A european question : RoHS

R

Rene Tschaggelar

Guest
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
--
Ing.Buero R.Tschaggelar - http://www.ibrtses.com
& commercial newsgroups - http://www.talkto.net
 
"Rene Tschaggelar" <none@none.net> schreef in bericht
news:429adb31$0$1152$5402220f@news.sunrise.ch...
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.
Click to expand...
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 ?
Click to expand...
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.

--
Thanks, Frank.
(remove 'q' and 'invalid' when replying by email)
 
Frank Bemelman wrote:
"Rene Tschaggelar" <none@none.net> schreef in bericht
news:429adb31$0$1152$5402220f@news.sunrise.ch...

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.
Click to expand...
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 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.
Click to expand...
That is what my impression was too.

Rene
 
"Rene Tschaggelar" <none@none.net> schreef in bericht
news:429afb29$0$1157$5402220f@news.sunrise.ch...
Frank Bemelman wrote:
"Rene Tschaggelar" <none@none.net> schreef in bericht
news:429adb31$0$1152$5402220f@news.sunrise.ch...

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.

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.
Click to expand...
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.


--
Thanks, Frank.
(remove 'q' and 'invalid' when replying by email)
 
Rene Tschaggelar schrieb:

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.
Click to expand...
You're right.

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

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.
Click to expand...
Makes no sense, but this is law meanwhile.

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.
Click to expand...
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.

It's all pretty vague stuff and many different interpretations
of the directives float around.
Click to expand...
Yes, many details have to be discussed further...

--
Dipl.-Ing. Tilmann Reh
http://www.autometer.de - Elektronik nach Maß.
 
On Mon, 30 May 2005 11:21:29 +0200, Rene Tschaggelar <none@none.net> wrote:

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
Click to expand...
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
 
Rene Tschaggelar wrote:
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 ?
Click to expand...
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
 
Rene Tschaggelar wrote:

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 ?
Click to expand...
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
 
Mike Harrison <mike@whitewing.co.uk> writes:

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


--

John Devereux
 
On 30 May 2005 20:23:48 +0100, the renowned John Devereux
<jdREMOVE@THISdevereux.me.uk> wrote:

Mike Harrison <mike@whitewing.co.uk> writes:

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).
Click to expand...
Did you see category 9 in Annex IA, and the corresponding examples in
IB?



Best regards,
Spehro Pefhany
--
"it's the network..." "The Journey is the reward"
speff@interlog.com Info for manufacturers: http://www.trexon.com
Embedded software/hardware/analog Info for designers: http://www.speff.com
 
Spehro Pefhany <speffSNIP@interlogDOTyou.knowwhat> writes:

On 30 May 2005 20:23:48 +0100, the renowned John Devereux
jdREMOVE@THISdevereux.me.uk> wrote:

Mike Harrison <mike@whitewing.co.uk> writes:

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).

Did you see category 9 in Annex IA, and the corresponding examples in
IB?
Click to expand...
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!

--

John Devereux
 
Frank Bemelman wrote:

"Rene Tschaggelar" <none@none.net> schreef in bericht
news:429afb29$0$1157$5402220f@news.sunrise.ch...
Frank Bemelman wrote:
"Rene Tschaggelar" <none@none.net> schreef in bericht
news:429adb31$0$1152$5402220f@news.sunrise.ch...

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.

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.
Click to expand...
How come network gear is exempted ?

Graham
 
"John Devereux" <jdREMOVE@THISdevereux.me.uk> wrote in message
news:87ll5wcybf.fsf@cordelia.devereux.me.uk...
Mike Harrison <mike@whitewing.co.uk> writes:

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_03720030213en0024003
Click to expand...
8.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_03720030213en0019002
Click to expand...
3.pdf
Interesting, that appears to exclude everything we, and our customers,
make (industrial test & control equipment, basically).


Yes, but....
Click to expand...

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
 
"Pooh Bear" <rabbitsfriendsandrelations@hotmail.com> schreef in bericht
news:429BBBCF.DE4DD6DA@hotmail.com...
Frank Bemelman wrote:

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 ?
Click to expand...
Mission critical stuff ;)

--
Thanks, Frank.
(remove 'q' and 'invalid' when replying by email)
 
Frank Bemelman wrote:

"Pooh Bear" <rabbitsfriendsandrelations@hotmail.com> schreef in bericht
news:429BBBCF.DE4DD6DA@hotmail.com...

Frank Bemelman wrote:


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 ?


Mission critical stuff ;)
Click to expand...
Burocrats. They have no idea what all can be
mission critical when it fails.
But you're right I guess.

Rene
 
On Tue, 31 May 2005 17:22:34 +0200, the renowned Rene Tschaggelar
<none@none.net> wrote:

Frank Bemelman wrote:

"Pooh Bear" <rabbitsfriendsandrelations@hotmail.com> schreef in bericht
news:429BBBCF.DE4DD6DA@hotmail.com...

Frank Bemelman wrote:


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 ?


Mission critical stuff ;)


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

Rene
Click to expand...
Or maybe lobbying from Alcatel or whoever.



Best regards,
Spehro Pefhany
--
"it's the network..." "The Journey is the reward"
speff@interlog.com Info for manufacturers: http://www.trexon.com
Embedded software/hardware/analog Info for designers: http://www.speff.com
 
Hello Tilmann,

But they (government) really don't care about the parts (or completely produced
gadgets) you (or any dealer) have on stock.
Click to expand...
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.

... I would hate to have the remaining
stock thrown into the landfill.
Click to expand...
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.
Click to expand...
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...
Click to expand...
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

http://www.analogconsultants.com
 
"Ian" <Ian_Buckner_not_@agilent.com> writes:

"John Devereux" <jdREMOVE@THISdevereux.me.uk> wrote in message
news:87ll5wcybf.fsf@cordelia.devereux.me.uk...
SNIP
The full details are annex 1A of the WEEE directive :

http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en0024003
8.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_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.
Click to expand...
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".)

--

John Devereux
 
Hello Spehro,

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

Or maybe lobbying from Alcatel or whoever.
Click to expand...
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

http://www.analogconsultants.com
 
Spehro Pefhany <speffSNIP@interlogDOTyou.knowwhat> writes:

On Tue, 31 May 2005 17:22:34 +0200, the renowned Rene Tschaggelar
none@none.net> wrote:

Frank Bemelman wrote:

"Pooh Bear" <rabbitsfriendsandrelations@hotmail.com> schreef in bericht
news:429BBBCF.DE4DD6DA@hotmail.com...

Frank Bemelman wrote:


I wonder how the directive applies to PC motherboards. Practically
every motherboard has an ethernet interface onboard. Voila -> network
gear.
Click to expand...
(Only just noticed this bit from Frank... Our stuff usually has an
RS485 port, does that count?)

How come network gear is exempted ?


Mission critical stuff ;)


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.
Click to expand...
That sounds more likely!

--

John Devereux
 
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