MATERIAL declarations are a major headache for everyone involved with the Reduction of Hazardous Substances (RoHS) directive. Product manufacturers have difficulty getting data from suppliers and suppliers are inundated with requests for declarations – all in different formats. To compound the issue for suppliers, they also have difficulty getting information from the manufacturers. And there is a sting in the tail.
Collecting Yes/No RoHS compliance material declarations is a simple system and the one that most companies are presently implementing. It does, however, have one major drawback. When the next substance is banned all material declarations will have to be resourced. A Yes/No RoHS declaration declares that none of the six RoHS substances are contained in the part, but it does not reference any other substance. So if, for example, polychlorinated biphenyls are banned in 2008, companies will need to go back and collect new material declarations for all components.
However, help is at hand. The new IPC1752 Material Declaration standard, which was released on 9 March, provides the basis for a future-proofed system.
It is an all-encompassing standard which allows for the present yes/no scenarios, but also allows for the level of data that will be needed in the future based upon the JIG A and B lists. These list all substances used in electronics that are either banned or listed as substances of concern in any country. Any substance likely to be banned in the future is also included in these lists. There are 15 substances in the “A” List (banned somewhere in the world) and nine substances in the “B” list (listed as being of concern somewhere in the world).
The IPC1752 Standard allows for six levels of declaration:
· Class 1 – RoHS reporting at a homogeneous level in yes/no format
· Class 2 – Class 1 plus manufacturing information (peak processing temperature, time at peak, MSL level)
· Class 3 – RoHS reporting at a homogeneous level in yes/no format, JIG level A & B at the part level and other customer-specific substances at the part level
· Class 4 – Class 3 plus manufacturing information (peak processing temperature, time at peak, MSL level)
· Class 5 – RoHS reporting at a homogeneous level in yes/no format, JIG level A & B at the homogeneous material level and other customer-specific substances at the homogeneous level
· Class 6 – Class 5 plus manufacturing information (peak processing temperature, time at peak, MSL level).
Classes 5 and 6 allow for the manufacturer to specify a “proprietary substance” with a declaration that it is not one of the JIG A or B substances. In this way a manufacturer can protect their intellectual property.
Some larger companies such as Motorola demand level 6 declarations as a base line requirement for supply. The Sony Green Partner program has similar requirements.
Where most companies have this level of data available is with custom parts, metalwork and plastics that is well worth storing in an IPC1752-compliant database. Companies may be surprised what proportion of their inventory is metalwork and plastics when they look. Typically it will be over 50%.
Information on the material composition for commercial-off-the-shelf (COTS) items is not freely available, however. Most manufacturers have it, but will only provide it as a commercial service. Companies like Total Parts Plus can supply this data, but at a cost.
When the next substance is banned, the COTS item suppliers will undoubtedly start to make substance level information available in IPC1752 format as no-one wants to go through the RoHS Material Declaration pain every four years (which is the EU RoHS substance review period; the Chinese RoHS review is annually).
IPC1752 has standard forms for data entry and for publishing declarations. These forms use Adobe Acrobat Version 7. A little known feature of Acrobat V7 is that it supports an XML schema, which allows areas on a page to be created as “data buckets”. They can be written to as normal PDFs, but more importantly they can be electronically read across the web. This means that forms can be created and posted on a component manufacturers website and the data can be read/downloaded by customers across the web.
All the major ERP systems have bolt on modules for RoHS compliance. SAP , for example, uses the TechniData database that integrates into the SAP Health and Safety Module. These larger ERP system databases are relatively expensive – in excess of $300,000 – when implementation is taken into account. While this is appropriate and affordable for the larger multinationals, it is out of reach of the average SME.
However, low cost but feature rich IPC1752 databases for SMEs are now available. Most notable is the Material Declaration Wizard (MDW) designed by the Goodbye Chain Group. Typically these SME IPC1752 databases will sit alongside the ERP/MRP system as well as the traditional component database. Some software will allow full integration of the existing component database, but some of the entry level systems, such as MDW, are designed to complement the existing component database, be it a simple folder/file structure or an MS Access or Lotus Notes style database. Entry level software starts at around $12,000.
Features that are needed in any of these are:
· a substance level database
· a component level database
· ability to import IPC1752 data from the forms
· ability to import and roll up bills of material (BOMs)
· ability to “publish” a IPC1752 declaration form at product level based on the rolled up BOM and the data at component and substance level
· an easy to use mapping tool at the front end to allow leverage and import of existing component databases.
IPC1752 is the way of the future. Companies in Australia and New Zealand can start using this standard now and save a heap of money when the next prohibition happens – be it the EU, China or the USA. Do it once and do it right. Cost effective and locally supported database solutions are available and will save many times the investment in future years.
Roland Sommer is the managing director of RoHS and WEEE Specialists International . The company has IPC1752 compliant databases available from its website www.raws.co.nz.