RoHS Compliance

[mpm]

I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

 

[Phil Allison]

mpm wrote:

I almost hate to bring this topic up.

** Bound to start a feud.

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright?

** Very likely, even a milligram of Cadmium does the trick.

One tiny CdS photocell wipes out approval in the EU.



..... Phil

 

[Mikko OH2HVJ]

mpm <mpmillard@aol.com> writes:

Question: Any chance this will pass RoHS, or does the lead solder kill
that idea outright? And if it doesn't, which other components should
I check first to rule in/out RoHS compliance, to save some time. In
other words, which common PCB RF components, or cabinet/enclosure
parts typically have trouble meeting RoHS?

Leaded solder alone is most probably enough. There are some exemptions
for medical and measurement/control equipment, but even those will be
much tighter starting 2021-07-22.

Other parts to check are any special components (power RF transistors,
optoelectronics and any older components - I would give the whole BOM
a quick check - component manufacturers and distributors generally have
easily accessible data.

From other parts like metal parts and connectors, look especially for
cadmium and hexavalent chromium platings.

Some aluminum alloys like 2011 (easy to machine) contain too much lead.

This is not a comprehensive list, but hopefully will help you find
something to CYA.

--
mikko OH2HVJ

 

[Robert Baer]

mpm wrote:

I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

As i vaguely remember, the idea was to sow that the amount of
prohibited stuff did not exceed so many TONS per year...
So,,,,if you sell only a few pounds of a thinggie per year you are safe.

 

[TTman]

On 23/07/2019 01:57, mpm wrote:

I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

ROHS means no lead...on anything.My old company had to reball 'leaded
only' BGAs (e.g.) with lead free balls to maintain ROHS compliance...
Seems ROHS is the least of your worries... FCC CE etc.

---
This email has been checked for viruses by Avast antivirus software.
https://www.avast.com/antivirus

 

[Chris Jones]

On 23/07/2019 10:57, mpm wrote:

I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

lead solder = fail.
There - saved you looking up the components, saved you testing.

Your remaining hope is if the non-compliant product falls into a
category that is exempt, but you shouldn't get your hopes up too much.

You might find something useful here, though likely out of date:
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf
I think the exemptions are on page 17.

Also:
https://2016.export.gov/europeanunion/weeerohs/rohsinformation/index.asp
https://www.gov.uk/guidance/rohs-compliance-and-guidance

I think you might get away with putting the loose parts and PCB into a
bag and telling your customer that it is a "kit" to assemble themselves,
but it doesn't sound like that sort of a product!

If you don't have a representative or office or dealer in Europe, then
the liability would fall onto whoever imported it, presumably the
customer, i.e. not your problem, but depending on the country it is
fairly likely to get impounded, especially in Germany.

 

Mikko OH2HVJ <mikko.syrjalahti@nospam.fi> wrote in
news:m2h87dp63q.fsf@mspro.home:

mpm <mpmillard@aol.com> writes:

Question: Any chance this will pass RoHS, or does the lead solder
kill that idea outright? And if it doesn't, which other
components should I check first to rule in/out RoHS compliance,
to save some time. In other words, which common PCB RF
components, or cabinet/enclosure parts typically have trouble
meeting RoHS?

Leaded solder alone is most probably enough. There are some
exemptions for medical and measurement/control equipment, but even
those will be much tighter starting 2021-07-22.

Leaxed solder is NOT permitted, and few get exempted. Military
(not medical AFAIK)gets exempted. Oddly enough, leaded solders are
still permitted for repairs. That allowance may have since been
killed too though.

snip

Some aluminum alloys like 2011 (easy to machine) contain too much
lead.

0.2 % is too much?

 

On Tuesday, 23 July 2019 01:57:50 UTC+1, mpm wrote:

I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

Lead solder? No chance, unless it's an exempted product. For RoHS compliance you need something demonstrating compliance of every part you use. The odds of random stuff bought anywhere complying are almost zero. Note that taking a Chinese supplier's word for it is not permitted in a lot of cases. Some plastics you can wave through if the Chinese mfr says so, but the ones that are liable to contain banned substances you can't. You can however take the word of reputable domestic companies.


NT

 

[Clive Arthur]

On 23/07/2019 01:57, mpm wrote:

I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

A comment.

Is there a practical test for lead solder? I mean, if I have a board
and I need to check, is there anything I can do without expensive
equipment? Some sort of indicator paper?

It's particularly important for high temperature work because of the
melting points, lead-free being considerably higher than tin/lead
(though very high melting point solder is nearly all lead).

Cheers
--
Clive

 

[Joerg]

On 2019-07-23 05:37, Chris Jones wrote:

On 23/07/2019 10:57, mpm wrote:
I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in
our User Manual. Problem is, that has not been tested. (And we're
unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then
half of them unique). The engineer who designed it did so without any
attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from
China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder
kill that idea outright? And if it doesn't, which other components
should I check first to rule in/out RoHS compliance, to save some
time. In other words, which common PCB RF components, or
cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks,
ITAR stretch to the point of breakage, FCC emissions, exaggerated
performance specifications, etc....) This isn't a consumer product,
so I'm not /that/ worried about liability, but if this baby is going
to fail RoHS --- and I'm betting it will spectacularly --- I would
like to be able to point to something definitive and say (with
absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?


lead solder = fail.
There - saved you looking up the components, saved you testing.

Yup. That's a hardcore fail. End of the game unless this is re-designed.

[...]

--
Regards, Joerg

http://www.analogconsultants.com/

 

[Joerg]

On 2019-07-23 09:04, Clive Arthur wrote:

On 23/07/2019 01:57, mpm wrote:
I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in
our User Manual. Problem is, that has not been tested. (And we're
unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then
half of them unique). The engineer who designed it did so without any
attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from
China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder
kill that idea outright? And if it doesn't, which other components
should I check first to rule in/out RoHS compliance, to save some
time. In other words, which common PCB RF components, or
cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks,
ITAR stretch to the point of breakage, FCC emissions, exaggerated
performance specifications, etc....) This isn't a consumer product,
so I'm not /that/ worried about liability, but if this baby is going
to fail RoHS --- and I'm betting it will spectacularly --- I would
like to be able to point to something definitive and say (with
absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

A comment.

Is there a practical test for lead solder? I mean, if I have a board
and I need to check, is there anything I can do without expensive
equipment? Some sort of indicator paper?

https://www.koslow.com/lead-in-solder-kit-1553.html

It's particularly important for high temperature work because of the
melting points, lead-free being considerably higher than tin/lead
(though very high melting point solder is nearly all lead).

Lead-free has other issues as well and is, therefore, not used for some
hi-rel jobs.

--
Regards, Joerg

http://www.analogconsultants.com/

 

[Martin Riddle]

On Tue, 23 Jul 2019 17:04:06 +0100, Clive Arthur
<cliveta@nowaytoday.co.uk> wrote:

On 23/07/2019 01:57, mpm wrote:
I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

A comment.

Is there a practical test for lead solder? I mean, if I have a board
and I need to check, is there anything I can do without expensive
equipment? Some sort of indicator paper?

It's particularly important for high temperature work because of the
melting points, lead-free being considerably higher than tin/lead
(though very high melting point solder is nearly all lead).

Cheers

You can use the '3M leadcheck' test kit, only a few bucks.
I've used it on pcb blanks to check for HASL lead solder.
Tests positive right away if lead is in the HASL finish.

Cheers

 

George Herold <gherold@teachspin.com> wrote in
news:a8047e4f-b0b1-4e12-a035-6b2a2e5b3886@googlegroups.com:

On Tuesday, July 23, 2019 at 9:00:18 PM UTC-4,
DecadentLinux...@decadence.org wrote:
George Herold <gherold@teachspin.com> wrote in
news:ba71d4c5-8137-43ca- 9f5c-8696f37cf53c@googlegroups.com:

When selling to Europe, should we change solder (and flux!),
charge more, and worsen the specs and performance?

How does it do that?
How does the Rohs flux increase the leakage?
I'm not sure.

Does it matter?

No. How does it "worsen the specs and performance"?

You are the one who said it, so it must matter.

 

[George Herold]

On Tuesday, July 23, 2019 at 9:00:18 PM UTC-4, DecadentLinux...@decadence.org wrote:

George Herold <gherold@teachspin.com> wrote in news:ba71d4c5-8137-43ca-
9f5c-8696f37cf53c@googlegroups.com:

When selling to Europe, should we change solder (and flux!),
charge more, and worsen the specs and performance?

How does it do that?

How does the Rohs flux increase the leakage?
I'm not sure.

Does it matter?
George H.

Other than long term reliabilty?

conductivity difference? A non issue.

So what differs? Tin whiskers?

 

George Herold <gherold@teachspin.com> wrote in news:ba71d4c5-8137-43ca-
9f5c-8696f37cf53c@googlegroups.com:

When selling to Europe, should we change solder (and flux!),
charge more, and worsen the specs and performance?

How does it do that? Other than long term reliabilty?

conductivity difference? A non issue.

So what differs? Tin whiskers?

 

[George Herold]

On Tuesday, July 23, 2019 at 3:23:10 AM UTC-4, Mikko OH2HVJ wrote:

mpm <mpmillard@aol.com> writes:

Question: Any chance this will pass RoHS, or does the lead solder kill
that idea outright? And if it doesn't, which other components should
I check first to rule in/out RoHS compliance, to save some time. In
other words, which common PCB RF components, or cabinet/enclosure
parts typically have trouble meeting RoHS?

Leaded solder alone is most probably enough. There are some exemptions
for medical and measurement/control equipment, but even those will be
much tighter starting 2021-07-22.

Huh,
Let's say* I'm a small company selling a small amount of stuff to
Europe. (~10% of total sales) I've got a low leakage front end... ~pA.
That uses Kester 44, on the sensitive bits.
When selling to Europe, should we change solder (and flux!),
charge more, and worsen the specs and performance?
I can't imagine a small company, wanting to jump through
to hoops of an exemption.
George H.
*this is all purely hypothetical.

Other parts to check are any special components (power RF transistors,
optoelectronics and any older components - I would give the whole BOM
a quick check - component manufacturers and distributors generally have
easily accessible data.

From other parts like metal parts and connectors, look especially for
cadmium and hexavalent chromium platings.

Some aluminum alloys like 2011 (easy to machine) contain too much lead.

This is not a comprehensive list, but hopefully will help you find
something to CYA.

--
mikko OH2HVJ

 

[mpm]

On Tuesday, July 23, 2019 at 2:04:44 PM UTC-4, Joerg wrote:
> Yup. That's a hardcore fail. End of the game unless this is re-designed.

Thanks Joerg,
That's what I thought.

I suspect the boss is going to claim RoHS anyway.
And I'm not going to go to war with him over it.
.... nor am I going to sign any paperwork.

He's a know-it-all type, and always has at least 50 different options or versions of any one product iteration in his head at any one time (none of which he effectively communicates to the entire team, just portions here and there as ideas (and that's a graceful way to put it) pop into his head. Very frustrating to work with somebody like that. He does not listen, (I assume that's because he already knows everything?)

And then, when things blow-up spectacularly (as they nearly always do, like this morning when an eval board shipped prematurely without the correct firmware loaded), he likes to point everywhere but inward. Conveniently, he completely forgets the "I told you so's". Because by his sheer will, everything will work fine - or so he believes. No appreciation for doing things correctly. If there's a shortcut, he'll take it. No doubt about it.

Add to this, he has completely unrealistic timelines for new product development. I think if he could, he'd want that invisibility cloak out by next Thursday, even if the product manual isn't quite ready by then. He's kind of an asshole when you stop to think about it critically. Just successful enough to boast, money-wise, but anyone in the know would expect revenues and profits of at least 30x better, if he'd just run it right. "Con-man" comes to mind. All talk, but no substantive engineering.

I might have to find something else to do pretty soon.
It's all starting to wear on me a bit. The pay is actually pretty good, or I would have already left!

Thankfully, not all my eggs are in this particular basket.

 

[Jasen Betts]

On 2019-07-23, Clive Arthur <cliveta@nowaytoday.co.uk> wrote:

On 23/07/2019 01:57, mpm wrote:
I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

A comment.

Is there a practical test for lead solder? I mean, if I have a board
and I need to check, is there anything I can do without expensive
equipment? Some sort of indicator paper?

Visit a paint store, they have a cheap DIY test for lead.

It's particularly important for high temperature work because of the
melting points, lead-free being considerably higher than tin/lead
(though very high melting point solder is nearly all lead).

leaded and lead free solders are available at a variety of melting
points. some low some high

--
When I tried casting out nines I made a hash of it.

 

[Robert Baer]

Jasen Betts wrote:

On 2019-07-23, Clive Arthur <cliveta@nowaytoday.co.uk> wrote:
On 23/07/2019 01:57, mpm wrote:
I almost hate to bring this topic up.
But, I'm getting pressure from the boss to state RoHS compliance in our User Manual. Problem is, that has not been tested. (And we're unlikely to.)

It's basically one circuit board, RF, with about 700 parts (more then half of them unique). The engineer who designed it did so without any attention whatsoever to RoHS. It is 6-layer surface mount RF4 (from China), with lead solder throughout.

Question: Any chance this will pass RoHS, or does the lead solder kill that idea outright? And if it doesn't, which other components should I check first to rule in/out RoHS compliance, to save some time. In other words, which common PCB RF components, or cabinet/enclosure parts typically have trouble meeting RoHS?

There are of course other ethical challenges with the boss, (CE Marks, ITAR stretch to the point of breakage, FCC emissions, exaggerated performance specifications, etc....) This isn't a consumer product, so I'm not /that/ worried about liability, but if this baby is going to fail RoHS --- and I'm betting it will spectacularly --- I would like to be able to point to something definitive and say (with absolutely no grey area!), I TOLD YOU SO!

Any ideas, comments or suggestions?

A comment.

Is there a practical test for lead solder? I mean, if I have a board
and I need to check, is there anything I can do without expensive
equipment? Some sort of indicator paper?

Visit a paint store, they have a cheap DIY test for lead.

It's particularly important for high temperature work because of the
melting points, lead-free being considerably higher than tin/lead
(though very high melting point solder is nearly all lead).

leaded and lead free solders are available at a variety of melting
points. some low some high

See attached for temperature info.

 

[Clive Arthur]

On 24/07/2019 07:29, Jasen Betts wrote:

<snip>

leaded and lead free solders are available at a variety of melting
points. some low some high

Yebbut off-the-shelf 99C is good for 180'C ambient operation with plenty
of margin for self heated parts, off-the-shelf 60/40 isn't. Also lead
free parts don't need to be re-tinned, the whole RoHS lead thing has
made life easier for some.

Cheers
--
Clive