Materials Reporting Update

Electronics

Oct 11, 2016

Brenda Baney

B Cubed Consulting

Agenda

• Overview / History

– Legislation

– Systems

• Current Structure

– Rec019 materials & component reporting

– Integration within supply chain

• REACH/RoHS

• Conclusions

• ELV as of July 2002 has restricted use of Pb in solder

– Exemptions have expired gradually for many applications

– Remaining exemptions are*:

• 8e High temp, high lead solder for ‘active’ components

• 8f split into 8fa& 8fb Mating side of vehicle harness connector not exempt for type approved (TA) vehicles after 1/1/17.

• 8g semi-conductor connections to flip chips

• 8j for soldering of laminated glazing for TA vehicles until 1/1/20

• Recommendation 019 and IMDS resources

– Interpretation Guide agreed upon at IMDS Steering Comm has dictated when updates required

– Assembly & comp reporting rules allow for format flexibility

* see interpretation guide & backup

Overview / History

• RoHS restricted use of Pb in solder since the 2002 release of RoHS1 (Directive 2002/95/EC, repealed in 2013)

– RoHS exemptions tend to be more product specific rather than covering a whole range of applications.

– RoHS2 (Directive 2011/65/EU, from June 2011)

• Uses 11 different product categories with varying exemptions

• Exemptions expire after 7 years for Cat 8-9 and 5 years for others*

• Products put on the market in EU are required to have a CE mark

• REACH

– Requires EU manufacturers and importers to document and report SVHCs to customers

– O5A principle (Once an article, always an article) guidance developing

* see back-up

Overview / History

Overview / History

• IPC 1752a B2B • IPC 1752 first published in 2006 as a standard with an associated FREE Adobe form that could be easily shared between business partners • Complete overhaul in 2010

• Removed the adobe form • Changed from Classes 1 thru 6 to the 1752a Declaration Classes A-D • Renamed to IPC 1752a

• Some companies using Class A or declaration statements; with large or complex assembly companies pushing for a cascade of full material declarations (FMD or Class D to IEC62474)* not industry-wide • Lots of solution providers able to create, send, and receive format

• List Management Challenges

• REACH updates every 6 months • Various industries insist on their own lists (IEC62474 versus GADSL, versus new emerging AD, other company custom, etc…)

* see back-up

• Recommendation 019

• Initially Flat BOM method for reporting of wiring harnesses • Expanded to include circuit board and hybrid assemblies • Users MUST HAVE underlying component compliance data • Includes component instructions for small parts (<5g) relating to naming and other relaxed rules for using material classification 8.x • Within IMDS Steering Committee direction, materials and semi-components are managed by ZVEI group with input from Supplier Alliance, and electronics materials companies. Asked to address new REACH relevant substances as well as O5A guidance input.

• Supports GADSL reporting as long as alternate data formats include appropriate substances Some examples:

• IPC 1752A, various classes • Timely REACH and RoHS and/or ELV compliance statements • Test data

Current Structure

Current Structure

• Problems/solutions with current REC019 material set

• Lead in solder removed from initial set, to reflect ELV exemptions, must be

individually added by MDS creator with appropriate codes

• Ceramics reporting, led to ceramics and glass pseudosubstances, with and w/o

lead instead of SVHC metal oxides as ingredients

• New REACH substances showing in epoxy materials. See below. Additional

discussions on-going to verify flame retardants and other additives in use for

‘standard’ PCB.

• Silver can be a biocidal and found in special metals. Not usually.

• More REACH or biocidal substances coming? Probably

• O5A implications? Definitely, but that’s why auto is on PEG

• TBBPA found in PCB – Epoxy for laminate, components • TBBPA is both a reactive and additive flame retardant

• Is reactive in epoxies and rubbers typically. Additive in styrene, ... • Will be replaced with CAS# 68928-70-1 Brominated epoxy

REC019 materials – PCB Std w/o Leaded Ceramics

Remember to use the most current Versions of the ZVEI semi-components

Impact to REC019 materials due to Biocidal Substances

Ag in both Metals & Special Metals

Ag potentially present in solder

Impact to REC019 materials due to TBBPA

Similar changes to

PCB – epoxy for components,

High Component Load

And PCB – epoxy for laminate(s)

Brominated epoxy resin CAS# 68928-70-1

Alternate epoxy materials from electronics suppliers

REC019 Application Code Impacts

• All 8f products when sent as a new part number to the customer will required

modification to 8(f)(a) or 8(f)(b).

• OLD code (58) must change to (67) or (68)

• 68 for 8(f)(b) is for “compliant pin connections other than the mating area of

the vehicle harness” &

• 67 for 8(f)(a) expires Jan 1, 2017 for new type approved vehicles

• Most customers expect ALL MDSs now to be one or other

• Customers should send list of affected parts for MY17

and later per Implementation Guide.*

* see links

IMDS Committee 60/40 solder with 8f Application Codes

Good and Bad Practices with regard to 8F

• Good Practices

– OEMs: Evaluate current 8f applications

• Provide list of affected parts to Tier 1s

• Communicate about parts requiring changes (mating surface of vehicle harnesses)

– Tier 1s: Evaluate and update 8f MDSs

• Bad Practices

– OEMs: Asking for all to get updated

– Tier 1s:

• Waiting until to get asked, using 8(f)(b) when it should be 8(f)(a)

• Using 8(f)(b) on parts other than compliant pin applications

• Picking a committee or other solder just because it is compliant

REC019 Overall Impacts

More steps, as must look at SVHCs, add biocide and application code info

Is it as easy as adding solder and selecting the 10a application code?

Integration within the Supply Chain

• Integration of various component reporting and different formats is the real “challenge of the day”

• Especially since electronics uses either • custom company B2B (majority) • IPC 1752a Compliance statements to Full Material Declaration (FMD)

• Further complicated by the emerging needs of heavy machinery, aerospace/defense, and other complex goods data requirements • IPC 1754 new standard Material Reporting for Aerospace & Defense

• Under development • Understand need to make usable down supply chain, but… insisting on disclosure to their ADSL, even in query “Contains…?”

• List Integration will be paramount to any successful effort to launch other industry reporting schema.

• Heavy Machinery decision to use GADSL+ Positive for Auto • Aerospace insisting upon own list Negative for Auto

Electronics Industry Sectors

• Aerospace & Defense

• Automotive

• Banking/Finance

• Chemicals

• Communications

• Construction

• Energy

• Entertainment/Media

• Government

• Heavy Machinery

• Insurance

• Manufacturing

• Pharmaceuticals

• Real Estate

• Retail

• Transport/Logistics

Combined, maybe 8% of the consumer electronics market!

IPC 1754 Materials Declaration Standard for Aerospace and Defense and other industries

• Group chartered with creating IPC-1754 materials declaration standard for Aerospace and Defense and other industries. To define an XML data structure to facilitate the exchange of data regarding chemical substance reporting either in: (a) In-Product – chemical substances found on the final product (b) In-Process – chemical substances not found in the final product, but are used in the process of manufacture [Optional] (c) Maintenance/Repair – chemical substances used in the maintenance and repair of a product [Optional] Goal to enable consistent reporting across multiple industries, using set of data elements with a mix of mandatory and optional. Data elements can then be required as applicable to an industry, against a defined substance list and rules (i.e. wildcards)

The Long Supply Chain

Industry overlap? For sure!

REACH / RoHS

• REACH overlaps across all industries (doing biz in EU)

• New European Court of Justice (ECJ) decision on “once an article, always an article” for Article 7(2) communication leading to need for modification of Guidance document on Article SVHC Communication from ECHA.

• First draft released to reflect legal language with plan for stakeholder group (PEG) to adjust guidance reflecting multiple examples • Auto actively participating in PEG • Providing input for exemption for PCB assm’s

• Auto works with:

• Supplier groups (AIAG, CLEPA, JAPIA) • Other Industries (shares info) • Other interested parties (ex. BDI)

• Auto has credibility with ECHA

IMDS may not be perfect data, but it is better than anything else

REACH / RoHS

• RoHS is becoming applicable to ‘all other’ electronics starting in 2019

• Category 11 is for “other EEE not covered by the categories above” and is affecting new product types*

• Consumer Use Heavy Machinery • Other complex durable goods?

• IPC 1752a developed for small electronics parts (ICs) • Will the 1754 schema approach work for complex assemblies?

* see back-up

Conclusions

• ELV/RoHS

– OEMs and Tier 1’s to evaluate their 8(f) applications

– Make sure you’re using 8(f)(a) for “compliant” compliant

– Understand the overlap between ELV and RoHS exemptions especially with regard to expiring ones for automotive and/or other industry customers

• REACH

– Stay tuned for REACH O5A Guidance final doc and the auto request for exemptions for PCBs due to the proportionality argument (benefits outweighed by extreme documentation effort)

Conclusions

• IMDS and other Systems

– Recommendation 019 is still a feasible method for automotive suppliers to document electronics content

• Check current electronics parts for compliance and then move to new semi-components for future submissions

• Make sure you have necessary underlying parts documentation

• Supply Chain

– North American automotive suppliers need to participate in Supplier Alliance activities to provide and receive needed info on substance restrictions, CAMDS, other B2B issues, …

– Auto electronics suppliers with non-automotive markets reach out to work with IPC 1752a, 1754 and AEM efforts

Enjoy the conference and provide feedback!

Thank you Brenda B. Baney (B3)

B Cubed Consulting, Inc. www.bcubedconsulting.com

BACK-UP

Links

• IMDS Interpretation Guide for Application Codes and ELV Exemptions

– New release for Version 3.0 June 2016

http://public.mdsystem.com/web/imds-public-pages/imds-news

• ELV Directive – 7th Revision of Annex II

http://ec.europa.eu/environment/waste/elv/events_en.htm

• Released May 2016

• RoHS Directive – recast June 2011

http://ec.europa.eu/environment/waste/rohs_eee/events_rohs3_en.htm

• Consolidated version June 2015

ELV 8f

Old exemption entry 8f

As introduced with

COM decision 2010/115/EU

New exemption entry 8f (b)

As introduced with

COM decision 2016/xxx/EU

New exemption entry 8f (a)

As introduced with

COM decision 2016/xxx/EU

Scope

Generic exemption

for compliant

pin connectors

Scope

Vehicles type approved after

31 December 2016 and spare

parts for these vehicles

“Lead in compliant pin connector

systems other than the mating

area of vehicle harness

connectors of vehicles type

approved after 31 December

2016”

Scope

“Lead in compliant pin connector

systems “ ( like 6th revision)

Vehicles type approved before

1 January 2017 and spare parts

for these vehicles Divided into 2

subentries by

7th revision of

annex II

RoHS Out of Scope Products

• EEE that was outside the scope of Directive 2002/95/EC, but which would not comply with this Directive, may nevertheless continue to be made available on the market until 22 July 2019

• EEE needed for national security or designed to be sent into space

• Large-scale stationary tools

• Large-scale fixed installations

• Means of transport (except non-TA electric 2 wheel)

• Non-road mobile machinery for professional use

• Active implantable medical devices

• Photovoltaic panels for professional installation for permanent use

• EEE designed for R&D and only available in a B2B manner

RoHS Product Categories

• 1. Large household appliances.

• 2. Small household appliances.

• 3. IT and telecommunications equipment.

• 4. Consumer equipment.

• 5. Lighting equipment.

• 6. Electrical and electronic tools.

• 7. Toys, leisure and sports equipment.

• 8. Medical devices.

• 9. Monitoring and control instruments including industrial monitoring and control instruments.

• 10. Automatic dispensers.

• 11. Other EEE not covered by any of the categories above.

REACH / RoHS

IPC 1752A Declaration Classes

• Class A Responses to standard or optional custom queries – Compliance Statements

• Class B (optional) Material Class reporting

• Class C Substance category reporting at the product level. Mass of substance category if above threshold.

• Class D Substances reporting at the homogeneous material level (FMD)

• Data provided by various software tools yearly verified to provide A, C, & D in proper format.

REACH / RoHS

IPC 1752A Class types

• Class A

– 6.1.1.1 Product meets RoHS without any exemptions

– 6.1.1.2 Product meets RoHS with only Ex 7b

– 6.1.1.3 Product meets RoHS with one or more of the exemptions (AppB)

– 6.1.1.4 Product does NOT meet RoHS

– 6.1.1.5 Product is Known to supplier but part Obsolete / No info

– 6.1.1.6 Product is Unknown to supplier

• Class C uses substance categories

• Class D typically uses IEC62474 list of substances

• Much reporting with electronics supply chain is either Class A reporting or based on test results