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Electronics Reporting and REC019 Update
Pam Carey
Molex Automotive
Agenda
• Overview / History
• Structure & Use
– Rec019 Requirements
– Legislative-driven Updates
– Steering Committee & Supply Chain Integration
• Conclusions
History ELV
• ELV restricts use of Lead (Pb) in solder
– Exemptions have expired for many applications
– Exemptions as of ELV 8th Revision still include
• 8e High temp, high lead solder for ‘active’ components
• 8f split into 8fa(expired)& 8fb
• 8g semi-conductor connections to flip chips
• 8j laminated glazing for TA vehicles until 1/1/20
History REC019
• Specific rules for companies using REC019 materials and component reporting – Companies must possess underlying compliance data for
each component in the electronic assembly
– Components <5g may use ‘relaxed’ naming & other rules
• Use of application codes to report exemptions – Interpretation Guide available from public IMDS site
– Timing is dependent upon OEM new type approval
History RoHS / REACH
• RoHS restricted use of Pb in solder for electronics 2002
– RoHS exemptions tend to be more product specific rather than covering a whole range of applications.
– RoHS2 NEW SCOPE
• Bringing in new electronics products (ex. Commercial generators) under Category 11 – all other uses
• REACH O5A judgment indicates Article 33 Safe Use communication at individual component level
REC019 Structure & Requirements
• Semi-components with ‘standard’ materials – Used to represent common laminate and ceramics assembly
– Solders and ‘non-standard’ parts report separately
– Companies must have underlying data • Timely compliance statements for all components
• Alternate reporting methods (ex. IPC1752a)
• Public data from verified suppliers
• Test data
• Component rules to aid in transfer of data
REC019 Structure & Requirements
• PCBA published Material Data Sheet types – 22 Material Data Sheets
– Standard – PCBAs with/without leaded ceramic material
– High Component Loads – PCBAs with high percentage of components with/without leaded ceramics
– Hybrids – LTCC Ceramics - with/without leaded ceramics
– Hybrid-ST – Sensors / Power applications
– Specialty – Components, Solders, Ultrasonic Systems
REC019 Structure updates
• Resolved Issues – Solders reported separately with application codes
– Ceramics modified to UVCB (unknown or variable composition)
– Epoxy materials using generic ‘brominated epoxy’
– Silver marked within materials as ‘not used as biocides’
• New or On-going Issues
– When are new application codes required? See IG
Steering Committee & Supply Chain Integration
• IMDS Steering Committee and the REACH TF support the continued use of REC019 for electronics
– ACEA’s REACH TF referenced REC019 data in discussions with ECHA on safe use SVHC communication. Agreed to publish updated AIG alongside the ECHA guidance docs
– IMDS Steering Committee supported use at f2f, May 2017
• Electronics assembly companies aware of approach with mixed usage
Pictures of REC019 Historical and New
Ag in both Metals & Special Metals
Ag potentially present in solder
2016 to 2017 ZVEI entered CM data
Rec 019 / 05A / Reach Article 33 Communication
• Recommendation 019 IS: – A method of meting the 05A obligations in full
– An alternate means of declaring CLSs based on industry expert knowledge
– Simplified method to report many electronic components
– Means of avoiding separate data collection of each article of each complex object within a PCBA
– In line with principle of aggregation in reporting CLSs
Rec 019 / 05A / Reach Article 33 Communication
• Recommendation 019 is NOT: – A way of avoiding 05A obligations
– A proposed exemption to the 05A obligations
– A method to “hide” CL substances present in electronic components