Action Alert!: Product ID Requirements
The most forward-thinking product
manufacturers may seize new RoHS type regulations as an opportunity to
revisit their overall approach to product IDs and the sources whom they
partner with to create them.
Many equipment manufacturers worked overtime to bring their products into compliance with the European Union's RoHS Directive that became effective July 1, 2006. However, a significant number of companies that have re-engineered their manufacturing methods to be RoHS compliant seem to have forgotten that nameplates, decals, labels and other product IDs are equally affected. Although RoHS is not a law per se, the dozens of similar measures now pending in various states probably will be. Bringing RoHS product IDs into full RoHS compliance is not as simple as some might imagine. In this article, we'll discuss the underlying issues of RoHS compliance as it affects product IDs and finding sources for nameplates, labels and decals.
What is RoHS?
The RoHS Directive stands for "the restriction of the use of certain
hazardous substances in electrical and electronic equipment." This
directive bans the placing on the E.U. market of new electrical and
electronic equipment containing more than agreed levels of lead,
cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB)
and polybrominated diphenyl ether (PBDE) flame retardants. The reason
for the ban on these substances is that they all have been determined
to wreak havoc, to greater or lesser extents, on the environment. That
is why, for example, the environmentally conscious State of California
is in the forefront of U.S. efforts to follow suit.
RoHS is not merely a constraint on solder formulations used in products with electronic components. Rather, products that might someday end up in landfill are covered in entirety. Whether it comes from the electronic wiring used to create control panel motherboards or the inks used for nameplate and label production, communities don't want lead or other heavy metals in their drinking water.
Hidden Problems in Product IDs Many of the substances banned by RoHS are used in the ink formulations that one sees in nameplates, decals or labels, especially lead and cadmium. In fact, traditional screen printing inks make extensive use of these banned substances because they often facilitate the precise color matching required in a specific design and/or the durability of the product ID over time, and especially in extreme weather conditions. This means that one can't just reach for an ink formulation without a banned substance, but rather one needs to do extensive testing of substitute ink formulations to ensure that they perform adequately during the entirety of the product's (and product ID's) lifecycle.
Re-Engineering Product IDs for Full Compliance
To ensure full RoHS compliance in product IDs, product manufacturers
need to rigorously re-examine their sources for product IDs and
determine in detail if the sources used are capable of RoHS compliance.
At the time of this writing, it is expected that the lion's share of
screen printing facilities that have been used in North America are not
RoHS-compliant. Many of these sources are too undercapitalized to make
the equipment investments needed for RoHS compliant product IDs. To
achieve consistency without compromising the appearance or performance
of the product ID is more involved than one may think.
-
"Has an exhaustive audit of all
substances--inks, adhesives, etc.--used in product ID manufacture been
completed by the product ID source?"
It is highly unlikely that all of the ink formulations that had been used prior to RoHS will still be viable. This actually is where many product manufacturers are getting into trouble, Sources for product IDs are often found early in the product's initial introduction into the market, with decisions on sourcing product IDs not re-visited with any regularity. If a longstanding source is unable to document their RoHS compliance inventory review process, then a new source for product IDs needs to be found post haste. -
"Have product IDs with substitute ink formulations
(etc.) been tested for the expected real-world conditions that they
will be exposed to?"
Many of the heavy metals that are now banned by the RoHS Directive (and similar rules soon expected to be laws in various states) have been used specifically because they either assist in color matching to design requirements or increase ink durability in extreme weather conditions. Completing a comprehensive re-engineering of product ID manufacturing methods to ensure RoHS compliance, there are no shortcuts that will work. Extensive testing of new ink formulations needs to include repeated and verified lifecycle testing in QUV Accelerated Weatherometers (or equivalent equipment). -
"Does the product ID source have the laboratory facilities one needs to test substitute formulations?"
Truth is, there are many smaller screen print operations that have never had the budgets or wherewithal to build such test laboratories, and a significant number of these are relatively undercapitalized businesses that cannot make such investments in equipment and personnel quite so easily.
Design Integrity and RoHS-compliant Product IDs
Actually, the laboratory and engineering expertise that a product ID
manufacturing source needs to possess to deliver RoHS-compliance is
similar to the capabilities required for state-of-art product ID
manufacturing and ultimate design flexibility.
For example, keeping adhesive inventories up-to-date typically involves ongoing testing of the many new adhesive formulations introduced in the market each year. Formulations specific to a range of hostile and harsh environments - saltwater, extreme cold, extreme heat and chemical exposures - exist today that did not exist even a few months ago. When these new formulations arrive, reputable product ID manufacturers will exhaustively test them in real applications before they are used in final jobs.
Selecting the right adhesive is usually a matter of matching fully tested adhesive/substrate combinations for the product lifecycle being considered. One should be able to specify the bond area and shape; required adhesive strength; expected temperature exposures and cycles over a product lifetime; mechanical shock and vibration exposures; expected exposure to water and various chemicals; and requirements for storage and shelf life. The matrix of answers to these various questions will usually narrow adhesive choices down considerably. However, if a nameplate/decal/label supplier has not kept their adhesive inventory up-to-date and tested the materials in their inventory with various substrates, shapes, etc., it is likely that a formulation with lesser qualities and/or greater expense is being used.
In a small minority of cases, re-engineering product IDs for RoHS compliance may involve basic re-design of the nameplate, decal or label, in terms of the substrates used, design finishes, or addition of special effects such as doming, embossing or debossing. A product ID source that does not have full-service capabilities may try to steer a product manufacturer towards inferior options, not fully apprising them of practical or less costly alternatives. A product ID manufacturer that is not equally versed in metal or plastic nameplates might steer a customer in one direction only, not fully apprising this customer of options beyond their company expertise. For example, adding doming effects (a top layer of polyurethane resin) is increasingly used not just to create pop-out design appeal, but also to add to a label's ability to withstand certain chemical exposures.
Summary
The new RoHS type regulations should propel product manufacturers to
carefully examine the product IDs used on their products and to ensure
that their sources for nameplates, decals and labels are RoHS-capable.
RoHS capability is not the straightforward matter that some may assume.
The most forward-thinking product manufacturers may seize this as an
opportunity to revisit their overall approach to product IDs and the
sources whom they partner with to create them.
