Recently, I have had a number of conversations with EMS companies and solder suppliers regarding RoHS implementation. They all the say the same thing — the number of customers actually implementing lead-free is, at best, around 30 to 35 percent.

This can be further broken down into most of the tier-one CEMs who have been practicing it for some time, but the tier-two and tier-three EMS companies are waiting to be customer-driven toward compliance. There are even some mythological rumors circulating that RoHS has been scrapped, or is about to be.

The truth is that RoHS came into law in Europe on July 1, 2006, and unless you are in an exempt category (and there is even some confusion around what exactly constitutes exempt), if you are not producing lead-free electronics assemblies, then you are breaking the law.

So why are so many manufacturers adopting such a laissez faire attitude toward implementing lead-free? The answer is “enforcement” or lack of it. Each member state, or in the case of Germany each regional state, is responsible for enforcing compliance of the Brussels directive within their territory.

In the UK, this responsibility was passed to the weights and measures department. After a little research, I managed to contact the head of this department and I quizzed him on how he was planning to enforce the directive. His initial response was “We have been instructed to adopt a softly-softly approach.” When I enquired exactly what he meant by that, he said, “We are going to put a lot of information on our Web site.”

The short answer, therefore, is that they are going to do nothing of any consequence to monitor and enforce lead-free manufacturing in the United Kingdom. To a greater or lesser degree, this is the attitude of authorities across the European Union. Whether you agree with lead-free or not, this behaviour by national and local government departments is irresponsible because it raises the costs and lowers the competitiveness of companies that comply with the EU directive, while leaving the door wide open for abuse by corner-cutting, less scrupulous manufacturers.

However, help may be on the horizon. China will implement China RoHS in the near future and much may depend on the Chinese government methods and levels of enforcement. If they enforce the rules strictly, this will drive many of the manufacturers in Europe to go lead-free quicker. China RoHS is stricter than its European counterpart because it includes at least six more banned metals.

Another driver will be the cost of lead-free components and materials. Already the prices are tumbling to levels equivalent with SnPb prices, but as lead-free components and materials increase, many manufacturers (even those in exempt categories) will be driven to use lead-free because the laws of supply and demand make them cheaper.

Finally, my personal opinion is that this all links into the other major problem in our industry, which is contraband components. According to a recent report published by The Boeing Corporation, as much as 15 percent of their goods-inward is contraband, i.e., “it is not what it says it is on the tin.” This is a serious and growing issue. There is an urgent need for some form of compliance testing that confirms that components are not only lead-free, but genuine parts. An in-line XRF tester, linked to supply chain software providing full traceability? Who knows? One thing is for sure. Until legislators or industry provide a solution, our planes, cars and even medical devices, will not be as safe and reliable as they need to be.