
Parliament members added numerous amendments to the documents that are now being resolved in the
Environmental Committee. The year for enactment of the provisions (either 2006 or 2007 at this time) is a major
point of discussion. A second reading and vote will likely occur in the 2001-2002 Parliamentary session. Approval of
the directive proposals by the European Parliament will then require the member states of the EU to establish
national regulations that implement the provisions of the directive in each country.
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Of the substances to be banned by the ROHS directive, Pb is by far the most significant to AMD. Pb is present in
our products in the solder balls on Ball Grid Array (BGA) and Fine-Pitch Ball Grid Array (FBGA) packages, the
external plating on leadframe packages, and the C4 bumps used for flip-chip assembly. The ROHS draft in its
present form will ban such uses, as well as the use of Pb-based solders for board-level assembly of components by
our customers. The proposal includes exemptions to the ban such as:
Pb as an alloying element in steel (<0.3%), aluminum (<0.4%) or copper (<4%);
Pb in electronic ceramic parts (e.g
.
, covers the use of Pb oxide in passive chip components);
Pb in the glass of cathode ray tubes, light bulbs, and fluorescent tubes;
Pb as radiation protection.
The document allows for additional exemptions in the future if the European Commission judges the use of a
material “unavoidable”. While the draft does not now include any specification of allowable threshold concentra-
tions, it does require that “as necessary” the Commission may establish maximum concentration levels for specific
components and materials in the future. The initial allowable levels are left to the member states to determine and
identify in their implementation legislation. The procedures for setting the allowable limits and for defining future
exemptions are not defined.
The WEEE Directive proposal also includes take-back provisions that would affect AMD customers. Manufacturers
and importers must set up systems to collect and treat waste electronic equipment from holders other than private
households, and absorb the costs of collection, treatment, and disposal for private households. Distributors
supplying new products must offer to take back similar equipment. Manufacturers may require that such costs as
are incurred from these take-back provisions be reflected in the prices that they are willing to pay for components.
The WEEE and ROHS Directives are significant because they would affect a market that consists now of 15
member states, 4 associated states, and an unknown number of future EU members. The provisions of the
directive will govern not only products produced in the EU, but also those sold in the EU regardless of origin. Since
the Directives are not yet approved and in force, a major question for AMD is whether the proposed ban on Pb will
remain as written in the final legislation. However, some EU legislation will eventually incorporate Pb bans or
restrictions, or require an end-of-life solution (
i.e.,
removal of Pb at product end of life). The result of the legislation,
in whatever form it finally appears, will be increased pressure to remove Pb entirely from production processes.
Additional bans have been proposed at various national levels. In 1998 Denmark proposed a ban on the import,
sale, and production of most products containing greater than 50 ppm Pb; Pb used in electronic equipment was
exempted until “further notice.” In 1998 and 1999 Sweden and Norway also identified Pb as a material they will
target for further restrictions in the future. The WEEE/ROHS directives would supersede these national bans if they
come into effect.
Other Countries
Most European countries, Japan, and Taiwan have enacted electronic take-back regulations that require
manufacturer recycling or recovery of materials at product end of life. In 1998, the government of Japan published a
Bill on Recycling of Specific Household Appliances, covering such “major” appliances as refrigerators, washing
machines, and televisions. Extension of this regulation to include all electronic appliances has been proposed.
While this type of “take-back” regulation does not explicitly ban the use of Pb, it does mandate the recovery of Pb
contained in the specified home electronics, and is an indirect incentive to Japanese manufacturers to avoid the
use of Pb entirely. A legislative ban on the use of Pb in Japan has been discussed, but it is not clear in what form or
when this might occur.
US initiatives affecting manufacturers of electronics have to date focused on community reporting, recycling, waste
restrictions, and product labeling. In August 1999, the U.S. Environmental Protection Agency (EPA), under the
Emergency Planning and Community Right to Know Act, proposed stricter community reporting requirements for all
industries that use Pb compounds. EPA has labeled Pb a persistent, bioaccumulative and toxic (PBT) chemical
posing a high risk of danger to human health. While present usage reporting thresholds are 25,000 and 10,000