ELV compliance – Allegro drivers, take note
Vehicle recycling is nothing new, but the REACH EU directive is. The vehicles being scrapped today are incredibly complex, loaded with electronic gadgetry which can no longer be consigned to the landfills; it must be recycled in an environmentally compliant manner. Additionally, new vehicles and their components must be made from materials which obey RoHS and REACH EU legislation. Even if your sole input into a new concept car is some nifty Allegro PCB design work, you must still be aware of what is required by law. There’s no point ordering semiconductors on your Bill of Materials if after they’re installed it’s discovered the lead content is too high. Before you start a PCB layout, it’s vital you triple check the component list to make sure all the components on the manufacturing BOM comply. As well as the RoHS and REACH legislation, there are a whole lot of EU legislations specifically targeted at the automotive industry. These include: the End of Life Vehicle, or ELV directive; the Global Automotive Declarable Substance List, or GADSL; and the International Material Data System, or IMDS. They cross over into areas like WEEE and REACH to some extent, though this hardly helps simplify things. ELV compliance affects both vehicle disposal and vehicle design, since at least 85% of the end product must be safely recyclable, and components and materials, from paint finishes to semiconductors in printed circuit boards, totally REACH and GADSL compliant. This can be complex and time consuming to implement. However, we at Enventure Technologies offer a full range of enterprise data management solutions to the automotive industry, including GADSL, ELV and BOM management.
Reaching ELV compliance in the UK
The RoHS and REACH EU directives have had many spin-offs, such as the End of Life Vehicle, or ELV directive which came into force in January 2006. As part of its structured program of environmental reforms, the EU wants 85% of all scrap vehicle content to be recycled. At present the scheme is around 75% successful; however, it requires a high degree of financial and technological investment to be fully successful. Parts of the ELV directive cross over into other areas, such as WEEE and ROHS compliance. Vehicle recycling is nothing new. Scrap yards have been recycling vehicles for years, mainly on account of the valuable metal content, which accounts for around 75% of the vehicle’s mass. However, vehicles from the 1990s onwards have been very different from those made in previous eras, with FPGA programming and printed circuit board wizardry going hand-in-hand with CAD visualization and computational fluid dynamics. There’s also the manufacturing methods, as plastics and manmade fibres have taken the place of chrome, wood and leather. Although some recycling was done, a lot of vehicle components such as batteries, bulbs, plastics, glass, electric cables, paint finishes and chrome trims ended up in landfill sites. This led to unacceptable levels of mercury, lead, cadmium, hexavalent chromium, and polybrominated biphenyls and diphenyls ending up in the soil; these dangerous chemicals are today targeted by the ROHS directive. When considering all this, the need for an effective recycling strategy becomes obvious. We at Enventure Technologies offer a wide range of manufacturing support solutions to the automotive industry, ranging from reverse engineering to master data management and REACH compliance.
System software for environmental compliance management
The new RoHS and REACH EU directives are making it more important than ever to have clearly defined obsolescence management and data cleansing strategies when planning your engineering projects. Environmental compliance management (ECM) is complex, involving a high degree of component cross-referencing, data cleaning and other tasks related to the Bill of Materials. For this reason many companies invest in specialised system software to help them manage. However, just like 3D modelling, the software can be time consuming and complex to use. There are also a lot of poorly designed packages out there. For this reason, a growing number of companies are outsourcing the work to enterprise data management firms specialising in manufacturing support, like us at Enventure Technologies. Effective, trustworthy environmental compliance solutions enable engineering companies to store data, produce ECM reports, perform component cross reference checks (such as the status of soon-to-be obsolete semiconductors) and manage BOMs. This will enable them to remain REACH and ROHS compliant, at the same time maintaining a smooth onward supply chain to their customers. Environmental compliance solutions should: Enable BOM scrubbing, loading and editing. Simplify data management by storing all relevant documents (Certificates of Compliance, BOMs, full material disclosures etc) in one secure place. Include a component cross reference library listing compliant components. Include a supplier management system that can be linked and cross-referenced to other areas of the system. Include secure data export capabilities. Environmental compliance services like ours use a combination of cutting-edge system software and commonsense to ensure you don’t suffer supply problems or risk prosecution by the RoHS/REACH EU directive.
When WEEE Compliance Can Cause Problems For Hardware Designers
The RoHS WEEE directive specifically forbids the use of lead in electronic components, unless the lead content is 0.1% or lower. This has effectively seen the end of tin lead (SnPb) finishes to a large extent, as component manufacturers switch to non-lead finishes. Some categories – for example, medical instruments and FPGA design for monitoring and control – were exempt. However, these exemption dates are coming to a close, causing headaches for mechanical engineering companies such as medical suppliers and aerospace firms. Many applications are committed to using SnPb components – often, the product lifespan covers decades, rather than years – forming major problems in obsolescence management if component manufacturers suddenly stop making them. It’s not always as easy as switching to a non-lead finish. The impact of using lead-free component technology in the aerospace industry was considered so serious that it led to the formation of the Lead-free in Aerospace Project (LEAP) working group, in partnership with the Aerospace Industries Association Government Electronics and Information Technology Association (GEIA). LEAP is an international group which includes members from both the EU and USA. It includes representatives from the world’s major aircraft and defence contractors, as well as mid-tier component manufacturers and mechanical engineering companies. When you’re building military aircraft, obsolescence management has to be tightly controlled, and the LEAP-WG has been feverishly working since before the RoHS directive was ever introduced, developing guidelines and acceptable lead-free practices for the aerospace industry. With the right obsolescence management tools, you can always be prepared. If you have RoHS/ WEEE worries, we at Enventure Technologies have solutions you can trust.
VHDL Design And The WEEE Directive
Even simple mechanical engineering projects make use of VHDL design now. VHDL stands for VHSIC hardware description language, VHSIC being Very High Speed Integrated Circuitry. Basically, it’s a hardware design language used to describe electronic systems such as FPGAs (field-programmable gate arrays). What does this have to do with RoHS WEEE legislation? Quite a lot as it happens, in so far as your bill of materials and obsolescence management goes. Due to the materials used in their construction, a large number of electronic components have been impacted by REACH and WEEE legislation; not least semiconductors – which are essential to VHDL design. The WEEE directive targets several chemicals commonly used in areas like PCB design and firmware development. These are lead, mercury, cadmium, hexavalent chromium (Cr6+); PBB (Polybrominated biphenyls) and PBDE(Polyprominated diphenyl ether). These are being closely regulated, with a maximum allowable concentration of 1,000 PPM, or 0.1%, under the EU RoHS ruling. Countries outside the EU, such as Canada and the US, do not have federal regulations banning these substances from electronics components yet. However, conscious of the need for environmental compliance – and the need to maintain trading relations with EU countries – they have started introducing restrictions, in particular the use of lead. For example, tin lead (SnPb) was, until recently, a common material in component finishes. However, since 2007, when the RoHS directive came into force, non-lead finishes have been introduced by many component manufacturers, especially those with an international profile. Balancing complex system design work against RoHS directives can be a nightmare. We at Enventure Technologies can help you every step of the way, from obsolescence management to embedded firmware development.
REACHing Across the Divide
Just as component engineering companies had got their heads around the intricacies of RoHS and WEEE legislation, along came the REACH EU directive, the most complex of the European Union laws yet. Much as there is a need for environmental compliance, mechanical design companies are feeling distinctly frazzled at this latest addition to their workload. But they’re in good company. REACH compliance affects everybody in the supply chain: Importers and distributors, who must ensure products from outside the EU comply with the new legislation; component manufacturers, who must recall non-compliant products and develop replacements; downstream users, who must ensure they use only REACH compliant products, and end-users, who must ensure OEMs are obeying the rules, and dispose of non-REACH compliant products correctly. Obsolescence management has never been so important. Initially, the hazardous chemicals listed by the ECHA (European Chemicals Agency) as coming under the REACH directive numbered just 16. This was in June 2008. Currently, the figure stands at over 30,000 – and is rising as more data becomes available. The ECHA has estimated that the high cost of REACH compliance will have at least 2% of the listed chemicals driven off the market, leaving manufacturers to come up with environmentally compliant alternatives to the products incorporating them – or declare those products obsolete. As kinks start to appear in the supply chain, users will be seriously compromised. The good news for electronic and mechanical design companies is that there is plenty of manufacturing support from distributors, component manufacturers – and us at Enventure Technologies. From obsolescence management tools to component engineering services, our high value engineering solutions will ensure you always REACH compliance.
PCN Alerts – A Growing Problem With REACH Regulation
With the dreaded “gang of three” – RoHS, WEEE and REACH compliance – now in full force, obsolescence management systems are going into overdrive, not least in the fields of electronic component engineering and mechanical design. With environmental compliance now central to everything engineering companies do, it’s no wonder they turn so many of the tasks over to us at Enventure Technologies. Obsolescence management comes under the umbrella of enterprise data management, and along with environmental compliance is essential in the engineering workplace. Normally, it takes around three years for components like semiconductors to become obsolete. Until the RoHS and REACH regulations came into force companies could expect a steady trickle of PCN alerts, which were easy to deal with as suppliers invariably held back-stock of obsolete semiconductors and other outdated components in store. That trickle has now become a torrent, with component manufacturers disposing of their “non-green” stocks rather than holding on to them. Some continue to supply obsolete semiconductors containing SnPb (tin-leaded) residues, as certain end-users are not yet subject to RoHS, WEEE or REACH legislation, but these exemptions are slowly being phased out. Responsible engineering firms want to be seen as “green” as possible. In the lead-up to RoHS and REACH legislation being made law, authorized distributors took the role of communicators, creating awareness and offering advice to clients. Now, they have shifted to obsolescence management, offering practical solutions and alternatives to discontinued products. Early communication is essential between end-user and supplier, to minimize disruptions in the supply chain. Our obsolescence management tools play a vital role in this.
Obsolescence Management and REACH Legislation
The REACH directive is an unwanted burden to companies already struggling under the weight of WEEE and ROHS compliance. RoHS/WEEE legislation covers just six main chemicals – more than enough for the average CAD designer or DSP programming engineer. REACH covers thousands more, affecting hardware design companies who were previously RoHS-exempt, as well as those already struggling with the rules. The most complex of the European Union’s environmental rulings to date, the REACH EU legislation has wide-ranging implications on electrical and mechanical design companies. It was established to control the production and use of chemical substances thought to be a risk to health, safety and the environment. So far, comprehensive risk assessments and safety data have been published for 30,000 substances, with many more implicated in the next decade. Obsolescence management was once a straight forward affair. System designers realised that as technology expanded, component engineering would have to follow suit. Generally, they could expect electronic components to be around for about three years before they were out-of-date. So, they happily absorbed each new PCN alert as it came along, relegating obsolete semiconductors to the bin and purchasing better drop-in replacements. However, the new directives have compromised things to the point where firmware development companies despair of giving an effective service to their clients. With RoHS legislation exemptions now expiring, plus the growing REACH directive list, the industry has been hit by a flood of PCN alerts and end-of-life notifications from component suppliers – who are similarly concerned. Thankfully, we at Enventure Technologies offer obsolescence management tools and environmental compliance solutions which are specially tailored for the needs of each customer.
Obsolescence Management – RoHS Directive Exemptions
The Restriction of Hazardous Substances and Waste Electrical and Electronic Equipment (RoHS/WEEE) directives became legally binding in 2006. Although a number of applications were exempt from the rules, the dates for many of these have expired – with more to follow. This has had tremendous repercussions on hardware design companies whose products are dependent upon what are now, effectively, obsolete semiconductors. Obsolescence management is a necessary part of firmware development. As electronic technology advances at an ever increasing rate, so do end-of-life (EOL) dates. On average, semiconductors become obsolete within 3 years of being introduced. Once the product is announced as discontinued, customers have at most a year to find a replacement, or redesign their system so it no longer needs that component – though generally, drop-in replacements are available. However, technological advancement is not the only reason for product change notification. PCN alerts due to pending expiry dates on the RoHS directive exemption list are increasingly of concern. Many aerospace, medical and telecommunication system designs are dependent upon components with a high SnPb (tin-lead) content. Finding alternatives has become a major problem in obsolescence management. There are many ways around the problem. For example, reverse engineering using non-lead derivatives has enabled companies to find replacements for obsolete semiconductors which don’t contravene RoHS legislation. System redevelopment is another option. The main thing is to be prepared – don’t just wait for the EOL date to arrive. We at Enventure Technologies can’t change RoHS directives – but we do have obsolescence management tools to ensure they are of minimum risk to your clients.
The WEEE Problem of Obsolete Semiconductors
Following toxic chemical concerns, the EU RoHS WEEE (Regulation of Hazardous Substances/Waste Electrical and Electronic Equipment) directive became European law in February 2003, with the deadline for full compliance being set at August 2004. The result was thousands of suddenly obsolete semiconductors which had to be replaced with lead-free alternatives. There were six banned chemicals in all, including mercury, cadmium, hexavalent chromium and polybrominated bi and diphenyls. Luckily, a number of component manufacturers were able to supply lead-free products compatible with the obsolete semiconductors being discontinued – often even when the component was not available in lead-free form from the original manufacturer. To soften the blow, many suppliers kept the cost of the lead-free versions the same as the lead-soldered ones, which continued to be sold. Some component engineering companies, for example those producing medical equipment, are currently exempt from RoHS legislation. There was some outcry over the cost of the RoHS WEEE directive from electronics manufacturers, who from August 13, 2005 were financially and physically responsible for WEEE compliance. Under the ruling known as extended producer responsibility, or EPR, manufacturers had to deal with the collection, recycling and recovery of electronics goods which had come to the end of their lives, in an ethical and responsible manner. Since “end of life” often meant the disposal of perfectly serviceable products that failed RoHS standards, it was a double expense, since these products had to be replaced. If you are struggling to comply with all the RoHS, WEEE and REACH directives, we at Enventure Technologies have a number of solutions to help you keep on track – and keep expense to a minimum.