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A european question : RoHS

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Rene Tschaggelar

Jan 1, 1970
0
A question to the Europeans :
Am I allowed to sell a gadget containing lead after the
1.July of next year when it was produced before that date ?
I guess not.
But if so, for how long after the 1.July.2006 ?

Rene
 
F

Frank Bemelman

Jan 1, 1970
0
Rene Tschaggelar said:
A question to the Europeans :
Am I allowed to sell a gadget containing lead after the
1.July of next year when it was produced before that date ?
I guess not.

If this gadget has been 'put on the EU market' (EU customers
could buy it) before 1 July you can. You can also continue
buying and using (old) parts that contain lead, to produce
this particular gadget, as far as I understand. A new gadget
that has never been on the market before, would need to be RoHS
compliant. There are excemptions too, for networking gear etc.
But if so, for how long after the 1.July.2006 ?

For eternity I'd think. RoHS should not turn existing stock
into worthless junk. Existing (!) stock will end up in landfills
either way so it does not make sense not allowing to sell and
use it. I suppose EU hopes that, over time, old stock will
run out, and new equipment will contain less lead. Practically,
that is *all* they can hope for.

It's all pretty vague stuff and many different interpretations
of the directives float around.

Just my 2 cents.
 
Not only can you not sell after that date but you must also be able to
demonstrate that your product complies with the regulations. Its not
just lead either, cadmium,mercury, hexavalent chromium, PBBs and PBDEs.
You need to start to get all the documents from your component
suppliers and replace what doesnt comply.
 
R

Rene Tschaggelar

Jan 1, 1970
0
Frank said:
If this gadget has been 'put on the EU market' (EU customers
could buy it) before 1 July you can. You can also continue
buying and using (old) parts that contain lead, to produce
this particular gadget, as far as I understand. A new gadget
that has never been on the market before, would need to be RoHS
compliant. There are excemptions too, for networking gear etc.

Does "this gadget" now refer to the product, or the single item ?
From what you tell, it is the product. N of it already sold,
M of it still on stock. Great. I would hate to have the remaining
stock thrown into the landfill.

For eternity I'd think. RoHS should not turn existing stock
into worthless junk. Existing (!) stock will end up in landfills
either way so it does not make sense not allowing to sell and
use it. I suppose EU hopes that, over time, old stock will
run out, and new equipment will contain less lead. Practically,
that is *all* they can hope for.

It's all pretty vague stuff and many different interpretations
of the directives float around.

That is what my impression was too.

Rene
 
F

Frank Bemelman

Jan 1, 1970
0
Rene Tschaggelar said:
Does "this gadget" now refer to the product, or the single item ?
From what you tell, it is the product. N of it already sold,
M of it still on stock. Great. I would hate to have the remaining
stock thrown into the landfill.

From my point of view it is the product. Part of the game is
scaring the shit out of everybody with piles of unreadable stuff
and nobody knowing for sure how the directive should really be
interpreted in individual cases. Still, the directive is a succes,
because soon components will only be available in lead free.
Certainly 'they' expect a period where the directives are violated,
manufacturers getting rid of their old stock of components. It's
not worth chasing that.

I wonder how the directive applies to PC motherboards. Practically
every motherboard has an ethernet interface onboard. Voila -> network
gear.
 
T

Tilmann Reh

Jan 1, 1970
0
You're right.

No. You might only use non-RoHS parts for repair.

The date limit is valid for every *individual* gadget being sold. AFAIK this
means "sold to the final, private customer". Industrial customers might be able
to still buy and use non-RoHS devices. This is one of the details that are still
rather unclear, AFAIK.
But they (government) really don't care about the parts (or completely produced
gadgets) you (or any dealer) have on stock.
Does "this gadget" now refer to the product, or the single item ?
From what you tell, it is the product. N of it already sold,
M of it still on stock. Great. I would hate to have the remaining
stock thrown into the landfill.

But that exactly is what this stupid directive says. :-(

Makes no sense, but this is law meanwhile.

That's why the directive was published a few years ago, to allow the concerned
companies to switch to RoHS components and materials *before* July 2006.

However, problem is that many parts still are not available in a RoHS version,
and the soldering process is the last to turn lead-free (to avoid lead
contamination from the parts). This makes stock management a difficult thing today.

Yes, many details have to be discussed further...
 
M

Mike Harrison

Jan 1, 1970
0
A question to the Europeans :
Am I allowed to sell a gadget containing lead after the
1.July of next year when it was produced before that date ?
I guess not.
But if so, for how long after the 1.July.2006 ?

Rene

Depends on what sort of gadget it is.
Contrary to a lot of press reports, it does not apply to all electronic equipment.
The broad categories included are large & small household appliances, IT and telecom equipment,
consumer electronics, lighting, tools, toys & leisure and automatic dispensers.

There is a lot of industrial, lab and test equipment that is not included in the above.

The full details are annex 1A of the WEEE directive :
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00240038.pdf

RoHs applies to sections 1 to 7 and 10 of the above, as stated in 'scope' :
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00190023.pdf
 
R

Rene Tschaggelar

Jan 1, 1970
0
Rene said:
A question to the Europeans :
Am I allowed to sell a gadget containing lead after the
1.July of next year when it was produced before that date ?
I guess not.
But if so, for how long after the 1.July.2006 ?

The background of the question is what about the stock
of products resting on my shelf. I have them produced
by 20, 50, 100, whatever and they rest on my shelf rather
long until sold out. This due to the cost pressure from
the customers. I cannot have them produced in smaller lots.
They'd be too expensive.

Rene
 
P

Pooh Bear

Jan 1, 1970
0
Rene said:
A question to the Europeans :
Am I allowed to sell a gadget containing lead after the
1.July of next year when it was produced before that date ?
I guess not.
But if so, for how long after the 1.July.2006 ?

If it's the same as for the CE marking issue ( which common sense
dictates ) , the rule was that the non-compliant product had to be 'in
the supply chain' - such as in stock with a distributor or shop - before
the cutoff date. Therefore non-compliant product can continue to be sold
after the cut-off date.

You can't allow any non-compliant goods out of your 'factory' after that
date.

Graham
 
J

John Devereux

Jan 1, 1970
0
Mike Harrison said:
Depends on what sort of gadget it is. Contrary to a lot of press
reports, it does not apply to all electronic equipment. The broad
categories included are large & small household appliances, IT and
telecom equipment, consumer electronics, lighting, tools, toys &
leisure and automatic dispensers.

There is a lot of industrial, lab and test equipment that is not
included in the above.

The full details are annex 1A of the WEEE directive :
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00240038.pdf

RoHs applies to sections 1 to 7 and 10 of the above, as stated in
'scope' :
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00190023.pdf

Interesting, that appears to exclude everything we, and our customers,
make (industrial test & control equipment, basically).
 
S

Spehro Pefhany

Jan 1, 1970
0
Interesting, that appears to exclude everything we, and our customers,
make (industrial test & control equipment, basically).

Did you see category 9 in Annex IA, and the corresponding examples in
IB?



Best regards,
Spehro Pefhany
 
J

John Devereux

Jan 1, 1970
0
Spehro Pefhany said:
Did you see category 9 in Annex IA, and the corresponding examples in
IB?

Yes, but that is in the WEEE directive. I was more concerned with the
RoHS directive, which seems to prohibit even the manufacture of
certain goods. I gather that the WEEE directive is more concerned with
disposal, placing the costs onto the manufacturer? I have no idea what
to do about this yet... Perhaps we could send our UPS account number
out with each item, then the customer can ship it back to us in 20
years time when they have finished with it!
 
P

Pooh Bear

Jan 1, 1970
0
Frank said:
From my point of view it is the product. Part of the game is
scaring the shit out of everybody with piles of unreadable stuff
and nobody knowing for sure how the directive should really be
interpreted in individual cases. Still, the directive is a succes,
because soon components will only be available in lead free.
Certainly 'they' expect a period where the directives are violated,
manufacturers getting rid of their old stock of components. It's
not worth chasing that.

I wonder how the directive applies to PC motherboards. Practically
every motherboard has an ethernet interface onboard. Voila -> network
gear.

How come network gear is exempted ?

Graham
 
I

Ian

Jan 1, 1970
0
John Devereux said:
http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en0024003
8.pdf http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en0019002
3.pdf

Interesting, that appears to exclude everything we, and our customers,
make (industrial test & control equipment, basically).
Yes, but....

Some components are becoming _only_ available in lead-free form.
Lead-free BGAs are not compatible with a lead based
process, and vice versa.
Other components will be very difficult to adapt to lead-free processes
due to the higher soldering temperatures (electrolytics, some relays etc).

Even if your products are outside the RoHS regs, you may still have
a problem.

Regards
Ian
 
R

Rene Tschaggelar

Jan 1, 1970
0
Frank said:
Mission critical stuff ;)

Burocrats. They have no idea what all can be
mission critical when it fails.
But you're right I guess.

Rene
 
S

Spehro Pefhany

Jan 1, 1970
0
Burocrats. They have no idea what all can be
mission critical when it fails.
But you're right I guess.

Rene

Or maybe lobbying from Alcatel or whoever.



Best regards,
Spehro Pefhany
 
J

Joerg

Jan 1, 1970
0
Hello Tilmann,
But they (government) really don't care about the parts (or completely produced
gadgets) you (or any dealer) have on stock.

It seems they also do not care much about what that does to the European
economy. Which isn't in a stellar state to begin with.

That will probably also become a punishable deed. Possibly by tar and
feathers because they may not be able to use prisons if the lock system
electronics aren't RoHS compliant.
However, problem is that many parts still are not available in a RoHS version,
and the soldering process is the last to turn lead-free (to avoid lead
contamination from the parts). This makes stock management a difficult thing today.

Which means there will be some electronics that Europeans and the
companies there can no longer have for a while. What an economic
stimulator. For Asia ...
Yes, many details have to be discussed further...

It would be nice if politicans became smart enough to realize that
details need to be discussed and agreed upon before a law goes into
effect and not afterwards. Reminds me of when I read about how they
began to ban the flat-taxed small jobs in Germany. Unemployment started
to sky-rocket and you could hear some politicians exclaim "oh s--t", in
public.

Regards, Joerg
 
J

John Devereux

Jan 1, 1970
0
Ian said:
Yes, but....

Some components are becoming _only_ available in lead-free form.
Lead-free BGAs are not compatible with a lead based
process, and vice versa.
Other components will be very difficult to adapt to lead-free processes
due to the higher soldering temperatures (electrolytics, some relays etc).

Even if your products are outside the RoHS regs, you may still have
a problem.

Yes, we will move to lead free anyway for this reason. My concern as a
small producer is the transition period. Some of our component reels
could have lasted for years in principle, at the rate we use them! We
can throw away the cheap parts, and use up some of the expensive ones
before the deadline. But we do have stocks of semiconductors in
particular that we would have liked to keep using, for however long
they last. But at the same time we would rather buy new stock as
lead-free, provided we can use it in the same (SMT) process. (I don't
know if this will work, yet. Opinion seems to be "probably".)
 
J

Joerg

Jan 1, 1970
0
Hello Spehro,
Or maybe lobbying from Alcatel or whoever.

This RoHS business is certainly going to snuff out a lot of small
enterprises over there. The big companies are unlikely to take over many
of the laid off employees because they are largely outsourced.

Considering that many countries in Europe are seeing unemployment rates
above 10% I am puzzled about how that law ever passed. It seems small
biz didn't establish enough of a lobby.

Regards, Joerg
 
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