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RoHS in EU

Discussion in 'Electronic Design' started by qbic, Jun 1, 2007.

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  1. qbic

    qbic Guest

    Hello,

    Question, There is RoHS directive, (and so what) Is there present any
    entity in yours country that can enforce this directive to stop
    production or import of electronic equipment? Is there any standard
    how RoHS compliance check should be preformed?

    I've found only IPC norms regarding Materials Declaration Management
    but i haven t found any information how RoHS audit should be
    preformed.

    I know there are several companies like UL that signs RoHS
    certificates, maby you have some experience - how it was done in
    your's company.

    For my understanding with RoHS compliance is like with CE sign you can
    engrave it on your equipment until someone check it? Is it correct?


    Thanks for any help and suggestions..

    Marek Kubel
     
  2. dalai lamah

    dalai lamah Guest

    Un bel giorno qbic digitò:
    You should find the law for each EC member that acknowledges the european
    directive. For example this is the law for Italy:

    http://www.federlegno.it/servizi/una/raee/dlgs151-220705.pdf

    Judging by article 15, it has been instituted a public committee
    (controlled by the parliament) that looks out for infractions. The
    sanctions are listed in article 16. There are "just" administrative
    sanctions (up to 100k euros), no jail.
     
  3. coals

    coals Guest

    Judging by article 15, it has been instituted a public committee

    100k euros? Oh my God!!!
    Or better "me coglioni!!!"

    :)

    enjoy
    coals
     
  4. Wimpie

    Wimpie Guest

    Hello Marek,

    In the Netherlands there are several organizations that are involved
    with product safety (and are authorized to do investigation).

    When it comes to products used by consumers (or assumed to be used by
    consumers) the "Food and Consumer Product Safety Authority
    (VWA)" ("Voedsel en Waren autoriteit" in Dutch) is responsible.

    For radio equipment it is "Radiocommunications Agency Netherlands".
    When there is a direct link to financial or fiscal fraud or movement
    of goods, the FIOD-ECD will be involved "Fiscal Information and
    Investigation Service/Economic Investigation Service".

    Airplanes and Ships are covered by "the Ministry for Transport and
    water supply"

    Your sentence:
    "For my understanding with RoHS compliance is like with CE sign you
    can engrave it on your equipment until someone check it? Is it
    correct?"
    is not correct.

    You are obliged to manufacture, sell or resell safe products. Most of
    the products can be self-certified, but that does not mean that you
    can do what you want. Many companies have tested their products by
    other parties to make sure that everything is OK, but that is not
    required in most cases).

    When a product turns out to be unsafe, you can run into severe
    problems when you cannot prove that you did everything to make a safe
    product. Safe also means: not using hazardous materials. As a
    manufacturer you should be familiar with what material may and may not
    be used (included ROHS directive).

    I am working as an independent consultant in the area of telecom and
    electronics, and I know there are companies that take risks to gain
    some additional profit.

    Best regards,

    Wim
    PA3DJS
     
  5. Joerg

    Joerg Guest

    http://www.tetech.nl/
    Looks like we are working in almost the same technical area, just about
    6000 miles apart. Do you also do EMI cases, possibly in Germany as well?
    I've got a real good EMI contact there now but it's at the Dutch coast,
    no idea where Maarsen is (yeah, I know, I should remember because I
    lived in NL...)
     
  6. qbic

    qbic Guest

    RoHS directive also create obligations to importers in example you
    import equipment electronics ie. from China ... But the entity that
    really puts equipment to the market is the customs office. So in this
    case, the product which pass customs clearance, should be
    automatically considered as RoHS compatible :p Again - am i right or
    wrong? :)
    So who is really reponsible for RoHS : Distributor, Importer or
    customs officer in case of default (product checked by some enforced
    entity and result : RoHS test -failed). Or maby RoHS compliance
    documents are needed thru customs clearance process (but that i don't
    know).

    Thanks for previous answers, im slowly getting the picture :)
    Marek Kubel
     
  7. Joerg

    Joerg Guest

    I am in the US so we don't have to deal with RoHS much. Probably they
    would go after the one they could get. For a company that does not have
    a subsidiary in Europe that might mean the distributor.

    Don't forget one seriously motivated group: You competitors. If they
    suspected that something wasn't ok they might quietly buy some of your
    systems and run them through some lab tests, then report it if they find
    something wrong.
     
  8. Wimpie

    Wimpie Guest


    Hello Joerg,

    Yes you are right, competitors are an important group. I am working
    as a designer/consultant for 7 years now and had 4 events where
    competitors where involved.

    I advised to change a design because of far to high near field H-field
    strength for a low frequency RFID design. The client wouldn't do it
    (they said "you with your regulations, we are doing this for years").
    Almost one year later, a received a phone call from the client that
    they received an unpleasant phone call from a competitor.

    Other 2 cases had to deal with electrical safety (EN60950). I advised
    a client to not use some components because of safety issues. My
    client disputed my advise because of 2 major manufacturers did use the
    same components, "so who are you to say we cannot use this
    components!". My client contacted one of the major manufacturers and
    discussed my statement. The major manufacturer is now changing his
    design, because they admitted they were wrong.

    Another case had to do with Variable Frequency Controllers (3 phase)
    with 125 kHz RFID. They VFCs interfered with a circuit that I partly
    designed. Fortunately I could solve it by adding bulky common mode
    chokes and the VFC is still radiating... However, when more RFID units
    will be installed, the VFC installer will probably has to install the
    (costly) RFI filters (that he left out to be able to present a more
    attractive quotation).

    Although this are no ROHS issue, I am sure someone doesn't like to
    miss turnover because of a competitor that is selling (cheaper) non-
    ROHS compliant goods.

    For your information, Maarssen is 3 miles N of Utrecht (or about 22
    miles SSE of Amsterdam). Although I do not advertise myself as an EMI
    specialist only, I do solve EMI problems.

    I checked your site also, it is very difficult to resist clicking on
    "analogconsultants" when being an analog minded person myself.


    Best regards,

    Wim
     
  9. Joerg

    Joerg Guest



    Hello Joerg,

    Yes you are right, competitors are an important group. I am working
    as a designer/consultant for 7 years now and had 4 events where
    competitors where involved.

    I advised to change a design because of far to high near field H-field
    strength for a low frequency RFID design. The client wouldn't do it
    (they said "you with your regulations, we are doing this for years").
    Almost one year later, a received a phone call from the client that
    they received an unpleasant phone call from a competitor.

    Other 2 cases had to deal with electrical safety (EN60950). I advised
    a client to not use some components because of safety issues. My
    client disputed my advise because of 2 major manufacturers did use the
    same components, "so who are you to say we cannot use this
    components!". My client contacted one of the major manufacturers and
    discussed my statement. The major manufacturer is now changing his
    design, because they admitted they were wrong.

    Another case had to do with Variable Frequency Controllers (3 phase)
    with 125 kHz RFID. They VFCs interfered with a circuit that I partly
    designed. Fortunately I could solve it by adding bulky common mode
    chokes and the VFC is still radiating... However, when more RFID units
    will be installed, the VFC installer will probably has to install the
    (costly) RFI filters (that he left out to be able to present a more
    attractive quotation).

    Although this are no ROHS issue, I am sure someone doesn't like to
    miss turnover because of a competitor that is selling (cheaper) non-
    ROHS compliant goods.
    [/QUOTE]

    Luckily my clients usually listen. Saves them lots of grief later,
    mostly the kind you just described. Occasionally they go back to stuff I
    had designed out like anodized aluminum which can be followed by an "oh
    s..t!" experience when deploying such equipment near a transmitter.

    Thanks. Yes, I remember Utrecht as pretty much "the" relay point for
    your railways. No matter where I went the journey inevitably touched
    Utrecht or I had to change trains there.

    Not much of a web site yet but so far serves the purpose. Clients just
    want a brief summary of what I do and did. But usually not even that
    because by the time 50% of them call their situation has percolated to
    emergency level, line stop or something like that. It's human, just like
    most of us easily procrastinate on a dentist visit until something hurts.
     
  10. Wimpie

    Wimpie Guest

    [previous text deleted]
    Hello, Marek,

    When the product has been manufactured outside the EU (like China),
    the representative that brings the product on the EU market is
    responsible for the product.

    When you drive to fast, you can't blame the police officer that he
    didn't give you a fine.

    So if you are importing (and selling in the EU) a nice gadget and it
    turns out to be not safe (for example it sets the house in fire), you
    have to convince the authorities that your did everything to assure
    the safety of the product.

    Best regards,

    Wim
     

  11. I've been digging around, trying to find some better info on this and came
    up with:

    http://rswww-uk.custhelp.com

    Even after reading through the FAQ, I'm still unclear on the method of
    enforcement. If I'm selling non-RoHS compliant electronics via a US website,
    and someone from Europe purchases an item and has me ship it to them, what
    realistic consequences would I be facing? Short of stopping future shipments
    at customs, I'm having a hard time seeing how this can be enforced upon
    anyone but the largest of manufacturers. Realistically, that's where the
    resources are most likely focused.

    Incidentally, I don't really have a problem with the concept of RoHS, but
    the lead-free solders and manufacturing techniques currently available
    really suck. Weak solder joints, SMT connectors pulling right off the
    boards, and heat damaged parts are common problems I've seen on lead-free
    boards. The industry simply did not have enough time to come up with good
    replacements for lead solder and plating.

    I have to wonder if this is going to become as big a joke as CE compliance?
    Self certification my ass...

    Chris
     
  12. mpm

    mpm Guest

    On Jun 3, 8:19?pm, "Christopher Ott" <spamtrap at ottelectronics dot
    com> wrote:

    I didn't read the whole thread, but I'll add (2) things.

    First, I saw an ad recently for a piece of test equipment that (much
    like an infrared thermometer) you just point and shoot at the circuit
    board and it would tell you if it had lead, or hex-chrome, or whatever
    in it.

    Presumably, this equip is targeted at RoHS enforcement agencies.
    Field teams, Customs, etc..

    Next, I agree. What's the point?
    Bad solder, bad joints, less reliable products, etc... And for
    what.?!

    Our product for example uses a 12-volt, 1.2Ah lead-acid battery!!
    That's exempt (as long as we also comply with WEEE).

    But there is more lead in that single battery than in 5,000 of our
    actual products.
    So I guess as long as not more than 1:5000 forget to recycle dead
    batteries, we're still ahead of the game...?

    Our testing agency actually wanted us to get the lead out of the inks
    used on our decals!!
    Where does the madness end?

    Oh, one more thing. Apparently, if they catch you saying something is
    RoHS compliant when it is not, they have the right to bar your import
    (and your future imports!), and leave your stuff sitting at the
    docks. Fines we might have risked, but not the future inability to
    import.

    Once again the idiots win.
     
  13. I'd suspect you might be exempt!...
    Equipment sold for medical devices, or 'monitoring and control'
    instruments, is currently 'exempt' from the requirement to meet RoHs.
    The best description of all the exemptions as they currently stand, is at:
    http://www.pb-free.info/rohsexemptions.htm

    Note also, that it does not cover 'one off' equipment.

    Best Wishes
     
  14. qbic

    qbic Guest

    Yeah Lead free solders are pain in the ass - higher temperature,
    higher reactiveness with environment (faster oxidation) that leads to
    cold-joints. More over PB-free soldering tips that has thicker
    shielding and much shorter lifetime. Really crap.. Well was was told,
    that in several countries different institutions are enforced to check
    RoHS compliance.
    What bothers me most is that there are no rules how the audit of rohs
    compliance should be performed - only guidelines. I've found IEC
    draft IEC 62321 111/24/CD "Procedures for the Determination of Levels
    of Regulated Substances in Electrotechnical products" XD-XRF is
    standard for heavy weight elements like PB - well but in case of PBB
    and PBDE in case of uncertainty should be preformed by Mass
    spectrometry and Gas Chromatography or Liquid chromatography! In case
    of CR6+ there should be some kind of calorimetric testing ... For the
    full examination of company with product that consists about 1000
    parts .. with this IEC guidelines, if this becomes obligatory, will be
    very expensive and time consuming. o_O

    Is there any private institution in your country that can reliable
    determine if something is rohs compilant or not (certification agency,
    or whatever), in the sense that theirs results are honored by enforced
    government.
    Cheers
    Marek Kubel
     
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