Red. It's the color of passion. It's also the matador's cloth to taunt the bull who, it is said, sees red and charges right into the trap set for him. Hence red is also the color of fury and berserkerdom. When you combine said meaning with the equally charged red tape, the results can be explosive indeed. Or frustrating as hell. For a sample of what US-based electronics manufacturers are about to face -- the below information was kindly forwarded by EveAnna Manley of Manley Labs -- let's dig into EU-style red tape which has previously raised the ire of amp and speaker manufacturers when binding posts had to be fool-proofed with plastic shrouds.

What you're about to read is a reminder missive from a Manley vendor who had just attended "another seminar on ROHS, the EU hazardous material initiative, hosted by the SMTA." Say what? The Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive was passed into law by the European Union (E.U.). It affects manufacturers, sellers, distributors and recyclers of electrical and electronic equipment containing lead, cadmium, mercury, hexavalent chrome, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE). After July 1, 2006 the use of these materials will be banned in new products sold in Europe. The RoHS Directive compliments the WEEE Directive.

The reminder EveAnna received from her vendor and shares with us reads as follows:

1) ROHS applies to lead (Pb), Hg, hex Cr, Cd and PBB/PBDE flame retardants. For our purposes, pb-free means free from all banned substances.
2) The initiative is intended to cover electronic products that could some day end up in a land fill.
3) There are a few exceptions which include:
  • Medical and monitoring equipment (category 8 of WEEE initiative)
  • products intended to protect national security and/or for military
  • spare parts for repair of products put on market prior to 7/1/06
  • telecom equipment
  • defined monitoring and control instruments (defined in category 9 of WEEE initiative, item 9 is listed in Annex 1B of the WEEE directive (2002/96/EC) but is referenced in article 2.1 of the RoHS directive (2002/96/EC)
  • large scale stationary industrial tools (the example provided was a DEK stencil printer vs. a plate glass fabrication machine. The plate glass machine is 400 meters long and clearly "part of the building" whereas the printer is large but not stationary as compared to glass machines. Therefore, mills, CNC machines, automated machinery, welders etc are not exempt)

4) Exemptions need to be approved by EC prior to 9/15/05; however, they are still accepting.
5) Don't expect much help from the EU.
6) Regarding compliance, you will be responsible to "self declare". See IPC 1725.
7) Compliance is further shown by submission of technical documentation which may include and may not be limited to: a certified PB-free BOM, a certified PB-free process, laboratory tear-down analysis results etc.
8) Technically speaking, the bare boards and components will be exposed to higher temperatures. You might want to consider using a high temp laminate such as IS410 instead of FR4. As for PCB finishes, we have the most experience with immersion gold but the costs are a little higher. We are getting some samples of pb-free HASL and will advise on that when we can. July 1, 2006 is only around the corner.

What's this mean? It's clearly a green effort to enhance sustainability and avoid toxic leakage in landfills. If you don't design electronica for built-in obsolescence, having them end up in landfills shouldn't be a real issue but that's a discussion for another day. That the bloody military is exempt is a silent curse for today and every day thereafter (let's make sure our bombs cause maximum damage and poison water supplies in the years to come). That the telecom industry is exempted is probably due to how much money it represents (so is it really about sustainability?). But back on track. The relevant issue today that's facing our audio manufacturers is one of compliance. This means, you gotta understand arcane rules & regs. The issue also is one of large parts inventories presently held by electronics manufacturers which, in a few months, could become outlawed for inclusion in merchandise bound for Europe. It could also affect NOS tubes. That's not a joke by the way. Pity those with large inventories.

This is a subject for which many domestic manufacturers could likely use governmental or state assistance - to offset large financial losses of dumping existing parts inventories; to find replacement parts that satisfy the new regulations; to understand the intricacies of "self declaration" and avoid having shipments confiscated and destroyed. It's merely another example of some of the challenges involved in manufacturing for a global market that is anything but universal in its adoption of standards, tariffs, requirements and legislatures. So next time you see red on some arcane audiophile ripple in the waters, remember that things can get far murkier on the other side - in the manufacturing of the goods we love to obsess about. Lead-free solder just assumed a whole 'nuther meaning, didn't it?