A Lead Free World?

Graham Slee explains why are small HiFi manufacurers are an endangered species

Interviewer: Geoff Husband - TNT France
July, 2006


A week ago I had an email from Graham Slee about his new phono stages. This wasn't unusual but the reason was that he wanted his latest designs re-reviewed because there were some fundamental changes that had been forced on him. I was intrigued by this and so asked - it opened the floodgates for what is obviously a frustrated man. The resultant correspondence I've put in the form of an "interview". I have no electronics knowledge but at the very least Graham's argument deserves to be heard and so I publish it here withough critical comment. However I do have some knowledge on environmental issues and so I have made a short comment at the end of the article which I hope is relevant.

Geoff Husband >
You are telling me that RoHS is a major threat to Hi-fi, but what is it supposed to achieve?

Graham Slee >
If you are not aware of it, RoHS is a directive of the European Parliament, which came into force on July 1 this year (2006). RoHS is the commonly adopted name for Directive 2002/95/EC on the Restriction of Hazardous Substances in electrical and electronic equipment. These (allegedly) hazardous substances are identified as: Lead, Mercury, Cadmium, Hexavalent Chromium, PBBs and PBDEs. Lead, alloyed with Tin, is used in solders, and for the protective coating (tinning) of component wires and pins. Lead is also used in glass of lamps and cathode ray tubes. Mercury is used in some lamps (Mercury vapour lamps) and some relays or switching contacts. Cadmium is used as a protective finish on metals, in NiCad batteries, and to stop relay contacts burning out. Hexavalent Chromium is a yellow coating on the inside of metal cabinets to prevent stray RF (helping many items comply with European Parliament EMC regulations). PBBs and PBDEs are flame retardants used in plastics including wire, cables and insulators. PBBs are hardly ever used these days but PBDEs have been in common use.

Originally, RoHS was to apply to everything electrical and electronic, but a number of exemptions have been applied. Some exemptions are obvious some are not. Until the directive was amended in late 2005 to encompass the categories of another directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE), it would have included motor vehicles. Rather than simply saying, "Motor vehicles are exempted", the amendment rather hides the fact in legal jargon, probably to prevent "unrest among the natives" (us!).

The RoHS directive is supposed to achieve a reduction in the number of toxins in the air or drinking water, due to the incineration or burying in landfill of equipment containing these alleged hazardous substances. The reality is that so many industry sectors have been removed that what's left are minority polluters. The World Health Organization, published in early drafts of UK DTI discussion papers, reported that Lead pollution was already within acceptable limits!

Also as the WEEE directive mentioned above, prevents those disposal methods, it could be seen as overkill.

Geoff Husband >
OK, so it may only be of limited use but anything's better than nothing, so what is the problem with it?

Graham Slee >
As so many TNT-Audio readers will know, changing an Interconnect can make a world of difference to a hi-fi system. The difference can be good, and then it can be bad. A change to OFC (Oxygen-free Copper) can do the trick. Silver can sparkle-up a dull system, and then again, it can take it over the top, producing an over-bright hard-edged sound. It is a question of balance.

Consider that Hi-Fi equipment was, before RoHS, soldered together using solder containing 37 to 40% Lead. So was the equipment used to record and produce the music. The component wires and pins had a protective coating of 60/40 Tin/Lead. The protective coating to the surface of a printed circuit board and the plating of via holes in double sided and multilayer PCBs was Tin/Lead. Insulation in wires contained PBDEs. Capacitor electrolyte, or the dielectrics of Polyester and Polypropylene capacitors could also have contained PBDEs.

It is not a long chalk of the imagination to realize that by removing these substances, some sonic characteristics could change. Will that change be for the better? Will it be for the worse? Will it be over the top?

There has been a long debate on the way capacitors affect sound. Companies like Elna in Japan have long been involved in Electrolytic capacitor formulations for audio, producing some very popular ranges like the Starget, Silmic and Cerafines. These capacitors are dependant on their chemical formulations for the audio characteristics they display. You can actually measure the difference in distortion between a circuit containing them and one containing general-purpose alternatives, making the differences objective rather than just being subjective. When the European distributor told me that Elna would not be making a RoHS version of the excellent Starget I was shocked. Reading between the lines it would seem that the Starget was dependant on all its (alleged) hazardous substances. By removing them the Starget simply wasn't a Starget any more. I (and reportedly, others in the industry) found the RoHS compliant alternatives on offer lacked the previous outstanding audio performance. The last I heard was that Elna was introducing an RoHS compliant Starget, but with sampling and delivery times that would take compliance way beyond the deadline, I decided enough was enough and abandoned Elna audio capacitors altogether.

It is a hard concept to grasp that a straight piece of wire or a nice flat PCB track can be an inductor. Surely inductors are coils of wire? So explain why many early high speed logic circuits would "glitch-up" causing errors? Thanks to research into high speed logic we now understand that all sorts of circuit elements previously considered benign contribute inductance. And as all inductors have a resonant frequency, maybe they can affect sound quality? Conventionally PCB track inductance is countered by decoupling with capacitors, but the alterations of chemical balance RoHS presents, has been noticed in changed behaviour, with results differing from those expected.

Component manufacturers have adopted different solutions to the protective coatings used on their component wires and pins. Pure Tin alone is generally OK, but gradually converts into another allotropic form called grey-Tin (Tin-plague) below 18 degrees Celsius (near room temperature). The decomposition to grey-Tin may take tens of years in the domestic environment, but is much faster at lower temperatures. Once "infected" with the grey spores the process is autocatalysed and components stored at warehouse temperatures quickly loose their solder-ability. To counter this problem alternatives to Lead are sometimes being used. The addition of a small trace of Copper or Bismuth (Bismuth is alloyed with Tin to produce type-setter's metal) can prolong the integrity of the corrosion resistance. Precious metals like Silver, Palladium and Gold, are also being used as anti-corrosive coatings.

These metals with their different chemical structures can be shown to have a real effect on the electrical performance of a circuit. Every metal has an Electrode Potential and where one type of metal terminates to another, a thermocouple junction exists. In a simple component such as a resistor, there is two of each type of terminal, and therefore the temperature effects cancel out. However, as every engineer undertaking thermocouple work is painfully aware, a great deal of noise is picked up in the junction of the thermocouple, and being independent and random, is not cancelled out. Although negative feedback in amplifier circuits is very good at dealing with noise, any additional noise that's not been identified or considered uses-up loop gain, and the gain-bandwidth product can be compromised causing circuit instability. It may not be destructive to the equipment but the instability is very destructive to the sound. In tests, I noticed that on changing between resistors from different manufacturers who use different wire coatings, different distortion figures were recorded.

In the past, these thermocouple junctions were Tin/Lead to Tin/Lead, having identical electrode potentials, they exhibited little thermocouple noise. Now there is an abundance of different metals used in coatings between element and wire, and wire to circuit board, which may have one of many protective coatings. Without manufacturer data in this early age of RoHS, the designer is set a difficult task in understanding just what is upsetting a previously good design.

Few in the industry have yet commented on the effect RoHS has made to the sound of their products. To go public on such matters could damage reputations built up over many years. Because of an apparent loophole which allows the sale of goods already imported into the EC prior to July 1st at any time after that date, many non-RoHS products are stacked up to the rafters in warehouses to satisfy the demands of the coming hi-fi season. It will therefore take quite some time before RoHS compliant imports hit the shelves of the hi-fi dealers shop. The European manufacturer cannot exploit this loophole (a very unfair consequence!) so unless his RoHS products perform as good as before, he is definitely at a disadvantage. He will be the first to be judged as to whether he understood the problem and dealt with it, or simply substituted RoHS compliant parts and hoped for the best.

Having worked on RoHS solutions since late 2004 I am in no doubt that it does have a profound effect on the sound of high-gain and high-resolution analogue audio for the reasons set out above. Digital is just 0's and 1's, and provided it isn't "bounced around" by the increased inductance of PCBs and component wires, then that's hardly going to matter - the analogue section is unity gain after all. But consider the output filter is a gain/frequency dependant circuit, and you might just find audible differences creeping into digital products too.

The science behind RoHS in my opinion is obviously flawed, as can be gathered by the number of exemptions. After all, you wouldn't want your new car's on board computer to grind to a standstill because the circuit has "rotted" into grey dust in the cold of the winter, or that the traffic lights all turned green at the same time. You will feel safe in the knowledge that all the relays in the back of your remote controlled preamp will continue to make contact because of a last minute reprieve on Cadmium plated relay contacts. If RoHS had been properly researched, it would not have necessitated so many hasty retreats.

Moreover, what about reviews? Will you be buying your RoHS compliant "gizmo" based on a review of an earlier non-RoHS version? I am hoping that the hi-fi magazines, online or printed, will reappraise the RoHS compliant versions of what have been already reviewed, although that is a massive task that could take an eternity.

Geoff Husband >
What other nasties are on the horizon?

Graham Slee >
You have heard the saying "it never rains but it pours"? RoHS is just one of three European Parliament directives to affect audio. The other two are Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE); and Directive 2005/32/EC on EcoDesign. They (including RoHS) are supposed to "complement each other" which is something I simply cannot grasp. RoHS, in particular the loss of Lead, will reduce the lifetime of anything but the most cared for piece of equipment, simply because of Tin Plague. This will result in more carbon fuel usage to replace prematurely dead equipment. As such, there will be more waste to be dealt with under WEEE which I suppose opens up a whole new area of exploitation? WEEE is all about recycling, which unfortunately requires transportation of waste within a complex infrastructure dictated by "red tape" and the geographic location of suitable recycling facilities. Dealers and distance sellers (online shops) will be tied into "take-back" schemes where unwanted end-of-life equipment will have to be shipped back to its source. New recycling and reuse plants are being set-up all over Europe to cater for the legislation - all consume power using up carbon fuel.

The EcoDesign directive states repetitively that it is about energy security and sustainability. How can WEEE and RoHS complement that? In the act of throwing stones into the air, it is advisable to have an idea where they are going to land. In other words, you should always think of the consequences. The consequence of these directives would seem to be pure hypocrisy!

Manufacturers large and small - even the hobbyist sat at his kitchen table making amplifiers for some extra pocket money, must register as a producer under WEEE law. The European Parliament refused an amendment from the UK Government to exempt small to medium enterprises (SMEs) and very small businesses from WEEE registration. Each European member country has been told to implement their own version of WEEE and as such, there is no centralized registration agency - there is no common policy in this "common market" legislation - everybody has to register separately with each country he/she will sell into. It is rapidly becoming a rat-race of confusion.

The German "take" on WEEE suggests that each producer must place a walk-in skip at every municipal "dump-it" site! Maybe something has been lost in its translation into English, but if that is the case, the tabletop hobbyist is faced with a bill running into millions and that is absolutely crazy! If we ignore the German "directive" and simply concentrate on the cost of being registered, we find that, including VAT, the cost using a not-for-profit scheme such as the "Repic" do-it-yourself approach is 1,000 per year per country, or 25,000 for all of them! (That is providing you can locate a WEEE compliance scheme in each country and translate fluently in every European language). As a very small business you will pay exactly the same as a mobile phone or washing machine manufacturer which suggests that the small producer will subsidize the giants - a bit like Robin Hood in reverse! Even if you're able to meet these costs, you can easily fall into the contradictory trap of what you must and must not say in your advertising, as Boots PLC recently found when they were fined for an omission in an advertisement that didn't meet with the Irish interpretation of WEEE. After all that, you must be able to provide a financial guarantee - a guarantee that is insolvency proof - a guarantee that will pay for the end-of-life costs of your product whatever that may be, whatever the inflation rate, and whenever that may be in the future, which may be in your lifetime or after you're dead and buried. Obviously, this can work for the industrial giant. Equally obviously, it cannot work for the small to medium enterprise or the very small business. I trust each European Community country is building sufficient prisons to hold us all in?

The final (or at least I hope it is final) directive - 2005/32/EC on EcoDesign may prove to be more friendly to the small enterprise. It requires the adoption of "implementing measures" for each EuP (energy using product) placed on the European Community market. Unless amended before it comes into force on August 11 2007, the "implementing measures" will only apply to EuPs "that represent a significant volume of sales and trade, significantly more than 200,000 units a year within the Community according to most recently available figures". Those last six words however, could be easily used to amend the directive making it yet another "nightmare come true" for the small producer.

The real terminator (pun intended) of audio freedom is in the figure of Arnold Schwarzenegger, Governor of California. He and "Energy Stars" around the World are to bring to an end the linear remote power supply. Plug-top transformers and even serious outboard linear supplies are to be outlawed as being considerable contributors toward climate change. Arnie wants all 50 US States to follow suit - a move that will remove the need for seven power stations throughout the USA. He is also looking into the efficiency of inboard power supplies, and the efficiencies of delivery of power to the load. In audio terms that would ultimately lead to the demise of class-A amplifiers because they are anything but power efficient. What will replace linear power supplies? Switched-mode of course! Taken to its logical conclusion (audio enthusiasts may disagree with the word "logical" here), I guess the future holds nothing but Pulse Width Modulated (class-D) amplifiers powered by "switchers" for our delectation.

In this article I have tried very hard to behave rationally and not to rant on emotionally about how all this legislation has a soul destroying effect on the designer who tries so incredibly hard to share his/her talents with the music lover, only to be shunned by what would seem to be ruthless dictators. I feel the need to point out the real hypocrisy of all this legislation which, is admirably summed up in the lyrics from Mike and the Mechanics "Why Me?" from the "Living Years" album, which goes: "I was so concerned with saving life, I never saw you pull the knife". While the electronics industry is lined up at its judgement day with officials such as Arnold Schwarzenegger taking the lead role of God, nobody can see the knife! Removing all the plug-top transformers from the USA may remove the CO2 of seven power stations. European EcoDesign may save a few more. But just stop to consider this - the Boeing 747 (and similarly other Jets) contributes the equivalent of one third of a power station of CO2. It puts it, not below the rain clouds where it has the chance of being washed back into mother earth, but directly into the fragile stratosphere where it hangs around to stop the process of condensation. The result is that rain does not fall on the most needy parts of our world where people are starving to death because of famine! And in other places it causes floods and results in water borne diseases killing even more of the poor people of this cruel world!

Don Quixote shaped politics, which is what we seem to be stuck with today may bode well for the self-gratification of those with all the power, but the saying "there is none so blind than them that will not see" may yet be their epitaph.

A couple of thoughts from a bewildered reviewer.

As a species we are in the process of fundamentally changing, if not destroying the planet we depend on. Heavy metals are poisons that are both persistant and dangerous and far too much of them end up in land fills. In our civilization we junk a huge amount of electrical equipment and these chemicals end up in land-fills and hence into our water supply. To reduce this is obviously a "good thing". There we have a simple argument and a valid one, the problem is what happens when it is applied world-wide (and this isn't just European) in blanket and inflexible legislation. I know for a fact that many small electronics manufacturers will continue to use lead in their products and certainly those I've had here lately do - add the number of manufacturers that use lead as a damping or high-mass material (especially turntables) and there are a lot of companies out there who could potentially be shut down overnight by the authorities. It's always difficult to make exceptions to rules, but a fixed limit of, say 10,000 units from any manufacturer would give the big boys the level playing field they want and the small manufacturers who are responsible for a tiny fraction of the landfull problem (even seen a Krell on a skip?) will either continue using specialist component manufacturers or gradually convert as components become increasingly lead free. But of course that wouldn't give the appropriate headlines.

BUT, and this is my own personal take on the matter, this kind of legislation, whilst in theory desireable, is political window dressing. Look carefully at all the international anti-pollution measures that are agreed on? Can you think of one that actually reduces consumption? No me neither - they are all built round schemes that in the end increase consumption, boost economies, increase employment and generally do zip for the fundamental problems of the planet. Yes, less lead in landfills is good, but the result will be loads more research and developement, new "environmentally friendly" products for you to buy, shorter lifespans, more transport use, obsolescence and a massive burocracy. This is what big business wants - "buy more product sonny and save the planet". I don't know if anyone has calculated the number of lives this legislation will save but compared with the tens of millions who will die in sub-Saharan Africa and Asia because of global warming in the next 25 years it is pitiful - in fact on balance this sort of thing probably contributes to that fundamental problem. I really think that until Rome (fill in your own capital) burns then politicians will be happy to fiddle.

"Inorganic Chemistry" David Abbott M.A., Ph.D., A.R.I.C. (M&B Publishing)

Greenhouse Gas Pollution in the Stratosphere Due to Increasing Airplane Traffic, Effects On the Environment

Technology Review: Emerging Technologies and their Impact

Is Global Warming Harmful to Health? Scientific American 20aug00

The European Community Directives:-




NB. Due to the "explosion" of Internet articles on the subject, the references to the amendments mentioned in the text can no longer be found

REPIC - Recycling Electrical Producers' Industry Consortium

California State Power Supplies and Consumer Audio and Video Equipment:-


NB(1). Pages 122 - 123

NB(2). Due to the "explosion" of Internet articles on the subject, the original separate legislation can no longer be found

Copyright 2006 Geoff Husband - www.tnt-audio.com