28 Sep 2005
Photonics firms are busy preparing for a suite of new environmental regulations drawn up by the European Commission. Oliver Graydon spoke to Kay Stegmann at Thorlabs about the directives and their consequences.
Two new regulations governing the disposal and manufacture of consumer electronics products are currently being rolled out across the European Community. The first of these, dubbed "Waste Electrical and Electronic Equipment" or WEEE, came into play in August and enforces an environmentally responsible way of disposing of unwanted equipment. The second directive, "Restriction of Hazardous Substances" or RoHS, bans the use of several toxic substances, such as lead solder, inside products and it becomes active next year.
Although the directives are firmly targeted at consumer applications, they are having an impact on the photonics industry as many large manufacturers of scientific equipment are also deciding to implement them. One company that is taking the directives very seriously and working hard to implement them, is Thorlabs. Oliver Graydon spoke to Kay Stegmann, compliance manager at Thorlab's German office in Karlsfeld, about the standards and their consequences.
What is RoHS? It is a directive of the European Commission and stands for Restriction of Hazardous Substances. It becomes valid from 1 July 2006 and bans six commonly used substances in electronic apparatus. Those substances are lead, mercury, hexavalent chromium, polybrominated biphenyl (PBB), polybrominated diphenyl ether (PBDE) (all banned to 0.1%) and cadmium (banned to 0.01%). The percentage is by weight in a homogeneous material, such as a solder connection, a plastic holder or even just the antireflection coating of an optical glass.
Most important is lead because of its use in solder, while chromium and cadmium are used for surface finishing, such as in rust-protection coatings. PBB and PBDE are used in plastics as flame-retardant materials.
RoHS covers electrical and electronic apparatus, divided into 10 groups. Two groups are excluded: group 8, medical equipment, and group 9, control and measurement equipment. This directive covers complete units - in other words, standalone apparatus that is driven by electricity.
OEM parts and components are not directly covered by the directive. Thus you are able to use something containing banned substances in your laboratory for, say, research purposes but you must not put it into a piece of electronic equipment that is to be sold. The idea behind this is to avoid the need to publish a complete list of components because that would become enormous. It is up to the manufacturer of the equipment to make sure that all components used in the product are compliant.
Regarding RoHS it is interesting that in the rest of the world you can find similar regulations. For example, Japan has a voluntary programme on lead reduction. South Korea has a voluntary programme on RoHS aimed at export activities. China is adapting an exact copy of RoHS for domestic purposes. In the US it is currently a piecemeal, state-by-state scheme. For example, California is implementing a light version of RoHS but there is no large national initiative.
What is WEEE?
This stands for Waste Electrical and Electronic Equipment. It is another European Commission initiative and covers waste recovery. It came into force on 13 August 2005 but some countries, like the UK, are implementing the scheme later owing to their national laws.
WEEE covers all of the equipment that is described in RoHS but includes medical equipment, and control and test equipment. The directive states that equipment sold to a user in the European Community after 12 August this year must be taken back by the manufacturer at the end of its life. This is valid in all countries of the EC.
In addition, some countries also require a like-for-like exchange scheme where, if we supplied a customer with a new product as a replacement for a piece of equipment that s/he bought some time ago from any manufacturer, we would be obliged to take back the old product. This like-for-like rule exists in the UK but not in Germany.
WEEE is relatively difficult and expensive for producers of consumer equipment because of the volumes involved and the need to participate in the country's public waste-collection system. For business to business products - as it is the case for most of the photonics industry - WEEE is much easier to handle. An offer to the end user to take back any end-of-life equipment without incurring costs is normally enough.
The company that sells the product in the European Community, be it a direct manufacturer or a distributor, will be responsible for compliance with RoHS and WEEE.
With WEEE there is one pending problem and that's remote selling across borders, such as via the Internet. WEEE only obliges the manufacturer to take back the unit if s/he has a local office or distributor in the customer's country. If there is no local presence there is no take-back obligation and the responsibility is passed on to the end user to dispose of it by the correct means. I expect that there will be some changes to the directive in the future to close this loophole.
What impact are these directives having on photonics? In terms of RoHS, because nearly everything that is used in the photonics lab is either a component or test and measurement equipment, most items are legally exempt at the moment. This means that there is no, or very little, obligation for the photonics industry. Only consumer products like cameras or projectors are covered. However, we at Thorlabs are aware of the increasing environmental responsibilities and the needs of the market. Our policy is to change to RoHS compliance wherever it is possible. Only if it's very difficult or impossible for a specialized product will we not make the change. As WEEE only covers electronic products, the impact on the photonics industry should be relatively small.
How has Thorlabs dealt with RoHS and WEEE?
We check every single component for RoHS compliance. It's a big job because we have about 10,000 products in our catalogue.
As for the changeover, we handle our stock very carefully to prevent creating a mixture of RoHS and non-RoHS parts. If necessary we make a redesign as components might disappear and a RoHS-compliant replacement may not exist.
For WEEE we offer the take-back-and-exchange scheme for all of our electronic products. This will be offered everywhere in the EC and it is up to customers whether or not they want to make use of it.
Are RoHS compliant components and products readily available?
My general impression of the current electronics market is that the availability of RoHS-compliant parts is less than 50%.
We as a manufacturer of products want to have compliant components as soon as possible. There is still a way to go until we will get full supply of RoHS-compliant components for our production. However, the situation is getting better every day and I think that the availability of these components should approach 100% by the end of the first quarter of next year.
Which products are the hardest to make RoHS compliant?
There are some optics that contain lead glass. Discussions about whether or not these parts should be exempt from RoHS are ongoing, given that lead is completely contained and cannot leach out, but there is no decision yet in sight. Today, to my knowledge, there is no alternative to lead that gives the equivalent optical properties.
Another example where you might have problems is if you use a special component normally produced for an exempted area, such as military or medical electronics. In this case it is probably unlikely that a replacement RoHS-compliant part will become available for non-exempt applications.
Is the photonics industry ready for RoHS?
From the legal point of view, the photonics industry will be ready in time as many of the products are exempt. However, if you do want to purchase RoHS-compliant products they may not be available from everyone. Many small companies may decide not to react to the directives, while some US firms may ignore them completely.
Do you think that the regulations will result in price rises?
Regarding Thorlabs, WEEE and RoHS will have no influence on the prices; the slightly higher costs in production will be covered by other measures. Regarding the photonics industry in general, RoHS and WEEE might have some effect, with a few products temporarily being more expensive. Take lead-free soldering: it may be 5-15% more expensive but it's just a small part of a product's overall cost. Managing the change to RoHS leads to additional costs for the equipment manufacturers in photonics. The question is whether or not will they pass the costs on to their customers. Some will, some won't.