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Fresh PCB Concepts: Sustainable PCBs—Raw Materials and Compliance Methods

The shift toward sustainability in the printed circuit board industry has required PCB producers to rethink their manufacturing processes and who they do business with. A PCB producer's sustainability efforts are for naught if their raw materials providers are not in regulatory compliance. Dealing with overseas manufacturers can raise questions about sustainability practices unless manufacturers follow standard regulations.

To help meet our own sustainability standards, NCAB maintains a Preferred Supplier List (PSL). Among other requirements, each preferred supplier must pass our sustainability and quality audits. They must also comply with legislation covering raw material content. This includes regulations such as RoHS, REACH, TSCA, and California Proposition 65. A thorough understanding of each is required to ensure NCAB produces sustainable PCBs. Here is a brief overview of each of these regulations.

RoHS
Restriction of Hazardous Substances (RoHS) is a European Union directive adopted in February 2003. Its primary goal is to restrict the use of specific hazardous substances in electrical and electronic equipment. The RoHS directive has been updated several times since adoption, most recently in 2019; this version is known as RoHS 3.

The substances banned by RoHS include lead, mercury, and cadmium, all of which had been widely used in electronic components in the past. Although it is an EU standard, many electronics manufacturers worldwide choose to comply with RoHS standards as part of their sustainability efforts.

REACH
REACH stands for Registration, Evaluation, Authorization, and Restriction of Chemicals. It is a comprehensive EU regulation and perhaps the world's most extensive chemical legislation. 

Manufacturers and importers of chemicals must register each of their products with the European Chemicals Agency (ECHA). The ECHA then evaluates the provided data to identify potential risks with registered chemicals and develop mitigation plans. Some chemicals require authorization from the ECHA if they are deemed to be "Substances of Very High Concern" (SVHCs). If a particular chemical is found to pose significant health risks or has the potential for environmental damage, it may be restricted under REACH guidelines.

TSCA
The Toxic Substance Control Act (TSCA) is a federal law in the United States. It was passed in 1976 and is administered by the Environmental Protection Agency (EPA). TSCA ensures that chemicals used in business don't pose significant environmental or human health risks.

The TSCA grants the EPA considerable authority over chemical production, use, and distribution. Under the TSCA, the EPA can require testing of certain chemicals to determine potential risks. TSCA also enables the EPA to impose restrictions on or prohibit the manufacture of chemicals that the agency deems potentially risky.

California Proposition 65
The Safe Drinking Water and Toxic Enforcement Act of 1986, also known as California Proposition 65, is a California state law that protects residents from exposure to chemicals known to cause cancer, congenital disabilities, or other reproductive harm. The California Office of Environmental Health Hazard Assessment maintains a list of chemicals that might meet these criteria in accordance with Proposition 65.

California businesses that expose individuals to chemicals on the list must provide warnings to customers. However, businesses with less than 10 employees and those that can demonstrate exposure levels below specified thresholds are exempt from warning requirements. Companies that are subject to Proposition 65 must perform regular assessments of their products and services to ensure compliance.

Persistent Organic Pollutants (PoPs)
The Stockholm Convention on Persistent Organic Pollutants is an international treaty that went into effect in 2004. Its primary objective is to limit or eliminate the production and use of several known dangerous chemicals or persistent organic pollutants (POPs).

The first 12 chemicals identified by the Stockholm Convention are collectively known as the "Dirty Dozen." Amongst these are DDT, Mirex, and Aldrin. Several POPs have been added to the treaty's list in the years since its initial adoption.

Creating More Sustainable PCBs
Choosing suppliers that comply with these and other regulations directly impacts creating more sustainable PCBs. Compliance ensures eco-friendly manufacturing processes, reducing the environmental impact of PCB production. Suppliers that follow these regulations also tend to have higher quality standards, leading to improved products that last longer.

Regulatory compliance reduces the risks of supply chain disruptions due to materials being held up for inspection. Avoiding product recalls, fines, and legal liabilities fosters a healthier PCB industry.

More importantly, following these guidelines means PCBs will not contain harmful chemicals that pose significant risks to customers and the environment. Today's consumers are increasingly aware of sustainability issues, and they will choose PCBs from a manufacturer they can trust. 

At NCAB, we use these regulations as a starting point. We also require our suppliers to comply with local social and environmental regulations and be ISO 9001 and ISO 14001 certified, where applicable. Creating sustainable PCBs is a continuous effort, and no one regulation is a complete solution. However, applying all these standards together help NCAB create the most sustainable PCBs possible.

Ramon Roche is a field application engineer at NCAB.