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Logistics Issues
Complying with new requirements and staying competitive present various technical and logistical
challenges to companies throughout the electronics supply chain. In order to avoid financial
penalties or halted shipments for non-compliance, and to ensure long-term competitiveness, it
is crucial that companies understand their obligations and plan carefully to develop an
implementation roadmap.
- Data Collection - To ensure compliance with the EU Directives, most electronics companies
are requiring their suppliers to complete and return materials declarations surveys describing
the presence and amount of certain restricted materials or materials of concern. The data
collection process can be extremely time consuming, and in some cases may require companies
to conduct analytical testing of their products. Few companies have access to all the necessary
information they need to complete the surveys, and thus must request information from their
suppliers, who, in turn have to ask their suppliers, and so forth throughout the supply chain.
Many producers have unique materials restrictions requirements and survey formats, and
electronics suppliers are increasingly coping with "survey burnout" in responding to the
myriad materials declarations requests they receive. The EIA, in cooperation with several
other international industry organizations has developed a draft guidance document called the
Joint Materials Declarations Guide, designed to harmonize data collection formats and content,
although there is still disagreement within industry over several details of the guide.
- Data Management - Hand-in-hand with data collection is data management. The data should be
easy to access, easy to update, and standardized to avoid duplicative data collection efforts.
Many companies are developing software to facilitate data collection and management; However,
it is unlikely that any one software product will emerge as the industry standard.
- Compatibility vs. Conversion - While the transition to lead-free electronics has started,
there is not yet a common conversion scenario. Due to the extreme complexity of the global
electronics supply chain, and of internal product structures, it is nearly impossible to
define a common conversion roadmap that would apply to the industry as a whole. Yet, scattered,
piecemeal conversion phases would impose significant logistical effort and cost. Instead of
trying to develop conversion roadmaps during the transition to lead-free, the industry is
seeking to promote compatibility schemes that promote flexibility in processing, for example,
choosing terminal finishes compatible with conventional tin-lead soldering processes (backward
compatibility) or lead-free processes (forward compatibility). Additionally, compatibility on a
global level is a challenge because the industry is in different phases of lead-free
implementation. The US and Europe are behind Japanese companies in their lead-free implementation
and preparedness; whereas many Japanese companies will not accept lead-bearing parts from
suppliers after Q4, 2004, most North American companies are not prepared to accept lead-free
parts before then.
- Large vs. Small and Medium Enterprises - There is concern that small and medium electronic
producers - both producers of finished product and producers of parts and components for use in
finished product - will have more difficulty meeting the legal requirements of the WEEE and RoHS
Directives than large producers. This may result from the fact that SMEs often lack the staff,
resources, and budget to develop comprehensive environmental compliance strategies. Large EEE
producers are concerned that SMEs will need information and tools to help ensure that the switch
to RoHS-compliant products is done in a uniform, industry-wide, and global manner.
- Overall preparedness - There is an alarming lack of urgency among the North American
electronics industry with respect to the Directives. Many companies, particularly SMEs,
have not begun to prepare for WEEE or RoHS and only have a vague understanding of the
requirements. According to Scott O'Connell, Senior Environmental Engineer with Dell,
"the majority of SMEs are not aware of RoHS beyond the 5-page Directive." Many companies are
waiting to move forward with compliance planning because of the lack of clarity from the EU
about the substance of the Directives. Because of the inevitable logistical expenses and the
necessary capital outlays for lead-free processes, there is a perceived risk in getting too
far ahead, particularly since there is a chance the definition of "lead-free" may change. More
importantly, SMEs are only just now starting to be pressed by their customers - this will be
the most important driving force. There is an overall sense among North American electronics
producers that, while the Directives are definitely real and are here to stay, their
implementation will likely be delayed. But there is no chance the Directives will be delayed,
so companies that are planning on this will be in trouble.
- Part number change management - There is no universal approach to numbering lead-free
parts. The IPC is currently developing a marking standard for communicating information about
the solder type and board finish, but there is no industry consensus on how or whether part
numbers should be modified. The conversion of a part from tin-lead to lead-free is considered
a major change and should require a Product-Change-Notification (PCN). However, many component
makers are reluctant to change part numbers because of fears of having to requalify parts, and
the impracticality of having two sets of part numbers for the same functioning part. Because
many suppliers provide parts for customers in both civilian sector applications (for which most
uses of lead are banned) and military applications (for which lead-free assemblies are exempt
and often forbidden), there is a strong need for standardized part numbering schemes to avoid
mixing of lead-bearing and lead-free parts.
- Labeling - The WEEE Directive requires producers to label regulated electronics equipment
with a defined icon. However, there are questions about specific labeling details, such as how
large the label must be, where it should be located on the product, what type of
ink/paper/adhesive should be used and, in some cases, which products should be labeled. There
is currently no defined label to designate RoHS compliant products, although JEITA has been
working on this issue (the IPC draft marking standard mentioned above does not focus on RoHS
compliant labeling - only process parameters for assembly).
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