Lead-free implementation

Unit 2: The legislative framework


Working towards Assignment 1

In Assessment 1, which you will find at this link, you are asked to analyse the impact of current and impending legislation on the products and services offered by Advanced Manufacturing Services (AMS), as described at the scenario. You may find it helpful to make some notes on the wide range of AMS’s activities before studying Unit 2; this will enable you to draw conclusions as to the implications for AMS and its customers as you learn from the unit more about the challenges and uncertainties.

Note that the scenario is quite detailed, and benefits from careful reading and note-taking – we find mind maps useful for this kind of activity.

Elements of the legislation

You might have noticed that one of the video clips in Unit 1 refers to the impending legislation as being introduced in 2004, a prediction which evidently didn’t come to pass! This is because of much of the legislation has been bitterly resisted, and many compromises have been made during protracted discussions. But we have now a firm date of 1st July 2006 for legislation within the European Community. Because this is a primary influence, we would like you to familiarise yourself with the documents, and reach your conclusion as to how they fit together before reading further.

Research topic

What Community legislation is influencing lead-free in Europe?
How do the elements of the legislation fit together?

Resource Link(s) Notes

On DTI's Sustainable Development and Environment web site, take the link to WEEE. Section 6 has a brief summary of the legislation. Bookmark that page as a resource to explore in later searches.

SAMC presentation
on lead-free (2003)


Solectron presentation
Lead-free production (2004)

the first few slides describe the legislation – we will return to the rest of the presentation in later Units

Look in detail at the EC documents themselves (there are links in Section 8 of the DTI page you bookmarked earlier)

show solution

Last revised 17 June 2004

The key items of legislation that affect the electronics industry are the two EC Directives described in the solution. Note that they have a different basis within the EC rules:

Note also that the RoHS Directive refers to the WEEE Directive, in particular to the Annex that describes the products to which the legislation applies. However, the schedule is slightly different in the two cases, and the restriction on the use of lead applies only to certain categories of product. However, these categories cover the vast bulk of commercial production for consumer and professional purposes – the exceptions are primarily critical applications, where long-life products are made in small numbers.

We have deliberately pointed you at the primary legislation, but there are a number of web sites where you get both legislation and some ‘spin’ on it. You will come across some of these in subsequent research.

[back to top]


UK implementation

European legislation is binding throughout the Community, the aim being to provide a “level playing field” for all producers, ensuring that there are no unfair barriers to trade. Yet one’s feeling in everyday life is that sometimes the dice are loaded against certain countries, in particular those that take a more rigorous view of legislation than others. To examine whether this might become true over lead-free, we need to look at how the legislation is being implemented and enforced in the UK and elsewhere.

Research topic

How and when is the legislation being implemented in the UK?

How is the legislation being enforced in the UK?

What are the penalties for non-compliance?

Are different countries doing things differently?

Resource Link(s) Notes

Look at the timeline and activities in Section 7 of the DTI page you bookmarked earlier.

Read the summary at Farnell's lead-free RoHS & WEEE information pages

Read more detail in the DTI booklet A guide to the marketing, product development and manufacturing actions you need to take [You need to register (free) at the Envirowise site]

Examine the timeline that is part of Kay Nimmo's 2003 review of lead-free implementation road maps

Dionics presentation on RoHS from a component perspective (2004)

Look out for references to "Am I implicated?" and "Does RoHS apply?"

Read the consultants' report on existing WEEE-related measures and transposition plans under development in other Member States

show solution

Last revised 17 June 2004.

We hope that you will have uncovered more than our simple explanation above, more decisions and amendments having been made in the interim!

[back to top]

Scope of the legislation

So what exactly do the Directives cover? Here we are talking specifically about lead-free, although of course the RoHS Directive also bans five other materials.

Research topic

Which areas of the industry are affected by the lead-free legislation?
Which areas of the industry are not covered by the legislation?

Resource Link(s) Notes

Search UK web sites for "RoHS Directive" +exemption (<100 hits)

interview with
Joe Felty (2003)

To view the video a Real media player is required.
Click here to download a free version of Real Player 10.

show solution

Last revised 17 June 2004.

[back to top]

Potential changes in the legislation

The timing of the implementation of legislation in the UK means that change is ongoing as this module is being prepared. However, at some stage in the near future the legislation will be “firmed up”, although the nature of recent legislation leads one to expect that its format will be enabling legislation plus a series of Statutory Instruments that will allow significant amendments to be made.

However, electronics is not a static industry, and there are many areas already within the legislation that are likely to be debated and decided upon in years to come. The question is, how are these changes to be made, so that the legislative framework is kept up-to-date?

Research topic

What (if any) are the areas of uncertainty relating to

What are the mechanisms for modification (if any) within the legislation?

Resource Link(s) Notes

Visit Electronics Weekly, and search for "RoHS" for news stories arranged most recent first. There are some gems on 25 February 2004 and 16 June 2004!

Familiarise yourself with the excellent news abstract service on the Soldertec web site (Go to Lead-Free Information, News, News Archive). What issues have been most in evidence in recent months?

Look at the March 2004 presentation by Eamon O’Keeffe (Sanmina-SCI) Lead-Free Technology – Supply Chain Issues

Look at the March 2004 presentation by Michelle O'Neill (Honeywell) EU lead ban status

Browse for adaptation issues at Pb-free.org

show solution

Last revised 17 June 2004

[back to top]

Other Community legislation

So far we have looked primarily at lead-free, although inevitably at its context with the WEEE Directive. But this is not the only legislation that affects our industry, or can be expected to do so in the future.


Research topic

What other Community legislation affects the electronics industry?
What potential Community legislation might affect the electronics industry?
Resource Link(s) Notes

Search for "environmental legislation" +"Electronics industry" – try filtering out terms such as WEEE in order to reduce the number of entries

Read Dorothy Maxwell’s article from Environment & Energy Management

Try the exhaustive (exhausting!) list Electronics Sector: Relevant Legislation/Regulations on the Envirowise site

show solution

Last revised 17 June 2004

[back to top]

Wider legislation

As we indicated in Unit 1, environmental legislation generally is tending towards an integrated holistic approach, emphasising the need for a producer to take responsibility for the environmental impact of the products he makes and of the processes and facilities used in manufacture and distribution. Directives affecting the industry include (“but are not necessarily limited to”, as it says in insurance fine print) the use of energy and IIP – more short documents at the links.

The Envirowise web site has a useful resource on compliance with wider legislation – GG427 Sustainable design of electrical and electronic products to control costs and comply with legislation. Notice that the title emphasises the fact that being environmental responsible doesn't inevitably cost more!

Before you leave this topic, we would like you to take a sideways look at eco-design by following this link to http://www.pre.nl/eco-design/ecodesign.htm. Hopefully this will reinforce the need for life cycle thinking, and at the same time stimulate you to use some methods, however, simple, to assess environmental effects. We particularly like the idea of the materials, energy, toxicity (MET) matrix as a simple tool.

The electronics industry is also affected, albeit at one remove, by legislation that affects its customers. A key example of this is the automotive industry, whose products are affected by the End-of-Life Vehicles (ELV) Directive. This sets what is in some ways an easier-to-understand requirement concerning the lead content, which is that each product should be clearly associated with a statement of the weight of lead within it. Whilst this is not the same as banning lead, the car-wide allowable maximum of 60g of lead implies that substantial use has to be made of lead-free technology, where this is available. Whilst the producer is able to incorporate more lead, this is only at the expense of having to identify those elements of the car that will need to be removed for separate recycling.

Finally, there is the question of how environmental issues are managed within a company. You will have seen this mentioned in Dorothy Maxwell’s article. A typical solution to the challenge is to set up an Environmental Management System (EMS) similar to that used for managing quality. As you might expect, there is an international standard for this, ISO 14001. An outline of how the ISO 14000 series of standards work is available at this link.

Note: There is no substitute for skim-reading (if not printing) the texts of this kind of document. AMI students are able to download PDF files of most current BSI materials at http://bsonline.techindex.co.uk/. To access this site you must set your browser to accept cookies and to enable JavaScript. You will also need an Athens username and password if you were not issued with one automatically when you matriculated. Send your request by email to Steve Crimes: he needs your first and last name, your full email address and your student ID card number. When an account has been set up for you, you will receive details by email.

ISO 14001 started by being substantially different from ISO 9001, its quality counterpart, but increasingly the standards (and that for Heath and Safety Management) are converging. All emphasise properly controlled activities, with regular audit and corrective action to improve performance. It is not surprising therefore that there are continuing pressures to simplify and combine the (expensive) processes of registration and demonstration of compliance to an external auditor.

[back to top]

Lead-free world-wide

Whilst the main driver in lead-free is currently the European Community RoHS Directive, the USA was the first country where the issue was raised in the legislature, and Japan has been the country where the electronics industry has made the most progress towards lead-free, so what is the worldwide perspective on lead-free?

Research topic

What is the legal framework affecting lead-free in the USA, Japan and China?
What is the general lead-free situation elsewhere in the world?
How does the lead-free situation in Europe compare with other countries?
What can we learn from the experience of others?
Resource Link(s) Notes

For a turn-of-the century perspective that still has much validity, read Ning-Cheng Lee's Lead-Free Soldering – Where The World Is Going. Other articles on this Pb-free.com site cover the China market.

Read the article Environmentally conscious electronics: A trend driven by global regulations and aggressive marketing strategies by Holly Evans and Ron Gedney that appeared in Advanced Packaging in 2001. For a more recent view from the same magazine, read John Lau and Katrina Liu's Global Trends in Lead-free Soldering. [You may need to register (free) at the site]

Read the Dec 2003 paper by Jennifer Shepherd (Solectron) Business Implications of Compliance with Emerging Environmental Regulations in the Electronics Industry

At Soldertec, browse for Lead-free information/Legislation [note that only registered students can get access to the whole of the site material]

Browse the national equivalents of the Environmental Protection Agency, for example in Denmark, Germany, Ireland, and the USA. There is a wider selection of agencies on this OECD list.

ITRI presentation on road mapping (2003)


JEITA 2002 road map


interview with
Malcolm Warwick (1999)

To view the video a Real media player is required.
Click here to download a free version of Real Player 10.

interview with
Jim Vincent (2000)

To view the video a Real media player is required.
Click here to download a free version of Real Player 10.

show solution

Last revised 17 June 2004

The solution above doesn't really comment on what we can learn from the experience of others, but we hope that it is clear that going lead-free is an activity where you will not be the first, so you can learn from those who went before. Also, the infrastructure is better in place, with increasing information available for suppliers. Finally, the manufacturing community is becoming more supportive and less protective of any competitive advantage.

[back to top]

Timelines for implementation

The Japanese industry first presented a lead-free roadmap in January 1998, when major electronics companies declared their own intentions to reduce lead use substantially within a year or two and to eliminate all lead from major products by 2001. Panasonic took the lead in marketing products as lead-free and ‘Produced for the Environment’: their first lead-free mini-disc player, launched in October 1998, gained 11% market share on release.

Progress was not as fast as anticipated, and the July 2002 plan was for the total abolition of lead solder on the following schedule:

Hitachi, Toshiba, Fujitsu
Sony, Mitsubishi
NEC (including procured components)
by end of FY2002
by end of FY2003
by end of FY2004
by end of FY2005

The Panasonic experience described earlier is one example of a timeline for lead-free implementation, but not everyone will have the same experience, and one suspects that for many smaller companies the timeline has not yet started. Before we start looking at the detail of implementing lead-free in Unit 3, we would ask you to carry out a final search.


Search the Web for "lead-free" +"time-line"

What conclusions can you draw about:


We haven't presented a solution here, because the situation changes substantially with time, but the general situation is much as shown in this Cookson presentation. The difficulty is that time-lines are indicative, and they always seem to slip. Look at the early slides in the SAMC presentation that was created in June 2003. Action needed to be taken a year ago! Which is why we need to get our act together and start looking at the options as we move into Unit 3.

[back to top]