ROHS - are the exemptions useful?

[Peter]

Hi All,

Like everybody here in Europe we have to face lead-free components and
solder from July 2006.

The list of exemptions (e.g. www.rohs.gov.uk) is however interesting.
Monitoring and control equipment is exempt, for example, and this
could cover a LOT of stuff.

What I wonder however is whether this will be useful. Like similar
scams (ISO9000 and CE being good examples) these tend to be run (in
big companies, anyway) by less than brilliant people who are just damn
grateful for having a job pushing bits of paper, and they will ignore
the exemptions and demand literal compliance. It's like requiring a
vendor of toilet paper to have ISO9000 - a common thing in many big
firms where some dickhead has built themselves an empire around this.

Would it be legal to issue a certificate of compliance which is false,
but in fact the product would have been exempt anyway (or a convincing
argument could be made for it to be exempt), or is a differently
worded certificate mandatory in such cases? In general, for example in
personal taxation in the UK if no tax is actually due, one cannot
prosecute for a false declaration if nothing is actually wrong.

I am already seeing the expected alarmist news articles, coming out of
the usual axe grinders, saying that a certificate of compliance will
not be sufficient and that a purchaser needs to do a bit more
(suprise, suprise, this is then explained as paying a specialist x-ray
lab to physically verify) that the stuff one is buying is really
lead-free.

It's the CE (EMC compliance) axe grinding circus all over again.

Any views?

 

[Paul Burke]

The list of exemptions (e.g. www.rohs.gov.uk) is however interesting.
Monitoring and control equipment is exempt, for example, and this
could cover a LOT of stuff.

Everyone with the money to employ someone to make out a case is applying
for as many exemptions as they can get. Because the law is a total
cockup from beginning to end, and was probably only carried through
because someone thought they could please the environmental lobby and
put a bit of trade protection in place at the same time.

less than brilliant people who are just damn
grateful for having a job pushing bits of paper, and they will ignore
the exemptions and demand literal compliance.

I see that you can buy little testing kits that use a dye indicator to
ceck for lead. Just what the idiots want, they'll sell thousands.

Would it be legal to issue a certificate of compliance which is false,
but in fact the product would have been exempt anyway

No. That's what the law is for. However, no one will enforce the law in
most European countries. Only in Britain, where "manufacturing industry
is oudated, we are in a post- industrial economy", will it be fully
enforced. Elsewhere it will be used to do down competitors, check
imports etc. etc.

paying a specialist x-ray
lab to physically verify) that the stuff one is buying is really
lead-free.

All for a few hundred milligrams of lead. Which is safe anyway, that's
why the lead lining of the Roman spring at Bath was still intact when
they excavated it ( they sold the lead as scrap!).

I've already got an 8 week hold on a project because some connectors)
single sourced, silly me) selected last December have suddenly
disappeared. The manufacturer has not yet relaesed the RoHS version, and
none of the distributors want to hold stocks of the leaded version, so
I'm stuuffed until they get them in.

Paul Burke

 

[John Devereux]

Hi All,

Like everybody here in Europe we have to face lead-free components and
solder from July 2006.

The list of exemptions (e.g. www.rohs.gov.uk) is however interesting.
Monitoring and control equipment is exempt, for example, and this
could cover a LOT of stuff.

What I wonder however is whether this will be useful. Like similar
scams (ISO9000 and CE being good examples) these tend to be run (in
big companies, anyway) by less than brilliant people who are just damn
grateful for having a job pushing bits of paper, and they will ignore
the exemptions and demand literal compliance. It's like requiring a
vendor of toilet paper to have ISO9000 - a common thing in many big
firms where some dickhead has built themselves an empire around this.

Would it be legal to issue a certificate of compliance which is false,
but in fact the product would have been exempt anyway (or a convincing
argument could be made for it to be exempt), or is a differently
worded certificate mandatory in such cases? In general, for example in
personal taxation in the UK if no tax is actually due, one cannot
prosecute for a false declaration if nothing is actually wrong.

Well I would think that you could not legally "issue a certificate of
compliance which is false". However, it might not *be* false to say
something with lead in it is "RoHS compliant" if it is the RoHS
legislation *itself* that specifies the exceptions.

I am already seeing the expected alarmist news articles, coming out of
the usual axe grinders, saying that a certificate of compliance will
not be sufficient and that a purchaser needs to do a bit more
(suprise, suprise, this is then explained as paying a specialist x-ray
lab to physically verify) that the stuff one is buying is really
lead-free.

It's the CE (EMC compliance) axe grinding circus all over again.

If it is anything like that, then we can expect the deadline to be
delayed by several years... But in fact I think this will be
different.

- the device manufacturers and distributors seem to be pushing it. I
don't think they want to make/stock both lead and lead-free
versions of product.

- Assemblers won't like to mix the processing because of the potential
for cross-contamination. They will want to just go one way or the
other.

 

[Robert Baer]

Well I would think that you could not legally "issue a certificate of
compliance which is false". However, it might not *be* false to say
something with lead in it is "RoHS compliant" if it is the RoHS
legislation *itself* that specifies the exceptions.




If it is anything like that, then we can expect the deadline to be
delayed by several years... But in fact I think this will be
different.

- the device manufacturers and distributors seem to be pushing it. I
don't think they want to make/stock both lead and lead-free
versions of product.

- Assemblers won't like to mix the processing because of the potential
for cross-contamination. They will want to just go one way or the
other.

And then there is the fact that a given "RoHS" part may have totally
different and non-compatible dimensions compared to the "old" part...
Just gloss over the additional possibility that other parameters may
also cause havoc...
BTW, put head in sand concerning the three different ways that tin
can grow (shorting) shiskers...

 

[PeteS]

I have seen some manufacturers using the entire RoHS situation as an
excuse to push customers into the 'latest' parts by discontinuing
existing parts (that are non-RoHS compliant) with the (quite
reasonable) excuse that they don't want the expense of upgrading every
part, so they are only upgrading (if that's the word) the newer parts.

Of course, that simply means lots more work for engineers as most of
these newer parts are not 100% form, fit, function compatible with
their elder brethren.

Cheers

PeteS

 

[Ian Bell]

Not just everyone in Europe but everyone who want to sell any electronics
good to Europe i.e. China, Japan, Taiwan, Mexico etc etc.

Ian

 

[John Devereux]

Not just everyone in Europe but everyone who want to sell any electronics
good to Europe i.e. China, Japan, Taiwan, Mexico etc etc.

Yes, and because of the hazards of mixing the two processes, and the
disadvantages of maintaining twice as many product lines, it seems to
me that everyone is going to have to go this way.

 

[Barry Lennox]

Hi All,

Like everybody here in Europe we have to face lead-free components and
solder from July 2006.

The list of exemptions (e.g. www.rohs.gov.uk) is however interesting.
Monitoring and control equipment is exempt, for example, and this
could cover a LOT of stuff.

What I wonder however is whether this will be useful. Like similar
scams (ISO9000 and CE being good examples) these tend to be run (in
big companies, anyway) by less than brilliant people who are just damn
grateful for having a job pushing bits of paper, and they will ignore
the exemptions and demand literal compliance. It's like requiring a
vendor of toilet paper to have ISO9000 - a common thing in many big
firms where some dickhead has built themselves an empire around this.

The exemptions could be useful, and I work with one company that could
clearly claim an exemption. However, there are two problems:

A competitor will go lead-free and suddenly you are at a real
marketing disadvantage, depending upon the markets desire for green
wankola.

A large percentage of component vendors cannot be bothered with Pb and
Pb-free parts and are simply changing to 100% Pb-free. I don't know
how industries that are wanting to stay with Pb and have solid
exemptions (eg, the Military) are going to get on.

Would it be legal to issue a certificate of compliance which is false,
but in fact the product would have been exempt anyway (or a convincing
argument could be made for it to be exempt), or is a differently
worded certificate mandatory in such cases? In general, for example in
personal taxation in the UK if no tax is actually due, one cannot
prosecute for a false declaration if nothing is actually wrong.

You may get away with it, it will be some time before prosecutions are
started, if ever.

I am already seeing the expected alarmist news articles, coming out of
the usual axe grinders, saying that a certificate of compliance will
not be sufficient and that a purchaser needs to do a bit more
(suprise, suprise, this is then explained as paying a specialist x-ray
lab to physically verify) that the stuff one is buying is really
lead-free.

It's the CE (EMC compliance) axe grinding circus all over again.

Any views?

Agree, the whole thing is a tub of crap, dreamed up by Bungling
Brussels Eurocrats. There is. AFAIK, no evidence that lead leaches out
of electronics. They are basing the whole thing on their
"Precautionary Principle"

I have one question, if it turns out that tin whiskers and other (yet
to be found) problems affect reliability, or that the Pb-free solder
is toxic or environmentally damaging, will these Eurocrats be held
accountable?

Barry Lennox

 

[Bibico Cando]

that are wanting to stay with Pb and have solid
exemptions (eg, the Military) are going to get on.

Bullets included and spreaded everywhere...
Green is not Grrrr..een.

 

[John Popelish]

Barry Lennox wrote:
(snip)

I have one question, if it turns out that tin whiskers and other (yet
to be found) problems affect reliability, or that the Pb-free solder
is toxic or environmentally damaging, will these Eurocrats be held
accountable?

I am willing to bet a significant sum that the answer is, "No."

 

[Rich Webb]

Barry Lennox wrote:
(snip)

I am willing to bet a significant sum that the answer is, "No."

And the question shouldn't have been "if it turns out that tin whiskers
.... affect reliability" but rather "when an event that kills a lot of
attractive people can be traced to the growth of tin whiskers."
The adverse impact on reliability is pretty much already established.

 

[Robert Baer]

that are wanting to stay with Pb and have solid
exemptions (eg, the Military) are going to get on.

Bullets included and spreaded everywhere...
Green is not Grrrr..een.

You have never heard of bismuth (esp used in duck hunting)??

 

[Pooh Bear]

You have never heard of bismuth (esp used in duck hunting)??

Lead free solders including bismuth seem to be popular in Japan.

It seems the Western approach is to use tin/copper or
tin/silver/copper.

They make lousy solders though.

Graham

 

[Pooh Bear]

And the question shouldn't have been "if it turns out that tin whiskers
... affect reliability" but rather "when an event that kills a lot of
attractive people can be traced to the growth of tin whiskers."
The adverse impact on reliability is pretty much already established.

I'm already aware of several reports of unreliability traceable to lead free
soldering.

Graham

 

[Peter]

I'm already aware of several reports of unreliability traceable to lead free
soldering.

This is interesting. I gather the Japanese have been doing LF
soldering for a number of years; their cheap disk drives are as
visually perfect as one can get. What is the secret?

Is the unreliability related to PCB-level soldering? What exactly goes
wrong?

I know SMT is a disaster looking for a place to happen anyway, and the
process has to be spot on for a good yield. But if one gets whiskers
growing between the pads of a 0.5mm pitch TSOP chip, that would be
different...

 

[Rene Tschaggelar]

John Devereux wrote:




Not just everyone in Europe but everyone who want to sell any electronics
good to Europe i.e. China, Japan, Taiwan, Mexico etc etc.

Just as sidenote : Japan has introduced RoHS a decade
ago with very little noise.

Rene

 

[JosephKK]

Lead free solders including bismuth seem to be popular in Japan.

It seems the Western approach is to use tin/copper or
tin/silver/copper.

They make lousy solders though.

Graham

Japan better check up on its heavy metal toxicity. Bismuth is as bad a
lead. Galena is even worse. I have been "arm chair quarterback" looking
at the issue for about 15 years and cannot beat lead/tin solders.

 

[Robert Baer]

Pooh Bear wrote:



Japan better check up on its heavy metal toxicity. Bismuth is as bad a
lead. Galena is even worse. I have been "arm chair quarterback" looking
at the issue for about 15 years and cannot beat lead/tin solders.

Excuse me, but bismuth is used in OTC antacid medication; an
indication of the fact that it is NOT a problematic element. It is also
used as a replacement for lead in birdshot for environment friendly users.
And Galena *cannot* be worse, as it is lead ore (lead sulfide, if you
must know).

 

[Rich Grise, but drunk]

Excuse me, but bismuth is used in OTC antacid medication; an
indication of the fact that it is NOT a problematic element. It is also
used as a replacement for lead in birdshot for environment friendly users.
And Galena *cannot* be worse, as it is lead ore (lead sulfide, if you
must know).

Mmmmmmmm, cleavage...
http://mineral.galleries.com/minerals/sulfides/galena/galena.htm

;-P
Thanks!
Rich

 

[James Beck]

Japan better check up on its heavy metal toxicity. Bismuth is as bad a
lead. Galena is even worse. I have been "arm chair quarterback" looking
at the issue for about 15 years and cannot beat lead/tin solders.

Let's see bismuth is the main ingredient in PeptoBismol(TM somebody I'm
sure) and the USFWS has approved it for use in non-toxic waterfowl
loads. AFAIC, the bismuth fared even better than iron in toxicity
testing.

You are correct about lead/tin solders, but the simple fact is the EU
has ROHS in place and you gotta' play if you wanta' get paid.

Jim