.

Example 2: In this example, the parts from Suppliers 1 and 2 have been determined to be RoHS-5 Compliant. However, information from Suppliers 3 and 4 is still missing. In this case, the action to take is to continue pressuring Suppliers 3 and 4 to provide the certification of compliance for their parts. At some cut-off date or deadline, if Suppliers 3 and 4 fail to provide the certification of compliance for their parts, then their parts must be removed from the AVL for part 12345-00, leaving only Suppliers 1 and 2.

Example 3: In this example, the parts from Suppliers 1 and 2 have been determined to be RoHS-5 Compliant. Information from Supplier 3 is still missing, and as in Example 2, Supplier 3 needs to be pressured to provide the certification of compliance for their part. For Supplier 4, the information received from them designates their part as being "Non-compliant" and therefore Supplier 4 must be removed from the AVL for part 12345-00.

Example 4: In this example, the information received from all four of the suppliers indicates that all of the suppliers have indicated that their parts are Non-Compliant. In this case, a safe strategy is to remove part 12345-00 from the BOM (and the system) and replace it with a new part number (called "pulling a new P/N") say P/N 67890-00 and update engineering design files and BOMs. Then suppliers for part 67890-00 need to be added that supply compliant parts. Parts 12345-00 and 67890-00 are added to the From-To (Non-compliant to Compliant) list. Alternatively, and more risky, is to keep part 12345-00, delete Suppliers 1-4, with appropriate dispositions such as "Purge" to purge inventory of those parts from manufacturing inventory, and then hope to find suppliers with replacement compliant parts.

Compliance Tool requirements

To do the BOM roll-up checks for compliance, it was necessary to create a tool (as one of this textbook's authors did) and to regularly run the tool to assess BOM compliance (as the other author did). Running the tool was done on a weekly basis and the tool was refined as needed to incorporate learnings. This was a labor-intensive process.

On the road to meeting the RoHS Directive, industry-wide parts management databases had little to no support for RoHS compliance. That was why we needed to create our own tool. Our Engineering parts management database tool only provided an add-on module one month before the RoHS Directive compliance deadline, which rendered it operationally not usable for the effort.

Role of Component Engineering

There is a Component Engineering role, housed either in Engineering or in Manufacturing, that performed these important responsibilities pertinent to RoHS-compliance:

• Scrutinize component data sheets.
• Verify component is suitable for higher lead-free soldering temperatures (defined in JEDEC 020-C) if going for RoHS-6 [check max temp].
• If going RoHS-5, need to ensure whether “RoHS-compliant” part is backward compatible with RoHS-5 process (e.g., will it be solderable at lower RoHS-5 temperature?).
• Check finishes: watch out for pure tin finishes for “tin whiskering” effect (ensure they pass test criteria in JESD22A121).

If your organization wanted to target target RoHS-5 compliance, there were some important considerations regarding parts or components:

• If the industry demand is weighted towards RoHS-6 parts, RoHS-5 (and non-compliant) parts will go End-of-Life (EOL) over time (but how fast was, in general, unknown).
• One needed to pay particular attention to parts such as screws, washers, stand-offs. It was unknown what the status of such parts might be on the "gray market."
• To avoid production line-down situations, proactively add RoHS-6 backward-compatible parts as alternates on the AVL/AML.
• Determine if the are any adjustments needed in manufacturing profiles (usually done by Manufacturing Engineering)

Manufacturing/Reliability

If going the full route to RoHS-6, it was necessary to be aware of a litany of things:

• Tin whiskers (see JESD22A121 spec). There was a concern that the new lead-free solders could result in tin whiskers that could cause short circuits.
• PCB qualification/PCB testing due to new board finishes. The major change is in the use of laminate materials that can withstand higher processing temperatures and different final finishes (thermal capacities higher than the “typical” 150°C glass transition (Tg) range).[5]
• Process verification
• Line and materials handling
  • Watch cross-contamination of parts if the manufacturing facility (factory) has RoHS and non-RoHS assemblies and rework going on concurrently.
• Marking of lead-free assemblies (IPC-1066)[3]
• Assembly inspection
• Factory qualification for RoHS

Lead-free soldering issues

• “Lead-free solder has generally been found to generate more defects of voiding, tomb-stoning, solder beading, bridging, and misalignment…Process optimization is critical for volume manufacturing with lead-free solder.”[1]
• Found SAC (SnAgCu) solder alloys with Ag (silver) content between 3-4% is acceptable.[1]
• Overall yield is slightly lower for lead-free solder as compared with SnPB (tin lead) solder for reflow.[1]
• AOI (Automated Optical Inspection) re-training needed due to the lead-free solder joints appearing duller and more grainy, less shiny (due to Sn dendrites). [1,4].

Mechanical shock/drop

There were concerns that the use of lead-free solders could result in issues if the product were to be dropped or experience mechanical shock:

• “SAC (SnAgCu) solder alloys can fail at loads up to 50% lower than SnPb when subjected to shock, drop, or static board bending.”[2]
• Cause: a combination of brittle inter-metallics, board degradation due to higher reflow temperatures, and a greater transfer of stress because SAC is a stiffer material than SnPb (tin lead).[2]

Verification and Testing

Depending on the types of changes that were being made to the product for RoHS compliance, engineering involvement was required to determine whether other work was required. The team made the assessment on a case-by-case basis, based on what changed. The additional work could include some of the following items:

• HALT (Highly Accelerated Life Testing)
• HASS (Highly Accelerated Stress Screening)6
• Vibration testing
• SQA (System or Software Quality Assurance) testing with the Software group to confirm that product software recognizes and operates correctly with the new part numbers (if the part numbers were changed)
• Field reliability data collection and analysis.

References

1. “Optimization of Lead-Free Soldering Processes for Volume Manufacturing”, presented at IPC Printed Circuits Expo, SNEMA Council APEX and Designers Summit 05.
2. “Long-term reliability of Pb-free electronics”, Electronic Products, September, 2005.
3. IPC-1066 “Marking, Symbols and Labels for Identification of Lead-Free and Other Reportable Materials in Lead-Free Assemblies, Components and Devices”, January, 2005. Available from www.ipc.org.
4. IPC-A-610D-Acceptability of Electronic Assemblies, published February, 2005.
5. “Lead Free: Making the Adjustments. Surface Mount Technology (SMT), October 1, 2005.
6. IPC - Association Connecting Electronics Industries, IPC-1752A Materials Declaration Management, IPC 175X Schema Version 2.0. February 2010. IPC-1752A. Accessed July 13, 2026.
7. IPC - Association Connecting Electronics Industries, IPC-1752A with Amendments 1 and 2, Materials Declaration Management. February 2014. IPC-1752A with Amendments. Accessed July 13, 2026.