February 20, 2006
RoHS and WEEE - EMA Design Automation
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| by Jack Horgan - Contributing Editor
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It is frequently said that we live in a disposable society. It often costs less to replace something than to repair it even assuming that you could find someone to fix it, could locate the spare parts and could live without the item while it is being fixed. Electronic parts seem to be the worst offenders.. This is due in part to shrinking product lifecycles. New versions and even new generations (the iPod is on its 5th generation) come out every 6 to 12 months. The new products are faster, have more functions, more capacity, more content and in general better by every objective metric. Customers are drawn to these new versions even when the products they bought just a few months
earlier continue to operate as advertised. Telephone carriers offer existing users incentives to upgrade their phones every 12 or 24 months. When a customer gets a new phone, the old one is shut off. It becomes a backup if the new phone is lost, stolen or broken but otherwise it is useless.
Old electronic products gather dust in our basements, garages, and attics. Sooner or later they make their way to the trash dump or landfill creating a burden for municipalities to collect and process. More troubling is that these products contain hazardous materials. The water from acid rain dissolves lead and other hazardous materials from the electronic equipments, and the rainwater mixed with these materials can go straight to the water table and then to the drinking water.
The European Union has issued two directives to address these issues. Specifically
RoHS (pronounced Ross or Rohas) - Restriction of Hazardous Substances.
WEEE - Waste Electrical and Electronic Equipment
Each country will enact legislation to define the actual requirements that the EEE producers must meet. Each country has its own laws, registration organizations, enforcement, compliance options, take-back options, language and fees. Most EU member countries have RoHS legislation in place.
The RoHs directive define the maximum concentration values (MCVs) for
Hexavalent Chromium (Cr6+)
Polybrominated Biphenyl (PBB)
Polybrominated Diphenyl Ether (PBDE)
The MCV for Cadmium is 0.01% and for the others it is 0.1%.
The limits are set not on the final product but rather on the “homogenous materials” contained therein. By homogenous material one means a material that cannot be mechanically disjointed into different materials by such actions as unscrewing,
cutting, crushing, grinding and abrasive processes. Examples of “homogenous materials” would be individual types of plastics, ceramics, glass, metals, alloys, paper, board, resins and coatings. A semiconductor component is not homogenous, as it is made up of many other homogenous materials such as the case (plastic moulding), the leadframe alloy and the leadframe coatings, etc., An electronic assembly with less than 0.1% lead by weight would be non-compliant if any components on it have solder plating that contains more than 0.1% by weight itself.
This RoHS legislation is effective July 1st, 2006 and from this date on products using these substances cannot be sold in Europe. There are exemptions if the elimination or substitution is technically impractical or if it would negatively impact health, safety or the environment. Many military and medical applications have exceptions.
There are several parallel efforts to the EU directives around the world
China - Regulation for Pollution Control of Electronic Products (RPCEP)
Japan - Japan Green Procurement Survey Standardization Initiative (JGPSSI)
Joint Industry Group (JIG)
California Electronic Waste Recycling Act of 2003 (SB20/50)
The purpose of the WEEE Directive is, as a first priority, the prevention of waste electrical and electronic equipment, and in addition, the reuse, recycling and other forms of recovery of such wastes so as to reduce the disposal of waste.
Basically the producer has an obligation to arrange and finance the collection, treatment, recycling and environmentally safe disposal of WEEE. The producer can do this alone or by joining a collective scheme. Users of electrical and electronic equipment from private households should have the possibility of returning WEEE at least free of charge. Each producer should, when placing a product on the market, provide a financial guarantee to prevent costs for the management of WEEE from orphan products from falling on society or the remaining producers. The responsibility for the financing of the management of historical waste should be shared by all existing producers in collective
financing schemes to which all producers, existing on the market when the costs occur, contribute proportionately.
The directive also spells out requirements for reporting data to authorities, to recyclers and consumers. For example as of August 2005 products will need to be marked with the wheelie bin symbol.
WEEE covers 10 categories of products that are listed below:
Large Household Appliances
Electric and electronic tools
Small Household Appliances
Toys, leisure and sports equipment
IT and Telecommunication Equipment
Monitoring and control instruments
A company that has become very much involved with RoHS compliance issues is EMA Design Automation of Rochester, NY. I had an opportunity to interview Manny Marcano, their President and CEO.
Tell me a bit about EMA Design Automation.
We have been doing VAR business for the better part of 15 years. We've sold for most of the EDA companies out there. But we've been doing Cadence since 1998. We started selling the traditional tools and rolled into OrCAD in 1999 when Cadence acquired OrCAD. Now we are the solution provider in North America for all their PCB tools.
Does this mean that you are a Master VAR/Distributor?
Officially we are the only VAR. We are it for all of North America. We are the sole distribution channel for Cadence in NA.
How many offices do you have?
We've got one primary office here in Rochester, NY. We have 60 plus people there and forty plus people in home offices scattered about the country.
Does Cadence have a similar sales model in Europe and Asia?
They do. They have some senior and experienced VARs running in some cases a country or multiple countries. Unlike some EDA vendors, they do not have any competing VARs in the same territory. They are very loyal to the VAR channel.
What is the biggest challenge for your operation?
Keeping up with the growth opportunities!
How do you attempt to do that?
We have found RoHS to be a compelling event that is driving opportunities in services as well as pulling software sales. That's the real growth. Although the PCB market is in essence not growing, we are finding our ability to displace competitors because of what we are doing in RoHS. That's where the growth is.
How do you fit in with RoHS and WEEE?
Our niche if you will in this new area is on the RoHS side. We are simply trying to give engineers the ability to define what we call compliancy by design by giving them content in their schematic with OrCAD so that when they pick a part, it is compliant. I think that part of the problem in the market place is most people are looking at RoHS as a manufacturing problem and WEEE as being so far downstream they don't care anymore. But we've taken the position that if you have the content that's compliant from the beginning of your design cycle, you now have the certification data for the RoHS ands WEEE.
What's the fundamental issue with RoHS facing manufacturers or designers?
We asked a customer just a few months ago how big his RoHS problem was. He told us that it was a $300 million problem to him because after July 1 he can not ship to Europe. The $300 million figure is the firm's annual revenue from Europe. That's the problem they face. If you are not compliant, you can be put out of business. What we have found is that most companies in the US have their head in the sand over this issue. They hope it will go away or they think that the EU is going to change its mind. That's not going to happen. The train has left the station and people have to become compliant.
If I am a manufacturer of an electronic consumer product like a DVD player, what is my responsibility with regard to RoHS if I am just assembling components from suppliers?
If you are doing component level design and manufacturing, you are responsible down to the resistor level to make sure that the part is compliant. If you are doing the assembly simply buying modules and bolting them all together, if your label is going on that end product, then you are still liable for that end product whether or not your individual suppliers are compliant.
We are involved in analysis at numerous companies where we are looking at the OEm's product but they have asked us to go to their suppliers and look at the subassemblies.
If I am getting a product from a supplier, am I responsible for testing that product's RoHS compliance or are there third party testing firms or do I rely on a compliancy statements from my suppliers?
All of the above will work. It's just a matter of risk mitigation, If you are satisfied that your supplier gives you a certificate of compliance and your legal department is willing to take that and defend that in front of the EU courts, then that could be suitable. But if you suspect that your supplier is saying that they are compliant when they are not, the liability is still on your firm for the product going to Europe. We had this case recently where a company told us that he is not worried about it because he has a Chinese contract manufacturer who is going to verify compliance. If anybody is going to be betting their company on that type of scenario, I would say that they do so
at high risk.
What do you advise your clients to do in terms of getting comfortable that their suppliers are in fact compliant?
What we are doing for our customers is going through their AVL (Approved Vendor List). We are scrubbing that list. We are getting that list compliant down to the component level. Not only do they have a RoHS yes or no, they have all the material data behind it. So when they print out the declaration statement for the EU that source data is right. They have it during the engineering phase and all the way to manufacturing and shipping. Basically we instantiate as much compliancy data in the original component level design data base as possible. That's where you mitigate the risk, early in the design cycle.
What type of data is necessary?
Things like the actual amount of lead by engineering units and how much Cadmium there is.
So on behalf of your client, you go to the firms on their AVL and gather all the information.
Exactly right. We literally have a large team of component engineers that are going line by line through the AVLs to validate and verify information.
Do you offer a service where you have a data base with all the collected information or do you do this on a client by client basis?
We are doing it primarily on a client by client basis because AVLs are customer specific. They are also intellectual property that companies keep very close to their chests for NDA purposes. We look at manufacturers' part numbers, we call the manufacture for the data, and we populate the data base. Because of this massive data collection issue, we have created an entity we call the Engineering Data Management (EDM). This essentially enables an engineering director to manage all of his compliant data in one data base without having to mess around with the big enterprise systems. So within EDM he can manage his compliant information in the work in progress kind of things where you are
re-designing and re-spinning boards. Once it is ready to go off to PLM, the data is all put together as a BOM and moved off to the manufacturing. We sell the tools OrCAD Capture and CIS Allegro but we've developed the methodology called EDM to manage this data.
Does the designer sitting in front of an OrCAD or Allegro screen only have access to elements that are RoHS compliant or does he have the option to choose?
It really depends upon the customer. For most customers we have made their AVL RoHS compliant. That's the optimum mode. So that engineers can not even design something with a leaded part. Some companies maintain inventory and know that they still have X amount of these leaded things. These items might become a suitable substitute for a lead free part to be used for prototypes. OrCAD also allows the customer to look at their data base, their design data and instantly know whether the design has any leaded parts in it or not.
Can you go backwards? Can you take an old design and map it against this data base and get a RoHS pass or fail?
Absolutely! In fact we have done that for numerous customers. It literally makes their jaws drop. Because their AVL is pristine when they look at their old designs, the bad stuff jumps right out at them. They know exactly what to change and what has to be redesigned.
Under these circumstances, do they typically find the changes to achieve compliance to be considerable?
It's hard to say that there is a certain number. We've seen 80% success rates and less of course. We've seen some situations where it is a straight suitable substitute to a lead free part. We've seen numerous situations where the leaded part is obsolete and there is no suitable substitute. It runs the gambit of problems out there.
The suitable substitute routine we do is especially applicable in the case of obsolete parts. Part obsolescence is in essence somewhat of a bigger problem than the RoHS issue. So many chip makers are obsolescing leaded parts right now that not only are these parts obsolete but their life expectancy is measured in months instead of years. So when a designer uses one of these parts that is available today, there is so much demand for those parts that not only could that part be obsolete but it may not even be available in the marketplace.
People say that they have an exemption, e.g. military and medical are exempt until 2010 time frame. What happens is that if the leaded parts go obsolete, they can't make their product anyway. We are engaged with several medical companies specifically that are way ahead of the curve because they clearly understand part obsolescence problem. By the way solving that problem solves the RoHS problem at the same time.
Are you helping any component manufacturers become compliant?
Not at the component level because most of the forward thinkers have got that already figured out. But we are engaged with a few where we are helping to redesign their reference boards. So while their chips may be compliant, their reference boards have the same problems as any other OEM has with their boards.
Your offering is a combination of software and service. How are these priced?
Sometimes it includes some Cadence software. First we get the tool methodology down. In most instances, we are finding success with the Engineering Data Manager software.
For our engine we are using a company called Omnify. There really isn't a price point that you can put your finger on. It runs the gambit where we are doing some pilot project in the less than $50K range. But we are also engaged in some very significant full product analysis and reporting in the six figure range.
Didn't I see where EDM lists for about $25K?
That's sort of an entry point to get you started with the server software. It depends upon the number of users. Over in manufacturing you can get some view only tools or licenses. You can roll out an enterprise solution for $100K or so.
Are you aware of anyone with a similar offering of products and services?
The PLM players like PTC, Agile and MatrixOne have similar tools but they are focused on the enterprise solution. They don't focus at all on an engineering solution. They have an engineering module but it's a byproduct of the enterprise tool. The PDM and PLM people are focused on manufacturing and very high end issues. Nobody to my knowledge is focusing on solving the EDM problem for engineering. That's what we have found as our sweet spot.
I saw an announcement of a partnership with PTC.
We are selling the Intercomm product from PTC. That's a great tool we are using for the visualization side of what we do. There are a lot of companies, as you are well aware, that are really conglomerates of lots of small acquisitions. Within those acquisitions they've got numerous different CAD tools. If we standardize on a library or at least the content part of it, they need to have some way to visualize one schematic over another schematic or dissimilar printed circuit boards. That's where the Intercomm tool fits in very nicely.
I see that you offer seminars and webinars on RoHS compliance. How is that going?
Incredibly successful! We did a phenomenal webinar with the PVR folks. There were hundreds and hundreds of people and hundreds more have signed up to view the on-demand version of it.
How does the US stand on the RoHS issue?
Let me rephrase. Is there any Federal or state legislation on the books regarding RoHS?
It's all very chaotic. California is the first state that has legislation on the books. I think about 30 states have legislation in the works but there is nothing at the Federal level. Nothing has come out of NIST. It's a big problem.
How about other countries?
Taiwan, China and Japan have similar things. In fact China has one of the harshest set of rules. You may achieve European compliance, yet you may not be compliant in China. Japan has their own set of rules. They are similar but not the same.
Our solution and we have done this consciously and with a little bit of luck is flexible enough so no matter what you have to comply with you can add the rules indefinitely as new hazardous materials get identified. You can add that attribute to you data base and press on. You do not have to retool because Taiwan says that they will not allow XYZ material in their imports.
So the data base is future proof but someone would have to gather the additional data.
That's exactly correct. So what we are trying to do and we are not there yet but we are working on it, is to develop our own RoHS data base. We want to make this available to our customers on a subscription basis so that we keep it refreshed for the customers. They can update according to how they have subscribed. We follow the rules. We see that Taiwan is going to add this material content next year. We try and get ahead of the curve for our customers. That's in the plan but we haven't executed it yet. We want this data base that we are building to be as dynamic as possible. So it grows as the rules grow.
Is this data base customize for each client or do you have one large data base and extract a custom view to match the clients AVL?
The latter! We are using the Omnify tool ourselves as our internal mechanism and that allows us to have a master data base with a subset per client. That's what will allow us to build this master data base for our clients that subscribe. We can use the master as the generic library.
Can you support other design systems other than OrCAD or Allegro?
To some extent. The data is specific to the chip manufacturers but it is generic to the schematic and board tools. Our methodology is what makes the total package a competitive advantage. Our ability to put content, EDM, OrCAD and Allegro all in a flow makes it successful. The content itself is certainly saleable to anybody.
If a designer is looking at a schematic or board layout does he see some symbology to indicate RoHS compliance?
Sure. We did an attribute in OrCAD for one customer where you can open the schematic and the attribute pops up with a Yes or No right next to the component. A manufacturing person or anybody can look at that schematic with an Intercomm tool from PTC and see that he has one part over here that's not compliant. That's an attribute that can be turned on or off.
For an assembly the percentage of a hazardous material may be very small. At what level (component, subassembly, assembly) does one need to have the percentage below a certain amount.
When we fill the data base we put in the weight of each material. Technically you could take that BOM and add up that column and say “Okay I have X amount of Cadmium in this design and I am safe.” That gives you a sort of compliance guideline. That can be derived from the data that we put in the schematic data base, the EDM data base.
My question really is if I had a design that had too much Cadmium by weight, couldn't I just add a brick or something and the lower the Cadmium percentage.
The authorities have figured that one out and are preventing someone from doing just that.
Are there any conference coming up focused on RoHS issues?
At PCB West EMA is sponsoring a panel. Several experts are coming in. There will probably be very detailed discussion on a lot of these issues. I would suspect that there will be a lot of contract manufacturers at PCB West focusing on their offerings in the RoHS space.
Historically lead has been used for soldering. Non-lead based soldering is done at a higher temperature. Doesn't that create some manufacturability issues?
All we are doing is to make sure they have the right footprint defined in the design. So that the footprint has the right temperature specification so that the right part is selected that has the right temperature spec to go through a tin process for example. We don't do anything on the manufacturing side. The CMs that are out there are doing a great job at that.
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
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.
A lot of CMs and even some component distributors are doing BOM cleansing and AVL cleansing after the product has been designed. They may get that one design compliant and out the door but it doesn't eco your design back to your library so that your next design is compliant.
It's very passionate with me. We've been doing this for a year now. We have learned so much from our customers. We have seen so many customers and prospects ignoring the problem. They say I will let my CM take care of it. The CM is not going to pay the fine. The CM's lawyer is not going to defend you in court. When you throw the BOM over the wall, the CM may change the design and inadvertently choose a part that is not compliant. Somebody blows the whistle in Europe and they find out that you screwed up. The OEM is liable no matter who did the design or who did the manufacturing. That's the part that drives me crazy. People are not paying attention to the liability.
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-- Jack Horgan, EDACafe.com Contributing Editor.