Concern for Counterfeit RoHS Compliant Components

Comments (add your comment)

1. Don Ballard:

   XRF can (but, not always) show that a component is in violation, it cannot show compliance. You are speaking more of handheld XRF hardware? What about the desk top applications that provide a more detailed analysis? Thanks!!

2. Mike K:

   Counterfeiting is going to really be a problem with RoHS. I have already heard reports of counterfeit lead-free solder in China! Used to be that buying counterfeit parts put you in production, quality, or reliability jeopardy; now it might put you in legal jeopardy...we're dealing with a whole new set of requirements, folks. Anyone that buys through the broker market and must maintain compliance has to demand the pedigree of the parts they're buying, determine whether they believe that pedigree, then test. XRF (be careful of the hand-held variety's serious limitations) and other tools for material identification used on homogeneous materials (yes you're going to have to crush hundreds of those 0402 resistors! ;o} ) is certainly one way to validate that the lot you've purchased on the gray market is compliant.

3. Don:

   I saw this with regards to crushing components: 14. Why can’t we just grind components into a powder, then test for RoHS compliance? Remember, RoHS compliance is based on each “homogeneous material” and not components or devices. If a component or populated circuit board is ground up and tested, restricted substance concentrations in the homogeneous materials are diluted. If a lab grinds up a complex component or entire product, they will not be able to state anything about RoHS compliance, since they will not know which material any restricted substances found come from, or if the restricted substance comes from an exempt application. The grinding equipment specified by the electronics OEMs to use in grinding up components is difficult if not impossible to clean. Plastic and low melting elements (e.g., lead) get smeared onto the blades and other surfaces of the equipment. Also, abrasive samples such as populated circuit boards will abrade parts of the equipment such as stainless steel and contaminate the sample with chromium and/or nickel or other elements. For example, let’s say that a circuit board is ground up using the electronic OEM technique. The first issue will be whether the ground sample has been contaminated by past samples or the grinding equipment. Even if that was not an issue, let’s say the final ground sample is analyzed for TOTAL lead, cadmium, hexavalent chromium, mercury, PBB, and PBDE. The analysis cannot separate exempt lead from non-exempt lead, exempt cadmium from non-exempt cadmium, and so on. So which is the “good” lead and which is the “bad” lead? No one can tell. Besides, there is no way to create a certified reference material to validate the results. So such testing is essentially WORTHLESS. If an electronics OEM tells you to grind up your sample and you tell us to grind up your sample, we cannot state compliance. Neither should you. Let the OEMs have the data and let them state conformance or non-conformance based on the results.

4. Don:

   I do have some issues with the final paragraph from the above.

5. Mike K:

   I am sorry that I was not precisely explicit in my use of the word "crush". Of course you can't simply "crush" a part and do the analysis...the definition of homogeneous material is quite clear about that. The point I was trying to make is that in order to get enough "homogeneous material" for a sample to enable a (particularly hand-held) XRF tool to give you a valid result you may need several units. I believe there are other tools that, while expensive, have spot sizes and the ability to identify materials that would enable more precise analysis at the homogeneous material level on, for instance, a single cross-sectioned part.

6. Don Ballard:

   I wonder how many people are going to do detailed analysis on their supplies? Judging from what I have heard within the industry, most folks are compiling CoC's and leaving it at that. Some are even saying they will get CoC's on what they can and if one is not available, they tried. They need to somehow solidify the term due diligence......beef it up. What is even more scary is, I have actually talked with people on RoHS and they have replied, "what's that?" Unlike the great CE rush of '95 (where most waited to the last minute) these directives would be best implemented sooner rather than later.

7. Jim:

   Don, Counterfeit components will always be a problem because when allocation and part shortages occur a company will often go to brokers and second sources. This is the supply line used for counterfits and the line that needs better controls. The only solution to dampen non-compliant parts would be to have verifiable tracking much like UPS uses for tracking packages from start to finish. An system supporting source to end user tracking is what is missing. This sounds extreme, but the open system now used has too many holes. Everything can come into the US without specific awareness of it's source. The CD and DVD industry is in the same boat. Source tracking is the issue there as well. A closed system tracking components will provide necessary verification that should be managed by a central overseeing agency. Otherwise, the cost of each companys 're-designing the wheel' each coming up with what they see as best will evolve into too many systems and too much cost that is pushed to the end user. Even our current systems(s) for managing compliant inventory is creating a large monster that will need taming. Currently, we are creating a compliant system without having the sound controls in place to protect that system. We have a date of July 2006 without even clarity of the compliant paperwork required. Everybody's guessing at this point, yet the due date is not changed. Looking at all the variables in place around this lead-free effort and the resulting counterfeit components we should realize this shifts the advantage to those with the cheaper transition costs. Adding this to high health care , high retirement, rising energy and rising taxes that follow rising real estate prices...the lead-free will convince many manufacturers it's time to move out of the US or go broke. With alot of lead/Pb around and not as much silver what happens with silver goes up? Expensive ROHS compliance will push remaining US manufacturing jobs overseas. Companies that don't ship to Europe or are in industries exempt from compliance will still need to re-design,test, and certify/or FCC certify because only lead-free parts will be eventually be available. Manufacturing both lead and lead-free is not sound. Nor is maintaining two inventories. The system needs to be economically sound enough and not reduce profit margins so much that the advantage is given or handed to Asian economies. Here's afew thoughts on this can of worms that we are opening.

8. more from Jim:

   Hi again Don, So much around lead-free and it's compliance has already slanted and dimmed all good thought and prespective around it. An easy solution to lead-free and restrictive materials is simply let the cost of disposal be charged upfront then let the market be the driver. BUT, with such a difference in cost between lead and non-lead that everybody will run to the non-lead parts. The overcharge for parts using restrictive materials will push the cost effectively to compliant parts. This gets things moving rightly and closes the demand for lead/ROHS restricted parts. The cost of compliance enforcement becomes a minor issue. The problem of counterfit parts becomes minor too. A $50 IC vs. a $5 IC will knock things in perspective very quickly. The extra $45 goes to environmental projects. This is a very easy solution and more easily implemented. Trying to add follow-up 'patch-job' solutions to implementing perhaps a 'bad' policy and 'bad' procedures. This is like selling something 'bad' and then selling the needed 'fixes' later. That's our current direction. This current direction for restrictive materials is not the best direction to go and it needs to be said.

9. Carl:

   Dr. Ron, You said, "I expect counterfeits will be an issue if one does not deal with reputable suppliers." Wish I didn't have to tell people that even through reputable suppliers, there may be no guarantee, though the odds are obviously better. Years ago when doing some contract working at one of Silicon Valley's biggest companies (the kind of place usually known by their initials), we actually ran into some counterfeit parts that came from a mainstream distributor. No one ever suspected that they were counterfeits as the company never bought components from questionable suppliers. Thankfully, the product's functional test was so stringent that the bogus devices all failed. But the fakes weren't all that bad. In someone else's product they might have never caught. It was only when the manufacturer was contacted and some failing parts were sent to them that they flagged them as counterfeits. They looked so legit that the manufacturer had to actually send us detailed information and pictures showing us how to identify the fakes. Without their help, we would have never been able to see the difference. Obviously, the mainstream distributor that sold us the parts didn't know. Some of the parts counterfeiters are pretty good at playing the game.

10. Bob Harris:

    Dr Lasky,

11. Andrew Jelen:

    Can anyone provide information on companies or laboratories with succcessful counterfeit screening programs.

12. Bob Maresch:

    I have to concur that counterfeit parts is an issue that will undoubtedly be ongoing. The protection has to come from a certified source. For example, my company (www.yesleadfree.com) provides guidance in the conversion and manufacturing processes. However, our partner is ISO9001/2000 AND QC 080000 certified. The QC 0800000 is the important part, as it is the IECQ's new arm, or link with ISO for the control and monitoring of all RoHS processes. As a rule, C of C's from 1st teir vendors are recognized as acceptable. However, we also "test" or audit the credibility of material by use of an XRF scanning gun to verify compliance. This will become more widespread as people are educated in the requirements of RoHS, and the ramifications of simply trusting the supply chain.

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