European Directive RoHs Compliance 1

[ScotsEdge]

Working for a OEM of Aerospace products in the USA that ships product to Europe, I am currently struggling with the following European Directives:

2002-95-ec & 2002-96-ec.

Having searched the web and read countless "opinions" on the directives, I'm wondering if anyone else would like to share their thoughts on this.

From what I have read there is a school of thought that Boeing believes commercial aircraft are exempt form these directives. Airbus believes the directives are more directed toward consumer goods and not applicable to aerospace products.

There is a request for exemption currently awaiting review by the EU, that will cover "Electrical/Electronic equipment that are used in transport-aviation, aerospace".

Having read the above directives they do not state that aerospace is exempt or that aerospace is psecifically included, with the exception of Military/Defense applications.

Our products are used in the Corporate, Commercial& Military Aviation markets which presents more problems as I see it.

We typically use Mil-C-5015 Circular Connectors on all our products, these Do Not and will not meet RoHs.
We also use Chromate conversion coatings per Mil-C-5541 which also does not meet RoHs.

I am aware that vendors are working on alternates to the Mil-C-5541 coatings, however if you are making a part to comply with the Mil, the alternate coating is not acceptable.

Anyone want to share there companies stance on RoHs at this time?

Or any other thoughts on this issue.

Thanks

 

[SteveBull]

My understanding is that RoHS compliant parts will NOT be required to be used within Air-Frame products

The Directive applies to the following types of product
(these categories culled from the WEEE directive)

1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools)
7. Toys, leisure and sports equipment
8. Medical devices (with the exception of all implanted and infected products)
9. Monitoring and control instruments
10. Automatic dispensers

Turning to page 10 of the WEEE legislation (2002/96/EC) will reveal Annex IA, which lists the ten broad categories of equipment that fall within its scope (and consequently the scope of RoHS). Categories 8 & 9 are currently exempt from RoHS, but are not exempt from WEEE.

Whilst products that go directly into aircraft are not required to be manufactured or sold as RoHS compliant, the problem is that inevitibly, RoHS compliant devices will become the only option in many cases... as Lead Free solders and surface finishes are subject to dendritic growth, they present a significant risk to product quality, not really a major issue if you are manufacturing a vacuum cleaner or DVD player, however, when the item failing could affect the safety of an aircraft, this becomes much more of an issue.

Other issues relate to the increased temperatures that are required to solder in a lead free manner, this can be between 10 and 30 degrees C different, and can lead to damaged substrates, and increased thermal stresses on PWBs (via holes may develop ring voids for example).

To muddy the waters, the use of the product is the primary criterion for deciding whether it needs to be RoHS compliant. A field telephone for example would be considered a telecommunications device, so, although it is being sold for the military, its function requires taht it be RoHS compliant. A microwave oven to go into a galley in an aircraft could arguably be describes as a Household appliance.

If you are in the UK, you should contact the NWML and discuss your products with them to find out if they should become RoHS compliant... We are generating files of "justifications for Exemption" for product where we beleive we are exempt from the requirements of the directive, this details:
Product Name
Details of variants
A photo of the product
A description of the product
Details of options and accessories
Physical dimensions and weight
Details of the marketplace it's sold into and the numbers sold
Recall capability (traceability)
List of customers
and finally, our take on whether it is RoHS complaint, whether under one of the temporary exclusions detailed above, or because it simply does not fall under any of the categories, and therefore RoHS cannot be applied to it.

We have bounced a few of these justifications off the NWML, and they have given guarded responses.. Something along the lines of "appears to be exempt, but this determination is one that must be made by a court of law"

Basically, perform due diligence in consideration of ones product lines, and provide evidence of this so that, should your organisation come under the scrutiny of the enforcing body, you can show that you have looked at the directive and decided whether or not you must abide by it.

I hope this helps and I did not ramble on too much.....

Steve






Steve Bull
Quality and Circuit Engineer.

 

[ScotsEdge]

Steve,

Thanks for your feedbck on this issue.
I'm sure it will get very interesting this year

Best Regards Niall Kennedy