Elv Reach

Status and Development of Substance Restrictions in the European ELV Directive
Dr. Otmar Deubzer Fraunhofer IZM Tel.: 030 46403-157 E-Mail: otmar.deubzer@izm.fraunhofer.de
Dr. Otmar Deubzer Dept. Environmental & Reliability Engineering Fraunhofer IZM
FRAUNHOFER Institute for Reliability and Microintegration
Fraunhofer IZM Facts

Figures 2010
23.1 Mio. turn over 92 % contract research 320 employees (186 full time 134 PhD, trainee)
Locations
Berlin Oberpfaffenhofen Dresden
Director
Prof. Dr. Klaus-Dieter Lang
Material characterisation
Process evaluation
Reliability testing
Failure analysis
Sample production
Training courses
Packaging and Interconnection - from Chip to Application
Role of Fraunhofer IZM in Exemption Reviews

Since 2005 review of ELV and RoHS exemptions for the European Commission together with ko-Institut
Review of Annex II (ELV exemptions) in 2007/2008 Review of solder exemptions (under no. 8)
in 2009/10 in 2011/12
Future Involvement of I/IZM

I/IZM won framework contract Assistance to the Commission on Technological, Socio-Economic and Cost-Benefit Assessments Related to the Implementation and Further Development of EU Waste Legislation I/IZM will review ELV and RoHS exemptions for next 4 years until end of 2015
Exemptions in Annex II ELV Directive
Exemption Rules and Procedures
Substance Restrictions in RoHS and ELV
ELV-RL: End-of-Life of Vehicles

Review of RoHS- and ELV Exemptions

Recommendations
(Reports, published)
Europ. Commission
DG Environment
Stakeholder, Industry (Associations), NGOs, Goverments,
Public StakeholderConsultation (online)
Public Tendering, Contract
Stakeholder Workshops, Individual Communication
External Experts Evaluate Infos

From Recommendation to Exemption

Europ. Commission
DG Environment Draft Exemption
Relevant COM Services
Proposal for Exemption
European Parliament
TAC
Member States
Agreement within 3 Months
TAC does not Agree
COM adopts
Proposal
Council Decides
Ministers of Member States
10
Exemptions
Based on Art. 4 (2) (b) (ii) ELV Directive
Exemption, if the use of restricted substances is unavoidable
Interpretation aligned with RoHS:

Use of a restricted substance unavoidable
if scientifically/technically viable alternatives not available if negative environmental or health impacts of substitution likely to outweigh environmental, health and safety benefits of substitution
Economic arguments no justification for exemptions
11
Principles
No exemption recommendation based on confidential information Periodical review of exemptions No exemption, if someone demonstrably has a solution
Exemptions can be cancelled, if viable alternatives available!
Exemptions are no lean-back option!

12
Compliant Solutions at Different Levels

OEM 1st Tier Supplier Material supplier (e.g. solder manufacturer) claims to have compliant solution (e.g. Bosch) has qualified solution (e.g. BMW) qualifies solution
User must prove that qualification procedures are state of the art and usually applied No special tests just to disqualify the material!
13
Exemption Restrictions and Cancellations

Supplier (e.g. Bosch) has solution
Yes!
Solution (generally) applicable?
No!
Cancellation of exemption after 12-18 months transition period (RoHS), possibly shorter in ELV
Continuation of exemption (with restriction)
14
Environmental Arguments
No exemptions based on intransparent and incomplete Life Cycle Assessments (LCA) (ISO 14040 ff) Higher energy consumption no proof of higher environmental impact
Decision of toxicity vs. impacts of energy consumption beyond reviewers mandate
Recycling good, but no reason for exemptions

Restricted substance must be avoided Exemption only based on exemption criteria
15
Trends and Potential Conflicts

Transformation/specification of exemptions from material specific to application specific exemptions
Example exemption 10 Lead in glass or ceramic [] of components
Drop-in vs. specific substitutes

OEMs and suppliers want drop-in subsitutes Substitutes for specific fields within applications increasing Split and specification of exemptions
16
Trends and Potential Conflicts

Established processes/equipment vs. new one
OEMs and suppliers want to continue using established standard processes and equipment Lead-free materials may require manifold, new processes and new process equipment Socio-economic arguments no base for exemptions
No economic and mass related exemption criteria!
17
Exemptions in RoHS and ELV Same Rules, Different Results
Quelle: Digitaleurope (EICTA) Source: ERA
Lead in Compliant Pin Connectors
RoHS Exemption expires End 2012

ELV Exemption continued (review 2014)
18
Upcoming ELV Exemption Reviews

Review in 2014, probably start in 2013
8 (e) Pb in high-melting point (HMP) solders 8 (f) Pb in compliant pin connector systems 8 (g) Pb in solders [] in integrated circuit flip chip packages 8(h) Pb in solder to attach heat spreaders to the heat sink in power semiconductor assemblies [] 8 (j) Lead in solders for soldering in laminated glazings 10 (d) Lead in the dielectric ceramic materials of capacitors [] in ultrasonic sonar systems
19
Transformation of Exemption 8 (e)

Electrical interconnects (second level)
Thermal interface die attach
Crystal oscillators
Exemption 8 (e) Lead in HMP solders
Possibly reference to type-approval

20
Expiry Types of Exemptions

2015
2016
No use of exemption in vehicles after December 2015
Exemption expiring 31 December 2015
Use in spare parts for vehicles put on market before January 2016
Exemption for use of banned substance in vehicles type approved before January 2016
No use of exemption in vehicles type approved after December 2015
Use of exemption in vehicles type approved before January 2016

21
Upcoming ELV Exemption Reviews

Review in 2015, probably start in 2014
2(c) Al with Pb content up to 0.4 % by weight 3 Cu alloy containing up to 4 % lead by weight 5 Lead in batteries
22
Future Developments
Recast of the ELV Directive
Inofficially announced, no timing fixed yet
Alignment with RoHS 2

Alignment of rules Alignment of exemptions as far as possible
Alignment with other EU policies

For example resource-efficient Europe
23
Essentials of RoHS 2
24
Schedule towards RoHS 2

Start of RoHS recast in autumn 2008 RoHS 2 officially published on 1 July 2011 Enacted on 21 July 2011
25
Periodical Review of Substance Bans
Initiative:
COM
Periodical Review of Annex II
Member States
Dept. Environmental & Reliability Engineering Dr. Otmar Deubzer
Periodical Review of Annex II
COM Adapts Annex II BEFORE 2 July 2014
3 Years
26
Fraunhofer IZM
1 July 2011 Publication of new RoHS Directive in Official Journal
Maximum Validity of Future Exemptions

Publication of Exemption in Official EU Journal
5 Years NEW GENERAL Exemptions (Annex III)
5 Years
Continuation Upon Successful Request
7 Years NEW Exemptions CAT. 8 and 9 (Annex IV)
7 Years
Continuation Upon Successful Request
27
Criteria for Exemptions in RoHS 2

REACh
Exemption does not weaken protection of environment/health from REACh
AND at least ONE of following criteria:

Substitution/Elimination scientifically/technically not prakticable Substitute not reliable Substitution/Elimination more negative for environment, health, safety
2. To be taken into account:

Dr. Otmar Deubzer
Dept. Environmental & Reliability Engineering Fraunhofer IZM
Socioeconomic Effects 28
Availability
Questions around Socioeconomic Effects

Alignment with Annex XVI of REACh Ordinance (socioeconomic analysis)?! Cost, SMEs, competitiveness, jobs, ? Whose cost, jobs, competitiveness? How much cost is ok for avoiding 1 kg of lead? Cost acceptable for big companies, not for SMEs?
29
The Limitation of Availability

Availability
Substitute manufacturable and deliverable within reasonable period of time Reasonable period of time comparable to time for manufacturing/deliverable of restricted substance
Substitute substance available, but not component/product with substitute substance? Inclusion of other availability into technical practicability?
30
Assessment of Expiry Dates

Priority Check
Substitution/Elimination technically/environmentally possible within maximum validity period of exemption?
Second Check
Availability Effects on Innovation Socioeconomic Effects
31
Deadlines for Exemption Requests

Exemption
Expiry Date of Exemption
Request for Continuation - 18 Months -6 Months
COM must decide
Expiry
No Continuation
12-18 Months COM decides
of
Exemption
No Decision
X+12 to18 Months
32
How to Handle the New Rules in RoHS 2?

Formal harmonization of exemption requests (Annex V RoHS 2) I/Fraunhofer IZM set up guideline for applicants for the Commission Interpretation and application of new exemption criteria and of Annex V
33
Harmonized Proof of Conformity in RoHS 2

1. Internal Production Control by manufacturer
(Decision768/2008/EG, Annex II, Module A)
Manufacturer prepares technical documentation
2. Manufacturer fills out EG-Declaration of Conformity

Annex VII new RoHS
3. Manufacturer applies CE label 4. Manufacturer keeps documentation for 10 years

34
Thank You for Your Attention!

Joint International Congress and Exhibition
Taking Green to the Next Level September 9 12, 2012 Berlin, Germany
Program Overview Sun Sept. 9th Tutorials, Get Together Sept. 10th -12th Conference and Exhibition Location Chairman Website
organized by
A Co-Operation of the Worlds Leading Conferences
the Dahlem Cube / Seminaris CampusHotel, Berlin Prof. Dr. Klaus-Dieter Lang Call for Papers see www.egg2012.de
35

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Status and Development of Substance Restrictions in the European ELV Directive

FRAUNHOFER Institute for Reliability and Microintegration

Fraunhofer IZM Facts

Packaging and Interconnection - from Chip to Application

Role of Fraunhofer IZM in Exemption Reviews

Future Involvement of I/IZM

Exemptions in Annex II ELV Directive

Exemption Rules and Procedures

Substance Restrictions in RoHS and ELV

ELV-RL: End-of-Life of Vehicles

Review of RoHS- and ELV Exemptions

Stakeholder, Industry (Associations), NGOs, Goverments,

Public StakeholderConsultation (online)

Public Tendering, Contract

Stakeholder Workshops, Individual Communication

External Experts Evaluate Infos

From Recommendation to Exemption

Relevant COM Services

Proposal for Exemption

Agreement within 3 Months

TAC does not Agree

Interpretation aligned with RoHS:

Economic arguments no justification for exemptions

Exemptions are no lean-back option!

Compliant Solutions at Different Levels

Exemption Restrictions and Cancellations

Solution (generally) applicable?

Continuation of exemption (with restriction)

Recycling good, but no reason for exemptions

Trends and Potential Conflicts

Drop-in vs. specific substitutes

Trends and Potential Conflicts

No economic and mass related exemption criteria!

Exemptions in RoHS and ELV Same Rules, Different Results

Quelle: Digitaleurope (EICTA) Source: ERA

Lead in Compliant Pin Connectors

RoHS Exemption expires End 2012

Upcoming ELV Exemption Reviews

Transformation of Exemption 8 (e)

Exemption 8 (e) Lead in HMP solders

Possibly reference to type-approval

Expiry Types of Exemptions

Exemption expiring 31 December 2015

No use of exemption in vehicles type approved after December 2015

Use of exemption in vehicles type approved before January 2016

Upcoming ELV Exemption Reviews

Alignment with RoHS 2

Alignment with other EU policies

Schedule towards RoHS 2

Periodical Review of Substance Bans

Periodical Review of Annex II

Periodical Review of Annex II

COM Adapts Annex II BEFORE 2 July 2014

1 July 2011 Publication of new RoHS Directive in Official Journal

Maximum Validity of Future Exemptions

5 Years NEW GENERAL Exemptions (Annex III)

Continuation Upon Successful Request

7 Years NEW Exemptions CAT. 8 and 9 (Annex IV)

Continuation Upon Successful Request

Criteria for Exemptions in RoHS 2

AND at least ONE of following criteria:

2. To be taken into account:

Dept. Environmental & Reliability Engineering Fraunhofer IZM