ACEA/JAMA/KAMA/CLEPA/et. al. request the exemption of: Lead in solder of electronic components to electronic circuit boards

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1 No. Criteria 1 Wording of the exemption Scope and expiry date of the exemption Vehicles type approved before 31 December 2015 and spare parts for these vehicles 2 What is the application in which the substance/ compound is used for and what is its specific technical function? Lead in solder for electronic circuit boards used in automotive applications. The function is to fix the electrical/electronic components on the printed wiring board and to ensure optimal electric and thermal conductivity. 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-term reliability of such units plays an important role in reducing negative impacts. Within the automotive industry there are very high demands on electronic components. The demands are similar to the requirements of aeronautic and defence industry equipment. Warranty of reliability, durability and replacement Source: Robert Bosch Up to now these absolute necessary high demands require a very extensive validation and a cautious change over to lead free solder which are required for all electrical applications. It is important to understand that all automotive applications (in-cabin, underhood etc.) are heavily impacted by vibration requiring highly reliable bonding strengths and yield strength characteristics as delivered by the current lead-containing soldering.

2 3 What is the specific (technical) function of the substance/ compound in this application? Lead is reducing the melting point of the solder alloy and thus the energy consumption in the soldering process (environmental aspect). In addition, lead keeps the solder ductile, ensures a reliable bonding, it avoids tin whisker growth which may occur in tin containing layers etc. Lead containing solders are excellent especially in areas with high and intensive thermal stress combined with mechanical vibrations as needed for all automotive applications. The interaction between the thermal expansion and heat conductivity of the material at a sufficient level of electric conductivity on the one hand and temperature range and mechanical stress due to vibration on the other hand is the technical reason why lead is used for soldering in automotive applications. The long term reliability of the soldering is the key. Producers of automobiles are responsible to ensure that the use of their products is safe for citizens worldwide. A failure in electronics may endanger life and health of the driver. Attached are some examples, where such a failure happened. Abstract: A 1998 commercial satellite failure caused by tin whisker induced shorts prompted NASA Goddard Space Flight Center (GSFC) to issue a NASA Advisory (NA-044 and NA-044A) (1,2) to remind the NASA community of the tin whisker phenomenon and the inherent risks associated with the use of pure tin plated components. 4 Please justify why this application falls under the scope of the ELV or the RoHS Directive (e.g. is it a finished product? is it a fixed installation? What category of the WEEE Directive does it belong to?). 5 What is the amount (in absolute number and in percentage by weight) of the substance/compound in: i) the homogeneous material ii) the application Source: The Continuing Dangers of Tin Whiskers and Attempts to Control Them with Conformal Coating Jong S. Kadesch, Orbital Sciences Corporation/NASA Jong.S.Kadesch.1@gsfc.nasa.gov and Jay Brusse QSS Group, Inc./NASA Jay.A.Brusse.1@gsfc.nasa If the same would happen in automotive electronics, it might lead to a failure of the system. This must be securely precluded. Any automotive application falls under the EU ELV directive. As these devices are designed primarily for use in vehicles (such as car radios) ( ) the ELV Directive applies. (Frequently Asked Questions on Directive 2002/95/EC on the Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) and Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE)). In contrast to typical consumer electronics which is lead-free under ROHS regulation the requirements for automotive electronics are significantly more demanding. The automotive applications are not covered by any category of the WEEE directive. i. ) approx % lead in solder for electronic circuit boards ii) In current cars: 1 weight-% lead per electronic circuit board (on the average). The absolute number is varying (double-sided / one-sided electronic circuit boards; size different) (according to Marion Wolf (Uni Erlangen): "Investigations regarding the representative composition of automotive electronics - A study of ZVEI and the Automotive Industry" it is around 0.86%). iii) Current vehicles contain around 1 to 6 kg electronic circuit boards. Based on the average of 3 kg electronic circuit boards per car the total amount is about 480 t/a for EU27 incl. EFTA (16 million cars i.e.

3 and iii) total EU annually for relevant applications? ignoring the current economic downturn - source: ACEA 2007). 6 Please justify your contribution according to Article 4 (2) (b) (ii) ELV or according to Article 5 (1) (b) RoHS Directive whereas: 7 Justification according to technical and scientific progress; 8 Substitution of concerned hazardous substances via materials and components not containing these is technically or scientifically either practicable or impracticable; Not all known alternatives to the Lead in solder of electronic components to electronic circuit boards can be applied for automotive purposes. It is therefore necessary to apply for a timely limited continued exemption for Lead in solder of electronic components to electronic circuit boards in relation to entry 8a) of Annex II to the ELV 2000/53/EC. 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 answer for the first question. Especially as in all automotive applications with high and intensive thermal stress and combined with mechanical vibrations lead containing solders are excellent. Please note that this applies not only to underhood but also to incabin applications. The automotive industry and the supplying industry took the challenge for lead free electrical and electronic components. In individual cases lead free components could be realized in lead-free solder technology. The same application can be affected by different temperature and vibration stress depending for example on the individual vehicle segments. 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. So an intensive testing in the target car is required. 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 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. For 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. The most common lead free solder are based on Tin-Silver (Copper, Bismuth, Antimony) alloys. The problems/risks of such alloys are (beside the higher process temperatures) fatigue, brittleness and possible tin whiskers growth causing malfunction of the electronic system. This brittleness is mainly caused by the addition of alloying elements (being less compatible and having a lower solubility). This can lead to growth of brittle inter-metallic phases in solder. The automotive vibration stress leads in consequence to the malfunction. These issues are still a big challenge for these alloys for automotive applications please note again that temperature as well as vibration stress apply to all automotive applications. Currently none of the lead-free alloys meet the requirements with respect to a similar melting point such as lead

4 containing solders, in combination with a proven reliability. In addition the production capacities are not sufficient available and need high investments. 9 Elimination or substitution of concerned hazardous substances via design changes is technically or scientifically either practicable or impracticable; Lead in soldering on electronic circuit boards cannot be avoided by design changes in automotive applications. The solder can not be replaced by lead free substitutes without changing and approving the whole system (see fig. 2, source ASM). Soldering is the most common method known to provide high reliability in electronic devices operating in an automotive environment. Hard wiring or wire wrapping of components together can be done for very low volume prototypes, but the reliability and durability of this type of assembly is far inferior to soldering and would require significantly greater packaging space. Currently lead bearing solder offers significant advantage in high temperature, high vibration, high humidity environments, with less solder fatigue and essentially no risk of tin whiskers compared to lead-free solder designs. Source: ASM (2005) Complex interaction between material selection, design, manufacturing and use for solder, component and PCB the whole system needs to be adjusted and tested if lead in solder is substituted. 10 Negative environmental, health and/or consumer safety impacts caused by substitution are either likely or unlikely to outweigh environmental, health and/or consumer 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. Also EU-funded Life Cycle Assessment studies showed no environmental benefit for lead-free electronic circuit board designs (see e.g. / International Journal of LCA 12 LCA (5) (2007) the lead-free solder design alternatives showed a slight increase in some environmental impact categories ). Also the University of Tennessee in

5 safety benefits thereof (If existing, please refer to relevant studies on negative or positive impacts caused by substitution). Cooperation with the US EPA identified in their study Solders in electronics: A Life Cycle Assessment the environmental issues lead-free soldering. The same findings made a German LCA-Study according to ISO in 2003 (see attached file). The reasons for similar or sometimes higher environmental impacts of lead-free compared to lead solder solutions are for example: o Higher process temperatures necessary o Generation of alloys as silver and other rare metals requires more energy (e. g. during the mining and smelting process) and their generation is closely linked to lead (i.e. silver generation is also generating lead, Bismuth is generating 9 times amount of lead during processing, ). Depending on the chosen alloy the energy consumption is increased by a factor of up to 350. The Global Warming Potential, and the acidification potential of silver or bismuth containing lead free solders are much higher than of Sn63Pb37 which is normally used (looking at the whole production phase) o A high content of silver in solder pastes has significant influence on the eco-profile of manufacture of solder pastes in all environmental impact categories. Apex Presentation 02April2003.pdf The estimated total amount of lead in solder for electronic circuit boards of about 480 t/a for Europe has no negative impact to the recycling or recovery of ELVs in theory this could be seen as part of the lead needed as a collector metal in copper smelters. Taking into account environmental and recycling aspects an extension of the exemption period of lead in solder for electronic circuit boards wouldn t have negative influence but ensure a safe and feasible transition from lead to leadfree soldering. 11 Please provide sound data/evidence on why substitution / elimination is either practicable or impracticable (e.g. what research has been done, what was the outcome, is there a timeline for possible substitutes, why is the substance and its function in the application indispensable or not, is there available economic data on the possible substitutes, Substitution of lead in solder is starting gradually and requires individual testing. This included some negative test results causing delay in the substitution (e.g. whisker growth in numerous applications). Nevertheless, carmakers with their suppliers already started new developed projects on various applications in lead-free soldering already during the last few years as stated in the road-map already during the last review. However, due to the economic downturn the phase-out time will be rather longer than assumed last year. This will postpone the start of many vehicle related electronic circuit board developments, i.e. the starting point of the months. Or it may interrupt some already started developments. C:\Documents and Settings\wschmi18\My Due to the multitude of applications in vehicles, the long automotive development cycles (5 years however, due to current economic downturn the development times are longer as investments need to be delayed) lead-

6 where relevant, etc.). free electronic circuit boards should be available for new type approved vehicle after This will not include carry-over parts. Another very critical issue in a change-over to lead free is engineering capacity. As qualified electrical engineers are very rare on the labour market, a quick increase of capacities is impossible. So existing staff has to manage the additional workload for change. Especially, if beside regular new products also carry-over parts must be changed, this will bust the capacities at car manufactures and suppliers. 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. However, it should be noted that the main issue for industry is the technical non-feasibility due to lower reliability of alternatives and the limited engineering and manufacturing capacity. 12 Please also indicate if feasible substitutes currently exist in an industrial and/or commercial scale for similar use. 13 Please indicate the possibilities and/or the status for the development of substitutes and indicate if these substitutes were available by 1 July 2003 (ELV) or by 1 July 2006 (RoHS) or at a later stage. 14 Please indicate if any current restrictions apply to such substitutes. If yes, please quote the exact title of the appropriate legislation/regulation. 15 Please indicate benefits / advantages and disadvantages of such substitutes. Similar use for automotive applications would be in the aircraft, defence or space industry. No similar efforts are known from these industries. In July 2003, lead in solder had been completely exempted from the heavy metal ban of the EU ELV directive. The reasons for that exemption are still valid; however, as described above in individual cases lead-free solutions have been developed. Still it is not possible to single out specific subapplications that can be made lead-free for all vehicles as this is very casespecific and testing is required in each case. REACH is covering all substance questions. Substitution of leaded solder by lead-free solder Advantages + lead content in vehicles circuit boards will be reduced to an average content of lead in automotive circuit boards below 0.1 % (Marion Wolf (Uni Erlangen): Study "Investigations regarding the representative composition of automotive electronics - A study of ZVEI and the Automotive Industry" ). This represents on a vehicle level a lead reduction by 0.3% (assuming a lead content 13 kg. Approx 1 % of circuit boards are lead today (see above) with on average 3 kg

7 of circuit boards. This amount of lead equals 30 g, i.e. 0.23% of total vehicle lead will be avoided). Disadvantages - higher energy consumption (and CO2 emissions) for soldering & production of solder and generation of alloy metals, - increase of heavy metals in product (more silver, copper, bismuth, etc.), - high risk of whiskers, - much more efforts for achieving the same reliability in automotive applications, - smaller process windows cause more production scrap and rework activities, - no long term experiences in automotive applications (lifetime >10 years!). Only little experience is available of the behavior of these lead-free solder joints under real field conditions. Investigations in different national (Germany) and also international projects have shown that an accelerated testing with thermal shocks or vibration under temperature leads to different failure mechanisms in the solder joints compared to very slow aging which would better correlate to field conditions. Attendant simulations based on Coffin-Manson or other specific Finite Element-models showed a great variance of lifetime values depending on the used parameters. Therefore an authoritative forecast about the lifetime of solder joints in electronic devices in an automobile isn t possible at this moment. More experiences with solder joint reliability under operating conditions and for automotive lifetimes (>10 years) are necessary for the comparison with results of test conditions and simulations. Examples for investigations showing the great differences between field and test conditions and the resulting different failure mechanisms are described in the final report of the German project LiVe (Material modification of geometrical and substantial limited solder joints in highly integrated electronic devices ISBN ). - insufficient engineering capacities for a quick change-over and testing and qualification in a responsible manner. - reserves to production ratio is worse for the alternative heavy metals (silver, copper, bismuth etc.). 16 Please state whether there are overlapping issues with other relevant legislation such as e.g. the Energy-using Products (EuP) - EuP Directive (2005/32/EC) that should be taken into account. According to Art 1 (3) the EuP directive shall not apply to means of transport for persons or goods. There are also no overlapping issues with the RoHS (see above) or the battery directive.

8 17 If a transition period between the publication of an amended exemption is needed or seems appropriate, please state how long this period should be for the specific application concerned. There are currently up to 80 different Electronic circuit boards in vehicles Each requires specific testing and each manufacturer has various parallel vehicle types with various options containing electronic circuit boards and different requirements. Given the economic downturn it is increasingly difficult to devote engineering and production capacities and investments in an area with limited or doubtful environmental benefits. If in spite of economic and environmental doubts the replacement of lead in solder is nevertheless required the transition period should: o Exempt carry-over parts that are used first on a vehicle type approved before 31 December 2010 when they are also used on the new vehicle type approved after 31 December 2010 without any functional change. o Exempt current vehicles including spare parts. Only apply to new type approved vehicles after 31 st of Dec o Repair of conventional lead soldered electronics requires the same procedures and materials. Otherwise repair fails.