RoHS and WEEE - EMA Design Automation


What are the PLM companies doing to support RoHS compliance?
They have some very good modules that address the issue for compliance so that an enterprise can solve the problem. The fundamental flaw in all that is nobody is providing the data like we are doing. They will give you the software module but there is nothing behind it to give you the tools you need to get the job done. It is incumbent on the companies to fill the bins with the data. Most companies need to work on new product introduction. Solving the RoHS issue is an unfunded mandate and companies do not have the engineering resources or the budget to do these kinds of content generation porjects. We are solving that problem by coming with a cost effective solution, filling the bins and giving them a lower cost alternative to their design methodology.

If they use your tools, will that produce the BOMs that the PLM systems require?
That's exactly correct. Our EDM solution solves the problem at the engineering level because we help fill the bins with the data. The bigger benefit you get from that is the direct link to the PDM, PLM, ERP, or wherever that you need to go whether it is a SQL or Oracle database.

Do you have anything to do with WEEE?
We don't do anything with WEEE specifically other than provide the compliant data, the information you need for the material declaration. That can be put into the right form. The form itself is used for WEEE reporting but there are companies out there like Forsythe who do an excellent job of collecting the data from the OEM, creating the documentation you need for the various countries in Europe. Every country in Europe has a different form that they want filled out.

In the case of WEEE is there a European wide form or procedure or does each country have different forms, procedures and languages?
To the best of my knowledge the WEEE reporting is country by country.

And in the case of RoHS?
The design fundamentals are the same. I believe that one of the Scandinavian countries added some hazardous materials to their list. So they are a little bit out of the norm. It's not really a dramatic change.

Does a firm have to submit compliancy statements in 30 different languages?
Yes. That's what Forsythe does. They'll take the data that we instantiate at the design level. That data migrates up the process to manufacturing. Then when Luxembourg needs a compliancy statement, this data rolls out to a form in whatever language Luxembourg requires. That's sort of the stream of data. While we are doing things generically on the front end, its country specific on the WEEE side. That is more to do with formatting the data than the data itself.

Does replacing lead soldering with lead free and less moisture sensitive materials have any impact on performance, reliability and so forth?
That a huge crisis. The biggest issue right now is tin whiskers. The temperature and humidity spec is causing ball grid arrays to deteriorate rapidly. I'm not an expert in this area but there are clear manufacturing problems.

What is your view of the current deadlines. Will the EU stick to them, relax them, offer more exemptions, ..?
The first lawsuit started last week. An Irish firm got sued by the EU and got fined for non-compliance. They were forced to pay a fine because they were supposed to register last year. I believe the data is July 1, 2006. In my worst scenario, I think lawsuits will start on July 2. What is happening here - and this is sort of my editorial- is that countries in Europe don't want US companies shipping into Europe. In my opinion this has become a trade war issue. If a company in Belgium has a US competitor shipping product into Belgium and they want to shut that company down, they will blow the whistle on the US company. It is then incumbent on the US company to prove that they are compliant. You are guilty until proven innocent. The company in Belgium doesn't have to prove anything because they are not exporting into Belgium, they are already there. While the US company has to burn up their resources defending themselves, their competitors in Belgium can ship their products. There is nothing stopping them.

The Belgium firm presumably would have the same problem if the were shipping to say Germany or France?
Yes. Then they have a different set of problems. An in-country company doesn't have to satisfy RoHS. They have to satisfy RoHS only if someone challenges them. That is my understanding.

I think that this has evolved more from a trade war mentality than from an environmental mentality. It winds up that EU is protecting electronic OEMs in Europe, making it more difficult for US companies to ship into Europe. Again, that is my opinion.

Does RoHS impact the manufacturers of PCs more than chip manufacturers?
The chip makers have a serious problem with their reference designs, everyone of them. They have known for some time about these issues and have been getting the chip compliant or putting them into a end of life if there is no good ROI in reengineering. I see a lot more risk to the smaller OEMS in North America being shut down, being locked out of European market in the short term and locked out of the global market going into 2007 if they don't become compliant. Most small companies can't afford to defend themselves, if they have to go to court in Europe. We have had some people tell us that they are not worried, they will just pay the fine and move on. I don't think it's going to be that easy.

How much investment is typically required for a company to become compliant ($Ks, $10Ks , $100Ks, …)?
I would put it more into the range of $100Ks if you look at the cost of tools, infrastructure, changes and so on. We've dealt with a few companies looking at millions of dollars. To throw in another variable, we are looking at mechanical RoHS compliance for the entire assembly. That's become costly but you have to do that regardless. They are taking this it the extreme. The label that goes on your printer has to be RoHS compliant. You have to look at the type of ink you are using and also the type of glue.

Why is the mechanical side more challenging than the electronic side?
It's not just more challenging in terms of time consuming. A copier for example has a lot of custom parts in it that have different types of plating, different type of manufacturing and so on. It just takes time to look at the drawings and drill down to the material content of that part. It's fairly repeatable once you understand what the company is making.

I'm guessing that electronic component suppliers are more likely to have the necessary data than say a company making a gear.
That's correct. We are partnering with a company in Ottawa that's done a phenomenal job on the mechanical side. A company called Ageus. They are mechanical wizards. We partner with them when we have an AVL for an entire assembly. That partnership has been very successful. Our sweet spot is the electronic component side, content for design and engineering data management. We bring these guys in for mechanical to provide a well rounded solution.

Is there anything else you would my readers to know?
Maybe it's kind of silly of me but I am concerned about OEMs in North America that are ignoring this problem. It's not going to go away. As an American I see companies going out of business because the EU is locking them out. I think this is a serious threat to the electronics industry in the North America.

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