Stakeholder Consultation Questionnaire
2.1 Proposals for additional exemptions
The automotive industry cannot support the removal of the current exemption and request the continued exemption of:
Lead: Entry 8: Solder in electronic circuit boards and other electric
applications
No / Criteria / Justification1 / Please describe the material and/or component of a vehicle that contains the
hazardous substance. / Electrical and electronic components are essential for the production of cars. E.g. electronic control units help to reduce emissions and to increase safety of passenger cars. Therefore the long-termed reliability of such units plays an important role in reducing negative impacts.
Within the automotive industry there are very high demands to electronic components. The demands are similar to the requirements of aeronautic and military equipment.
Up to now these absolute necessary high demands require the use of lead in solder and electrical applications. Lead-free substitutes in many cases have not yet achieved the same level of quality and reliability.
2 / Please indicate the type and quantity of the hazardous substance used in the
material and/or component.
Please indicate the quantity of the substance in absolute numbers and in percentage by weight in homogenous material. / The most common solders are Tin-Lead solders with a lead content between 20 and 40 % lead.
Since the automotive industry/electronic industry is in the process of reducing lead solder applications step by step the amount of lead has been continuously reduced step by step but is still above 60g in some vehicles, depending on the amount of electronic equipment.
For more details please see Ökopol reports I/II [2].
Even if the amount of automotive electronic systems in use is increasing and functionality and complexity are rising, shrinking processes of ECU boards and IC´s as micromechanical devices compensate an increase by weight. So the weight proportion of electronics is nearly constant since several years.
3 / Please indicate the functionality of the substance in the material and/or
component of a vehicle. / The outstanding material properties of lead this lead containing solder alloys like melting point, flexibility, prevention of whisker building and growth and the process behaviour and reliability of the solder joints make these to an ideal material. Especially in areas with high and intensive thermal stress and combined with mechanical vibrations lead containing solders are excellent.
4 / Please provide an estimate of the annual quantities of the hazardous substance used in this particular application. / For more details please see Ökopol reports I/II [2]
5 / Please explain why the elimination or substitution of the hazardous substance is currently technically or scientifically impossible / impracticable. / The experiences in lead free soldering from other industry sectors like consumer electronics can not be simply transferred to automotive applications due to different demands to the product. The safety aspects are very important. See 1.
Especially in areas with high and intensive thermal stress and combined with mechanical vibrations lead containing solders are excellent.
The automotive industry and the supplying industry took the challenge for lead free electrical and electronic components. In some applications lead free components like sensors or switches could be realized in lead-free solder technology. But there is no broad solution yet for assemblies and modules and control units. Lead-free solder substitutes still often intend to embrittle or to fatigue earlier which can cause drop outs up to total failure of an assembly.
During the last years the development of electronic components like resistors capacitors and integrated circuits was in the focus. The target was to qualify electronic components which are able to bear respectively to face the higher temperatures of lead free solder processes. The lead free solder processes need around 25 to 30 degree Kelvin higher temperatures, which cause thermal stress and a reduced life time. Lead-free solder processes consume around 30 % more energy than conventional lead-based solder processes. Fore most of the related components substitutes could have been developed. But life time and reliability demands are in some cases still not on the level of components used for lead containing solder processes.
6 / Please indicate if the negative environmental, health and/or consumer safety impacts caused by substitution are likely to outweigh the environmental, healthand/or consumer safety benefits.
If existing, please refer to relevant studies on negative impacts caused by
substitution. / The most common lead free solder are based on Tin-Silver (Copper, Bismuth) alloys.
The problems/risks of such alloys are (beside the higher process temperatures) fatigue and tin whiskers growth, and possibly causing malfunction of the electronic system. This issues are still a big challenge for these alloys.
Recent cradle to grave assessments done in the US for lead containing solder in comparison with lead free solders missed a significant overall benefit for lead free soldering. Environmental burden of mining processes and higher process temperatures should be considered.
In some special cases lead might be substituted by Indium for technical purposes. Based on a annual global mining production of 445 t /a and a Indium price of around 100 x price of lead the use of Indium is very limited.
It is proposed (and already partly in use) for terminals for heated screens.
Considered under environmental and toxicity aspects Indium does not show advantages in comparison to lead. So Indium might be a problem cruncher for some technical issues but could not be considered as an overall and environmental compatible substitute for lead.
7 / Please indicate if feasible substitutes currently exist on an industrial and/or
commercial scale.
Please indicate the possibilities and/or the status for the development of
substitutes and indicate if these substitutes will be available by the expiry date of the exemption or at a later stage. / In the next step, which is currently in scope of R&D work, the interaction of the single components within an assembly or board is in the scope. Not until assembly and boards for automotive applications produced with lead free solder technologies have proven equivalent reliability and life time expectations a change over from lead to lead-free processes can be taken into account. There are still some imponderabilities, which need to be overcome and forces us to act with caution.
8 / Please indicate if any current restrictions apply to such substitutes.
If yes, please quote the exact title of the appropriate legislation/regulation. / As mentioned above, the toxicological impacts are not yet clear.
It is recommended that EU Commission initiates a comprehensive risk assessment process regarding ecotoxicity and adverse effects in humans of Indium (and other potential substitutes as well) before making any decision for substitution. Alternatively at least it should be waited until the necessary Toxic and environmental toxic data are created during the REACH process. Some toxicological investigations have shown that Indium compounds can create adverse effects regarding health and environment.Expanding usage of Indium shouldnot berecommended until comprehensive data about Indium and Indium compounds are carefully assessed whether it is for health and environment really an improvement.
9 / Please indicate the costs and benefits and advantages and disadvantages of such substitutes.
If existing, please refer to relevant studies on costs and benefits of such substitutes. / The costs of the above mentioned TIn-Silver alloys are 1.3 to 2 times higher compared to Tin-Lead.
In addition to this, the process costs are higher due to the higher melting point, longer processing times.
See also 6.
10 / Please provide any other relevant information that would support your application for an additional exemption. / In particular within the car industry there are many mechatronic systems, which combine mechanical with electrical components. For getting a good electric contact of mechatronics by soldering the mechanical metal components need to have a distinct process temperature range. Otherwise safe production processes can not be ensured. The specific heat capacity of the mechanical components must be considered carefully in order not to cause cold soldering joints or to destroy electronic elements by influence of heat.
There specific demands for these electrical components are established in standard IP JST (JEDEC/ IPC) Joint Standard 0020c. Up to now around 50 to 70% percent of the single electrical components are able to meet the standard, which is a prerequisite for making mechatronic assemblies where additional problems have to be solved like spatial factor of stresses etc. A change over requires that all necessary electric components are capable for lead-free processes.
Sources:
[1] P.T. Vianco, “Solder trends and Pb-free Soldering issues”, Sandia National Laboratories, SMTA information, September 2005
[2] J. Lohse, K. Sander, M. Wirts: Heavy Metals in Vehicles II (Final Report) , p.22 ff ; Ökopol - Institut für Ökologie und Politik GmbH Hamburg July 2001 Report compiled for the Directorate General Environment, Nuclear Safety and Civil Protection of the Commission of the European Communities Contract No B4-3040/2000/300649/MAR/E.3
[3] I. W. Clelland, R.A. Price ITW Pactron leadfree solder study; Lynchburg / Virginia Sept 2005
[4] P. Lange, A. Herenz, J. Diekmann, W. Labod, T. Seubert, “ Bleifreie Automobilelektronik:
Status, Trends & erste Erfahrungen“ ATZ Mai 2006 Sonderausgabe ATZ MTZ extra Systempartners
[5] N.N. Lötverbindungen bleifrei MP Materialprüfung 10/2006 48Jg .483
[6] ZVEI work group „Whisker“, “Recommendations for lead-free plating of electronic components and connectors”, official brochure in preparation for July 2006
[7] M. Dittes, “Board level reliability of tin plated components”, Technical Information of company Infineon, 2005
Assessments done by Tukker, Jansen {1}] as well as by Moll et alt. (see waste topics in eionet) mandated by the EC show that the ecological imprint of passenger cars is dominated of the product use and not by waste issues. {1}A.Tukker, B.Jansen: Environmental Impacts of Products; Journal of Industrial ecology Vol. 10 p 159ff TNO /Delft MIT/Massachusetts 2006
Results of Oekopol I /II study
“…Presently extensive investigations to find lead-free alternatives are carried out by several car manufacturers and suppliers, and replacement of lead is already possible in several application fields. But it has to be considered that there is no universal solution that would be suitable for all cases. Unlike consumer electronics like TV or hifi systems, safety requirements in cars, in combination with temperature and mechanical stress and corrosive conditions, make replacement more problematic.
Lead-free soldering in the automotive industry can only be implemented stepwise.
Experiences from applications with moderate safety demands and ongoing research will lead to transfer of lead-free soldering technology from automotive parts with less adverse conditions (e.g. interior) to those with more demanding requirements.
A total ban of lead containing soldering cannot yet be recommended in the present situation.”
“Technical progress leads to an increasing use of electronic devices in automobiles, some of them under extreme conditions such as strong vibrations and high temperatures (e.g. when applied directly on the engine block) which require solders with a higher melting point….”
Therefore it is proposed to continue the exemption for solder in electronic circuit boards and other electric applications and to have a reassessment in 2010.