On January 27, 2003, The European Parliament and Council of the European Union established a Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment. This Directive is significant in that it restricts the use of some heavy metals and other substances used for electronic equipment to be sold in EU markets after July 2006. Some of these substances are not new to the list of harmful products. European Union Directives have singled these substances out and described programs for their reduction as far back as two decades ago.

Why is this happening? The EU had established certain Directives to manage the increasing waste stream of electrical and electronic equipment and components in EU landfills and waste incinerators. The WEEE directive (2002/96/EC) provides more details.

The goal is to limit the total quantity of waste going to final disposal through increased recycling. Electrical and electronic equipment producers are responsible for taking back and recycling equipment. This provides incentives to design equipment in a more environmentally efficient way. The restriction of certain hazardous substances takes the program one step further by limiting the generation of hazardous waste that includes some specific heavy metals and other substances. This is described in RoHS directive (2002/95/EC).

Who does this affect? This affects any manufacturer and producer of electronic equipment that is intended for sale in the European market. Products can contain only limited amounts of Lead, Mercury, Cadmium, Hexavalent Chromium, PBB or PBDE as of July 1, 2006.

Are there exemptions? There are some exemptions that your products may fall within. For example, brass, an integral part of most electronic devices, may contain up to 4% lead. Most products manufactured by Mill-Max have a base material of brass. Therefore, the raw material for Mill-Max products is exempt from the requirement to be lead-free. Other exemptions may also apply to your intended use of some Mill-Max products. Customers must determine if those exemptions apply by reviewing the Directives.

Has the Directive been amended? The EU amended the original RoHS directive (2002/95/EC) in August 2005. The amendment (2005/618/EC) now describes an allowable amount of the originally banned materials. The threshold limits defined are so small that the amendment is academic. For Mill-Max products, there is no intentional use of those substances, unless specifically exempt such as lead in brass. Details of the amount of allowable Lead, Mercury, Cadmium, Hexavalent Chromium, PBB, and PBDE can be found in the referenced Directive. Subsequent amendments and additional Directives have been added to the original list of banned or restricted substances. At this time, Octa-BDE, Penta-BDE, PFOA, and PFOS are also included in the restriction. More information about those materials and the restrictions can be found in (Judgement of the Court) and (2006/122/ECOF)

What about Lead and Lead-Free Products? Lead has been an important part of most electronic products. Lead is a common alloy in plating. Lead makes significant contributions toward lowering soldering and reflow temperatures as well as its known properties for inhibiting tin whisker growth. Although the directives limit a number of substances, the attention seems to be mainly on the substitution of lead. That is why most companies associate RoHS with the phrase "Lead-Free". To be accurate though, lead is only one of the substances restricted by the directives. All the restricted substances need to be addressed. Claiming a product is "lead-free" does not make it RoHS compliant. The other restricted substances must still be below the threshold limits.

Are Tin Whiskers a concern? As companies move from tin/lead plated connectors to pure tin plated connectors, they must be concerned about tin whisker growth. Only the customers application will determine if pure tin plated connectors are an acceptable alternative. Actions have been taken to inhibit tin whisker growth. Special platings were developed by Mill-Max and its plating chemistry supplier to meet this objective. However, pure tin plating can exhibit tin whiskers over time. Our pure tin matte finish plating has been tested by Technic, the supplier of our plating chemistry, for tin whisker growth. The result was that pure tin matte finish plating, over a nickel underplate, can exhibit whisker growth. The report is available in the Document Downloads. Customers are cautioned to determine if this property is detrimental to their application.

What's happening at Mill-Max? Most of the restricted materials had been eliminated from environmentally conscious companies a long time ago. This includes raw material suppliers to Mill-Max. Mill-Max has offered certification that some of these substances are not present in our process or in our packaging for over a decade. The limit on lead in plating is the most significant change. This will have the greatest impact on Mill-Max and our customers. We have developed alternative plating choices to replace tin/lead plated products. Mill-Max offers its RoHS compliant products with unique identifiable part numbers. However, we strongly recommend customers re-qualify new RoHS compliant product. This must be accomplished where it matters most; in the customers process and in their specific application. We can identify alternative products for customers that choose to re-qualify, and our Technical Services group is committed to helping accomplish this important step in the process. We urge customers to discuss this change with our Technical Services groupand consider the impact to process, function, costs, and availability with great care.

What's next? The European Union continues to review this subject. Additional Directives and revisions could add to the list of restricted substances, and also add to the exemptions as well. This may directly affect equipment manufacturers. Mill-Max will continuously monitor the subject and revise our policies accordingly. If you need more information about your current Mill-Max product or need assistance choosing an alternative to a tin/lead plated product, please contact a Mill-Max RoHS team member. We are here to help.