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Feature Articles

RoHS Part I: Machine Vision Tackles RoHS Operational, Business Challenges

by Winn Hardin, Contributing Editor - AIA


Part II of this series will look at the technical challenges posed by RoHS regulations.

Restrictions on Hazardous
Substances (RoHS)

Regional Deadlines:
European Union (July 1, 2006);
Japan ([J-MOSS] July 1, 2006);
California (January 1, 2007);
China (March 1, 2007);
Korea (July 1, 2007);
more U.S. states to follow.

Restricted Substances:
Lead (Pb);
Mercury (Hg);
Hexavalent Chromium (Cr(VI));
Cadmium (Cd);
Polybrominated Biphenyl Flame
     Retardants (PBB);
Polybrominated Diphenyl Ether
     flame retardants (PBDE).

Maximum Concentrations:
0.1 weight/percent of lead, mercury,
    hexavalent chromium, PBB and PBDE;
0.01 weight percent cadmium in
     homogeneous materials.

Homogenous Material:
A single substance such as the PVC insulation
on insulated copper wire. Components such
as capacitors, transistors and semiconductor
packages are not “materials” but contain
several different materials.

Relevant Products:
Varies, but most concentrate on electrical and
electronic equipment below 1000 W. The EU
RoHS, which is the basis for other regulations,
applies to: large/small household appliances; IT
and telecom equipment (servers exempt until
2010); consumer equipment; lighting and light
bulbs; electrical and electronic tools, except
large industrial machinery; toys, leisure and
sports equipment; automatic dispensers.

Excluded Products:
Medical and Military.

Additional Exemptions (EU RoHS):
Lead: In high melting point solders;
In glass of CRTs, fluorescent tubes
     and electronic components;
In electronic ceramic parts;
In certain alloys at limited concentrations;
In solders for servers, storage and storage
     arrays and telecommunications network
     infrastructure equipment.

Mercury: In fluorescent and other lamps.

Cadmium: Plating except where banned by
     directive 91/338/EEC (Cadmium Directive).

Hexavalent chromium: Carbon steel cooling
     systems for absorption refrigerators.


With the exception of the microchip, few events will impact the electronics industry as much as global regulations related to the Restriction of Hazardous Substances (RoHS). Environmental health is at the core of RoHS. The regulations hope to limit the amount of toxic material leaking into the environment from landfills around the world caused by a growing body of interred electronic equipment.

Like the larger electronics industry, the machine vision industry is trying to find its way in an RoHS world – a world governed by a global electronics supply chain, but battered by disparate regional environmental regulations. Although most in the machine vision industry are at least partially familiar with RoHS, this article will take a snapshot of the evolving RoHS global landscape, and look at how machine vision companies are using different methods to make their products more environmentally friendly while still operating a successful business.

Regional Confusion
Using more environmentally safe materials in electronics manufacture presents several technical challenges, but RoHS also poses some very significant business challenges too, most related to one question: does the vision supplier go 100% RoHS compliant, or support multiple product lines and endure the supply chain headaches that it creates by trying to serve all applications in all regions based on their particular regulatory requirements?
Addressing diverse regional regulatory requirements is a highly complex endeavor. The European Union (EU) RoHS directive, which grew out of the EU's Waste and Electronic Equipment directive (WEEE), excludes electronics made for military and medical equipment. At the same time, Japan's RoHS regulations only require companies to declare hazardous content levels, but for up to 24 hazardous chemicals instead of the EU's six restricted materials. China takes a different course. Instead of exempting a few industries, China will publish a catalog of equipment covered under its RoHS regulations, while Korea closely follows the EU RoHS example. The U.S. muddies the waters further, as a patchwork of states are adopting or proposing differing RoHS regulations. Leading the way, California’s RoHS regulation takes a lead from Europe, prohibiting EU banned goods, but only consumer goods, not industrial. Finally, the U.S. Department of Defense is taking its direction from a report from the U.S. Air Force saying that technical issues common to high-melting point, low-lead solders among other issues preclude the use of RoHS components in military systems.

Compliant, Non-Compliant, and In Between
So how does a company adapt its supply chain and operations in an absence of global RoHS guidance? Historically, market leaders in the electronics industry chose the lowest common denominator when trying to comply with varying global regulations like RoHS. Large electronics companies that sell product worldwide roll all related government regulations into a single regulation that summarizes the toughest limits, and then they set that as the base standard. This allows companies to operate under a single set of rules regardless of where the facility is located globally, or which markets they sell to. By manufacturing to a single standard, the company can maximize raw material purchasing and similar activities that benefit from economies of scale.
In the machine vision industry, Cognex Corporation (Natick, Massachusetts) officials say they have converted many products to meet the directive, and all new products are designed and manufactured to be compliant, according to Cognex's public relations manager, John Lewis. Cognex does not intend to support two product lines (RoHS compliant and non-compliant). Instead, the company is dedicated to producing new product lines that are RoHS compliant and that perform to the same specification as previous non-compliant product lines. "The strategy is to put the customer first by responding to their schedules and RoHS choices, while converting products to meet the EU RoHS directive at the earliest possible time and delivering the best quality product," Lewis explained. 

JAI Inc. (San Jose, California) has taken a different approach. JAI is taking advantage of the RoHS issue to unify multiple brands owned by the company into a single JAI product portfolio. Initially, JAI has designed all its cameras and vision product offerings to be RoHS compliant as of July 1, 2006, with the exception of the PULNiX line. JAI has tasked the PULNiX line, which is manufactured in North America, to include both RoHS and non-RoHS compliant models – mainly because the bulk of customers buying machine vision that do not have national RoHS regulations are in the U.S.

 ‘‘The PULNiX line of JAI cameras sells about 30% of its units into the defense industry in North America,’‘ says Steve Kinney, Product Manager at JAI Inc. ‘‘We basically have 3 types of customers: RoHS, non-RoHS, and the 'I don't care, but don't change my product' group. So for those end users that want the traditional version, we use TM or TMC product designations (monochrome or color). For users who want RoHS versions of PULNiX products, either in North America or elsewhere in the world, we have separate versions designated RM or RMC for RoHS compliant product. Unfortunately, the end result is that we as the manufacturer have two product lines, with two naming systems and product line numbers, two bills of materials…two of everything.’‘

Divided Markets, Unified Answers
Regardless of whether a vision company goes 100% RoHS compliant, ignores RoHS because they sell mainly into North America or exempted industries, or are somewhere in between, there are external factors that make black and white decisions difficult.
‘‘People use our products for a long period of time after we put them on the market,’‘ explains Daniel Vuk, Matrox Imaging's (Dorval, Quebec, Canada) Engineering Hardware Manager. ‘‘Customers require that we continue to ship the identical component for the life of the customer's product. With the RoHS transition, we saw a lot of component suppliers take advantage of RoHS to discontinue a lot of older components that we designed into our products years ago and for which the supplier didn't see a lot of volume in the future. When we aren’t able to obtain a supply of (retired) components, we make every effort to come up with a solution that is completely transparent from the customer's point of view.’‘ 

This brings up the question of 'due diligence', a legal term meaning that any electronics manufacturer has tried all 'reasonable' efforts to make sure that RoHS compliant products have restricted substance values lower than governing regulations. Due diligence is different for different parts of the electronics supply chain. Although a system manufacturer is just as responsible for the high-lead solder board as the supplier that sold the OEM the board, their responsibilities differ. The OEM is considered safe if they have reason to believe the supplier is telling the truth and submitting the correct documentation along with the component. The component supplier, however, must use testing systems such as x-ray crystallography to determine the exact amount of restricted substances in a homogenous material and document RoHS compliance accordingly.

Transparency from the customer's and integrator's points of view is the driving RoHS theme, but is it really achievable? Industrial customers are very specific about long-term support of existing product lines, but even small changes can lead to additional non-recurring engineering (NRE) costs to the customer and integrator.

 Ultimately, each machine vision vendor has to ask the question: will I try to support two product lines and keep everyone happy, or transition all products to RoHS compliancy? The answer is a combination of demands from key industries, regional governments, and what is technically feasible while still being cost effective. For instance, although the U.S. defense industry is fighting RoHS, their procurement personnel know that they cannot afford to maintain a captive electronics market. In Part II of the Automated Imaging Association's RoHS series, market leaders will discuss the technical challenges caused by RoHS regulation and the various ways and means to adapt their processes to meet regulatory approval and differing customer needs.









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