For purposes of exemption in telecom land, when the EU defines only the solder as exempt, does that really mean just the solder? ie, can you still have a board manufactured with the HASL process and can you still have an IC that has tin lead leads? Or does the PCB and the leads on the component still have to comply? I guess it depends how you define "solder". is tin/lead simply "solder" that is plated onto an IC lead? Is a HASL board just coated in "solder" ... ??
Is there an easy answer here?
(I enjoy reading your stuff .... very well written)
Practically I think the exemption would cover the solder materails and the component leads and finishes. No one would be able to tell if the leads and finishes had lead anyway, in a tear dowmn analysis, as the solder used in assembly will dissolve the finishes. Also it is likely that you will have trouble finding PWBs and components that have lead anyway. Right now it may be easy to find HASL with SnPb solder. But, as RoHS goes into effect many PWB shops won't want two processes so they may only do SAC HASL, the same (probably more so) with components.
However, remember that the rest of RoHS applies to telecom, so you must eliminate CrVI, Hg, Cd, etc. Some people consider CrVI to be a considerable challenge. These tasks should keep you busy!
Glad you like my writing!