Judging by the number of e-mails Electronics Weekly receives each week, the legislation and timetables around the RoHS and WEEE Directives are still causing a lot of confusion.
EW is inviting readers to raise issues related to the Directives, compliance and enforcement. Dr RoHS and a panel of experts will try to clarify issues and get to the bottom of problems you have brought to our attention.
If you have a query, please send it to dr.rohs@electronicsweekly.com Please note that we can only answer questions that are published in the magazine or on this page of the website.
June 8, 2006
Dear Dr RoHS
Our company designs and manufactures test and monitoring products for the television broadcast industry.
There are portable and fixed versions, the later being designed to be screwed permanently into a 19in rack with other devices.
Do the fixed devices which are intended to be placed on the market as a single functional commercial operating unit come outside the scope of RoHS requirements?
Steve Nunney
Hamlet Video International
Dr RoHS answers
This is a difficult one to answer as the scope of the WEEE and RoHS Directives are not entirely clear and the answer may depend on each country’s definition of fixed installations.
The UK NWML www.rohs.gov.uk site gives the following advice: “The intention of the fixed installation exclusion follows the same principles as the exclusion for vehicle mounted equipment. ‘Products that become part of a product that is outside the scope of the directive are outside the scope of the directive’. In the case of fixed installations the intention is that the product becomes part of the fabric of the building.
“Once fitted is the equipment discernable from the rest of the building or has it become part of the building? If a business were to move would they be likely to move or leave the product? Lifts, electric doors and gates etc are fixed installations, fitted kitchen appliances, large fixed equipment, cctv camera systems are not.”
Dr RoHS thanks www.eco3.co.uk and the NWML at www.rohs.gov.uk for their help with this answer.
May 26, 2006
Dear Dr RoHS
I noted the article in the current Electronics Weekly regarding monitoring and control device exemption from RoHS.
Our business is instruments for electrostatic measurements and as such we had understood that we came within Category 9 exemption.
To change to full compliance will take time and quite a lot of effort and cost for us as a small company. Is there any indication of a likely timescale at which compliance is likely to be required?
To achieve this by July would be quite unreasonable. Any guidance will be much appreciated.
John Chubb
John Chubb Instrumentation
Dr RoHS answers
Take a look at http://europa.eu.int/comm/environment/waste/weee_index.htm.
Almost at the bottom of this page is a reference to a study: Review of Directive 2002/95/EC (RoHS) for the possible inclusion in the scope of this Directive, equipment which falls under categories 8 and 9 set out in Annex IA to Directive 2002/96/EC (WEEE).
Click on Presentation by ERA Technology to read what the European Commission is reading.
May 22, 2006
Dear Dr RoHS
My question is simple, the answer may not be so.
If we produce equipment which itself is not electronic or electrical in nature, but is used on assemblies which include those components, do our non-electrical/electronic components also have to be RoHS compliant
And if so, where is the documentation to prove this.
James Tinker
Design Engineer
Norgren
Dr RoHS Answers
It is the final equipment that is important. If the final equipment has to be RoHS-compliant, then everything in it has to be RoHS-compliant, except for a few specific exemptions.
Go to http://europa.eu.int/comm/environment/waste/weee_index.htm for documentation to prove this.
May 19, 2006
Dear Dr RoHS
We are a manufacturer/supplier of wiring harnesses, control panels, power supplies etc to the caravan and motor caravan industry, and I have been informed by one of our American suppliers that caravans and motor caravans fall under the vehicle directive.
This I am informed does not have to comply with RoHS until 2007. Could you please clarify this?
Terry Hardy
BCA Leisure
Dr RoHS replies
Motorcaravans come under the end of life vehicles (ELV) Directive and not RoHS.
I am informed that the DTI’s RoHS specialist recently said that caravans are outside the scope of RoHS. You should e-mail your question to www.rohs.gov.uk to confirm this.
You need to study the ELV Directive. It is separate from RoHS and I know almost nothing about it. Products you make that are installed anywhere else may need to be RoHS-compliant.
Dr RoHS thanks www.eco3.co.uk for its help this week
May 11, 2006
Dear Dr RoHS
Our company develops and manufactures devices that are connected to water meters for the purpose of remote monitoring of water consumption, as well as for detection of potential leaks. The equipment does not perform any function when not connected to a water meter.
Our understanding is that this type of equipment is a monitoring and control device (as per Category 9) and as such we would currently be exempted from RoHS compliance requirements. We also understand that since this product is fixed to the meter or to a wall, it could also be considered as a fixed installation, which might also have some influence on the issue of RoHS compliance.
Yarum Locker
CEO
Miltel Communications
Dr RoHS answers
The water meter is highly likely to be Category 9 (Monitoring and control instruments) and therefore outside the scope of RoHS.
However, reading between the lines of your e-mail, it looks to me as though your product is a radio. Category 3 includes: “Other products or equipment of transmitting sound, images or other information by telecommunications.”
If that radio was part of the water meter, it would not be covered by RoHS. If it is attached to the water meter, it becomes a moot point and there may not be a clear answer until a similar situation is tested in the courts.
Across the EU, Category 9 has been interpreted differently by various bodies. Because of this, the Commission has initiated a study into this Category (as well as Category 8 - Medical devices) with a view to tightening the Directive if need be.
Could it be part of a fixed installation? Maybe in this case it could be. You need to read all the literature in the light of your detailed product knowledge.
A note on the Fixed Installation exemption.
A large number of companies seem to think that putting wall mounting lugs on the back of equipment allows it to be exempt. The Commission’s WEEE FAQ description of a Fixed Installation includes the phrase: “not intended to be placed on the market as a single functional or commercial unit”.
You have been warned.
Dr RoHS thanks www.era.co.uk for its help this week
May 03, 2006
Dear Dr RoHS
The directive mentions an exemption for voltages over 1,000Vac and 1,500Vdc. How does this come into play?
Using an Industrial X-ray machine as an example. Most of the machine runs off standard line voltage, but some of the parts run at very high voltage.
Can the supplier of the X-ray tube claim an exemption because it runs off high voltage? Can some of the driving circuitry be exempt?
Bart Dring
Engineering Manager
MCL
Dr RoHS answers
If the equipment runs off standard line voltage, and it is not in an exempt category for other reasons, it has to comply.
Within the equipment, certain parts may have exemptions for other specific reasons, but there is no exemption for sub-assemblies just because they produce or operate at high voltage within equipment. For example, CRT anode voltage generators in televisions are not exempt.
Although I am prepared to be corrected on this: I feel it very unlikely that an industrial X-ray machine would be exempted as a large scale industrial tool unless it was made specifically only ever to be used as part of something big like a particular production line.
April 19, 2006
Dear Dr RoHS
Can unleaded BGA solder balls potentially grow tin whiskers as tin plated leads do? Annealing seems to be the standard approach for pure tin plated lead devices, but what about BGAs?
Are unleaded BGA joints as reliable as leaded? I hear all sorts of problems after n thermal cycles and that they are brittle.
David Cooke
Surrey Satellite Technology
Answer
Even tin-lead solder can potentially grow tin whiskers. It has, but it is extremely rare. So tin-inclusive lead-free solder balls cannot be guaranteed free from the possibility of tin whiskers.
However, I phoned around and no one I asked remembers hearing of a lead-free solder ball growing a whisker. Lead-free and lead-inclusive joints are differently reliable, neither being superior in all circumstances.
Lead-inclusive solder might have an edge with large BGAs under fast thermal cycling as it is more flexible than lead-free, and I have recently heard rumours - which I cannot substantiate and know no more of - regarding lead-free joint reliability under drop testing.
You may have to organise testing aimed at your particular environment. If you are already using that particular BGA in lead-inclusive form, do you need to change?
I would be interested in feedback from readers who have had reliability problems with lead-free BGAs on otherwise reliable assemblies. Or from anyone who knows more about drop test reliability.
Dr RoHS thanks www.twi.co.uk and www.lead-free.org
April 12, 2006
Dear Dr RoHS
We are a manufacturer of marine hydraulic steering components. These are hydraulic pumps, linear actuators and cylinders driven by 12v or 24v dc electric motors and switched using solenoid valves.
This equipment goes on to be installed in marine vessels and is used to steer them via computer controlled navigation systems.
I can understand that the electronics in the navigation systems will need to be RoHS compliant, but do our components?
Clive Morley
Hydraulic Projects, Devon.
Answer
According to NWML, marine craft are outside the scope of RoHS except for the hand-held torpedo engines used by divers. Hence any equipment solely used in these is also outside the scope of the regulations.
If the same sub-assembly is used in a product within scope then those units would need to be compliant - however that does not seem likely in this situation.
Dr RoHS thanks www.eco3.co.uk for its help with this answer
April 7, 2006
Dear Dr RoHS
We were informed last week by one of our chip suppliers that they are not taking a specific chip family to lead-free but are instead requiring all users to place end-of-life purchases. And there is no technology available replacement. Do I correctly recall reading about exemptions pertaining to technology availability constrains?
Jerry Pearson
QuVIS
Answer
According to my information, more than 70 exemptions along these lines have been requested, and none have been granted.
It costing money to design-out the lead-inclusive component is not justification for an exemption.
The justification for an exemption it that there is no technical alternative.
If, for example, doing without the lead-inclusive chip means a new circuit with two chips instead of one, there is a technical alternative.
Dr RoHS thanks ERA Technology for its help with this week's answer.
March 31, 2006
Dear Dr RoHS
Can you please advise as to the penalties that EU states will impose on manufacturers which ship banned leaded parts into the EU after July 1?
Ken Hartman
Intersil
Answer
For the UK, section 14 of the RoHS Regulations (linked from www.rohs.gov.uk) is the important part. Unravelling the paragraph references:
A producer putting non-compliant EEE on the market on or after 1st July 2006 shall be liable on summary conviction to a fine not exceeding the statutory maximum, which the Home Office tells me is currently £5,000. Or “on conviction on indictment to fine” - there is no statutory maximum.
Producers failing to provide documents showing compliance within 28 days of an official request shall be liable on summary conviction to a fine not exceeding level 5 on the standard scale. Level 5, coincidentally, is also £5,000 at the moment.
Failing to retaining technical documentation for four years after EEE has been put on the market is also a not-exceeding-level-5 fine.
Other EU states have widely differing penalties for similar infringements.
March 23, 2006
Dear Dr RoHS
Chromate plating and percentage by weight. Our company manufactures rubber parts that have metal inserts for which customers are requesting RoHS compliance. The metal inserts are steel, brass, or aluminium.
Some of the metal inserts are plated with zinc chromate for anti-corrosion. Do we need to breakdown the chemical make-up of the metal and calculate the per cent by weight of the end rubber moulded part?
Renee Ludwig
Chemist
Lavelle Industries
Answer
No. You have to find the percentage by weight of the banned substance within whatever it is homogeneously part of.
For example, the weight of Cr(VI) within the plating, not within the rubber-steel-plating assembly.
Judging by the mail bag, the subject of chromium-based plating is giving a lot of people headaches - particularly as some plating system makers claim their coatings are RoHS compliant while others say identical coatings are non-compliant.
The facts are: chromium as Cr(VI) is banned by RoHS. Chromium as Cr(III) and Cr(0) (metallic) are not banned.
Chromium based platings are applied as Cr(VI) - mostly as chromate or dichromate. The plating process converts some or all of the banned Cr(VI) to legitimate Cr(III) or Cr(0). If less than 0.1 per cent of the finished weight of the plating is Cr(VI), you have a compliant plating.
X-ray fluorescence (XRF) testing will tell you if a plating has any Cr. Non-trivial wet chemistry is needed to tell how much of the Cr is Cr(VI).
Careless wet chemistry can change the oxidation state of Cr(VI) to Cr(III) and give false results. Chromate plating solutions are yellow, dichromates are orange. If a plating looks yellow or orange, it is worth checking for excess Cr(VI).
Dr RoHS thanks Soldertec Global for its help with this answer.
March 16, 2006
Dear Dr RoHS
As far as repairs are concerned on product put on the market before 1 July, these can be carried out using leaded components and lead solder throughout the rest of the item’s life.
But if you have no lead, are there any reliability issues concerning the use of lead-free solder on leaded components or boards already worked with leaded solder?
For example, in two or three years’ time we will not have lead solder and lead-inclusive components, but may be asked to repair a board built, say, today. Clearly we will not be able to strip the entire board, nor can we ensure we have ridded the work area of lead. How will we know what solder to use and how well it will work long term?
Jim Bennet
Aerial Controls
Answer
Repair of lead-inclusive boards with lead-free solder is possible, but bear in mind that higher temperatures or longer soldering times will be required so tracks and pads are more likely to lift, particularly on older boards.
Avoid lead-free solders that include bismuth as Pb and Bi can interact and result in weak joints, particularly on boards that operate at high temperatures. Experiences with using SnAgCu alloys on lead-inclusive boards suggest joint reliability will not be significantly worse than tin-lead joints.
Remember lead-free boards are not inherently more or less reliable than lead-inclusive boards. Which type is most reliable depends on many component, board and environmental factors.
If you need it to repair equipment placed on the market before 1 July, SnPb solder is unlikely to disappear from sale entirely as it is still required for military and aerospace equipment, although it may become more expensive. Your stock control will have to ensure Pb does not get into new products.
Dr RoHS thanks www.twi.co.uk for its help with this week's answer.
March 8, 2006
Dear Dr RoHS
I am concerned that the response to the question posed by you in Electronics Weekly of 22/02/06 indicates that ‘fire & intruder alarm systems’ are in the scope of the RoHS regulations.
In the majority of cases such equipment is considered to be an ‘electrical installation’ or ‘components’ thereof and thus out of the scope of the regulations.
With respect to RoHS specifically, all components of such systems are to be considered Group 9 equipment.
Martyn Rowe
Novar EDS
Answer
In the most recent Commission RoHS TAC meeting, it became clear that several member states think ‘fixed installation’ is only relevant when applied to the category 6 exemption for large-scale stationary industrial tools. This means, at present, some countries say alarm systems are covered by RoHS and others say not.
On the subject of RoHS grey areas - inclusions and exceptions not clearly listed in the WEEE Directive (Dr RoHS 15/02/06) - part of your Due Diligence reading should be a document called: ‘Guide to the implementation of directives based on the New Approach and the Global Approach’ - known the ‘blue guide’.
Carefully look at pages 15 and 16 of the blue guide: ‘Scope of New Approach Directives’ - particularly, in this case, the third paragraph which starts: “A combination of products and parts....”
In the RoHS Directive, the paragraph on the first page beginning “(5) The available evidence indicates...” is also important here - this refers to the definition of WEEE in the WEEE Directive.
Although in broad agreement, Member States differ on the interpretation of some of the finer points of RoHS. There is no Right Answer yet in many cases.
The blue guide is available here.
Note: RoHS is not a New Approach Directive. Although very similar, it is actually an old approach Directive and therefore not covered by the 'Blue Book'.
However, although there is no real link, the Blue Book is increasingly being used as non-legally binding guidance for RoHS as there is no useful official European alternative.
March 03, 2006
Dear Dr RoHS
We are manufacturers of cable management products. For example: control panel trucking, cable ties, sleeving, labelling and marking.
I am aware that under the WEEE directive, any of these products containing the banned chemicals must not find their way into the waste.
However, as they are not electronic do I have to mark them with the wheelie bin?
Probably over 80 per cent of our products will find their way into a control panel or similar piece of equipment as a way of managing the cables that are installed.
Philip Seymour
SES Sterling
Answer
Any of these product containing the banned chemicals must not be inside products covered by the RoHS Directive and placed on the market after 1 July 2006.
The WEEE wheelie bin logo is applied at the finished product level: For example the monitor, computer, keyboard and mouse of a PC need the logo. The circuit boards inside do not.
If your cable management products contain any materials or components listed in Annex 2 of the WEEE Directive they will need to be removed from final products when they are recycled.
If 20 per cent of your products go into equipment covered by RoHS, those customers are going to require RoHS compliant stock. You will have to supply it or lose the business. Why not go fully RoHS-compliant and supply these to all of your customers regardless of the type of equipment.
If your products are used alone, not inside finished products, the situation is complex and unclear. Read the Enforcer’s FAQ at www.rohs.gov.uk, and also the Commission’s FAQ.
The only situation where the components you mention need not comply for sure is if they were to be used in a product which was outside the scope of RoHS or exempted -for example: ‘fixed installations’ or ‘monitoring and control equipment’.
For ‘fixed installation’, see last week’s Dr RoHS column below.
Dr RoHS thanks www.eco3.co.uk for this week's answer
February 21, 2006
Dear Dr RoHS
There is some confusion over two exemptions in the RoHS Directive. What is the difference between ‘large-scale industrial tools’ and ‘fixed installations’, which both have RoHS exemptions?
Answer
Aside from the European Commission’s version, reproduced in last weeks Dr RoHS column, there is little official guidance on what constitutes large-scale stationary industrial tools.
RoHS enforcers NWML (National Weights and Measures Laboratory) have spoken to the Commission, the Commission’s Technical Adaptation Committee and the DTI and generated guidance which is available in its Decision Tree at www.rohs.gov.uk.
A large-scale stationary industrial tool, according to NWML, should meet all of the following criteria:
It should consist of a combination of equipment, systems, products and/or components. This does not include a singe discrete tool such as a lathe, milling machine or pillar drill, however large.
- Be a tool and not be covered under any other category.
- Be required to be fixed to operate safely or within specification.
- Be of ‘large-scale’ - where large scale is related to throughput rather than size.
- Require professional installation.
- Only be used in an industrial environment.
- Be built to perform a specific task.
A fixed installation, according to the Commission’s FAQ is “a combination of several equipment systems, finished products and/or components assembled and/or erected by an assembler/installer at a given place to operate together in an expected environment to perform a specific task but not intended to be placed on the market as a single functional or commercial unit.
Examples of fixed installations are:
- Power station
- Domestic electrical supply systems (ring mains, fuse boxes and meters)
- Lifts or escalators
Fire and intruder alarm systems are however not ‘fixed installations’.
NWML is using this fixed installation definition for its enforcement policy but warns; "This opinion is open to amendment at any time and there is no obligation to provide any transition period for compliance. Our best advice is that products which fall within this category should work towards full compliance.”
A fallible, non-definitive, but useful litmus test is that a fixed installation is something a company would leave behind when moving.
For example a lift is a fixed installation. A mixing desk in a recording studio, although screwed down, is not a fixed installation.
February 14, 2006
Dear Dr RoHS
I have a question whether our product is in the exemption or not. We ship our products to Europe about five or six systems per year. Our products are equipment for the professional movie industry, not for consumer.
Also, our products will be used by the limited people who is familiar with the film handling and in a limited special environment.
But our products have a PC inside, and transfer the image data to storage with a LAN. Is our product applicable in the exemptions?
Yoshio Tagaya
Electronics Engineer
Imagica, Tokyo.
Answer
Question 1.4 of the European Commission’s WEEE and RoHS FAQ asks: ‘Do WEEE and the RoHS Directives apply to electrical and electronic products for professional use?’.
The official answer is: While WEEE is generally a consumer Directive, ‘the RoHS Directive does not differentiate between households or professional [electrical and electronic equipment], so products for professional use are covered by the RoHS Directive.’
Your products must be compliant.
Dr RoHS thanks ERA Technology www.era.co.uk for its help this week
NB: The Commission’s FAQ has the mysterious, barrister-funding status of non-legally-binding guidance. Ignore this at your peril
Dear Dr RoHS
Our company manufactures voice coil and we have to use high melting point (HMP) solder for soldering a copper plate. The problem is HMP solder is not RoHS-compliant but we have to use it because it can stand high temperatures.
We’re looking for high temperature lead-free (300°C) solder. Would you advise us? And, can you explain exemption 9 for us?
Loudspeaker voice coil maker A-Ton
Thailand
Answer
Lead in high melting temperature type solders (tin-lead solder alloys containing more than 85 per cent lead) are exempt from the directive.
January 30, 2006
Dear Dr RoHS
We use SAVBIT solder to connect 0.05mm self fluxing enamelled wire to terminals in small transformers. If we use conventional solder the surface of the copper dissolves into the solder so the wire is “necked” just where it enters the joint, making the wire extremely fragile and easily damaged.
The high copper content (1.5%) of SAVBIT prevents this happening. We have tried various RoHS compliant solders including one with 3% copper and none of them are as good as SAVBIT, can you offer any suggestions?
Elsewhere in the same transformer we use high melting point solder which contains more than 85% lead, apparently we can continue to use this. Can one obtain a similar concession for SAVBIT.
Denis Sharp
Roband Electronics
Answer
There is no clear answer unless your assembly is only used in RoHS-exempt products. Finding a solder with even higher copper content is a possibility.
If the assembly can withstand 300°C, the high-melting point (HMP) solder used elsewhere is also a possibility and would be legal. Tinning the wire with HMP solder then soldering it to the assembly with lead-free solder would produce a non-compliant mix.
Can you first plate the wire with a barrier material like nickel and then solder with lead-free solder? Applying for an exemption like the one for high-melting point solder is a lengthy process and is extremely unlikely to be granted by the RoHS deadline, although if there is no technical alternative you could have a case.
Dr RoHS thanks Soldertec Global for its help this week
January 25, 2006
Dear Dr RoHS
We produce a range of add-in boards, the latest ones being designed and built RoHS compliant.
Three months down the line, multiple units sold, installed in Europe and US, customers happy, a component distributor writes to us stating that the components they sold us were in fact not RoHS compliant as the manufacturer got it wrong.
Check back to our parts list where we luckily embedded the manufacturers PDF data sheet and distributors web page reveals that they both stated the parts were RoHS compliant, which is why they were chosen.
Checking today reveals both manufacturer and distributor say non-RoHS compliant. We have changed the part for new builds but are not too sure what to do about boards in the field?
Answer
If all the non-conforming product is already with its final user before the RoHS deadline, there is no problem.
If your customers are going to add the non-compliant boards into products that are within the scope of the RoHS Directive and will be sold within Europe after the deadline, they need to be compliant. So you need to warn your customers.
If the non-compliant boards are to be sold to consumers in Europe after the deadline for the consumer to add into a consumer product, the situation varies somewhat from Member State to Member State depending on how the add-in board is added to the consumer product. You will have to find out State by State. For the UK, use the decision tree at www.rohs.gov.uk.
January 18, 2006
Dear Dr RoHS
The term ‘put on the market’ would seem to have given some manufacturers a get out clause in terms of RoHS compliancy as I understood it.
We buy end product from a manufacturer, who themselves get the items made in China. They are saying to us that so long as they bring product into the EU, and then can have it available for sale by 30th June 2006, this product is OK to be non-compliant in terms of materials.
In other words, they can sell it after 1st July, so long as it landed in the EU before this date. If we decide to stay with this supplier, we then cannot state to our customers that post 1st July sales are compliant, and it seems to me this kind of interpretation encourages stock pile of finished goods.
John Swindale
Operations Manager
Sarabec Ltd
Answer
Your Chinese manufacturer is correct, several year’s stock could be imported, and this situation is seen as a loophole which counts against European manufacturers.
Some European equipment makers have decided to level the playing field by setting up their own distribution companies to enable them to make the legally-crucial financial transaction - effectively with themselves - before 01/07/2006.
France, we are told, has decided the French border rather than the EU border will count in its legislation, although this may prove to be illegal.
Dr RoHS thanks Eco3 for its help with this question. www.eco3.co.uk
January 11, 2006
Dear Dr RoHS
We are a small company manufacturing PO3000 type electromechanical relays which are still used in the manufacture and maintenance of mining equipment, railway signalling, power station controls and lift controls. We use cadmium in silver cadmium oxide [SCO] contacts for certain mining applications.
The mining equipment manufacturers are unwilling to change from SCO contacts because of the cost of getting their product re-approved. Most of the newly manufactured mining equipment is for export outside the EU.
We should very much appreciate any clarification you can give on our position.
Bruce Griffin
Managing Director
Telerelay (Sales)
Answer
Annex C of the DTI RoHS guidance now includes an exemption which allows cadmium and its compounds to be used in electrical contacts. This was included following a European Commission decision to bring the RoHS Directive in line with the Marketing and Use Directive.
So you can continue to use SCO in your contacts.
However, RoHS exemptions are only granted where there is no technical alternative to a banned substance, and in the next batch of ‘exemption requests’ a firm has applied for cadmium’s exemption to be cancelled as it claims a viable alternative now exists. A decision will be made after technical scrutiny.
Large-scale industrial tools are also exempt from RoHS - see paragraph 16 of the guidance.
A few readers have had trouble downloading the latest version of the Government’s RoHS guidance notes. If this includes you, try going to www.dti.gov.uk/sustainability/weee, then scroll down to the fourth paragraph of ‘Latest Information’ and click on the last link.
December 14, 2005
Dear Dr RoHS
With the RoHS directive looming in 6 months time, I have a very specific question that I cannot find a clear answer to. One product that we manufacture uses an obsolete integrated circuit with Pb-tinned leads. The component is no longer manufactured and there is no replacement available. I can still get the component on the surplus markets.
Can I continue to use it after 1st July 2006? I understand that the product must comply in all other respects, my question specifically relates to using obsolete components in existing designs where no alternative is available. The product is an assembled and tested PCB for industrial controls, which my customer uses in their systems.
Gerald Coe
Director
Devantech
Answer
Industrial instrumentation and controls are exempt from the RoHS directive. If the equipment was not exempt, you would not be able to use the component you describe - unless its lead was only in high melting temperature solders containing 85 per cent or more lead by weight.
Be aware that using lead-inclusive components in an otherwise lead-free process can cause unreliable joints through the formation of fragile lead alloy layers within the joints. It also contaminates solder baths.
Chemical process are available to remove lead from the exposed parts of chip lead-frames before placement to improve joint reliability. This does not make the component RoHS-compliant as encapsulated lead-frame parts still have the Pb coating.
Dr RoHS thanks Soldertec Global for its help.
December 7, 2005
Dear Dr RoHS,
Our company manufactures testing equipment for the rubber and plastics industry. Our instruments are manufactured in America and we sell them in Europe. We are classed as producers. I am unsure how we are to comply with WEEE, my understanding is that if we have branch sales offices in European countries they are responsible for the WEEE in their country.
I am sure that our sales people in these offices would not know how to, or have the time to, carry out this task; so we will need a central management system set probably in the UK. So how do we go about registering for a scheme to handle our WEEE? Do we have to register each of our branch offices as they are all potentially 'producers'? (Article 3 section (i) 1 2 and 3)
It would be difficult to estimate how much WEEE we are likely to recover each year as most of our instrument sales do not lead to the old instrument being scrapped. They are normally moved to a different part of the manufacturing process within the company.
Pete Goddard
Quality Manager
Alpha Technologies.
Answer
Each of your EU sales offices is a 'producer' and has to register in their own country. If they re-sell to another EU country, the importer in that other country takes on producer responsibility.
UK registration with the Environment Agency starts in January 2006. You will have to declare the value of UK net sales in 2005, the net weight of your products, the WEEE category, and the breakdown of your sales that are business-to-business or business-to-consumer. You will be charged a fee for registering.
In each EU country, either join a compliance scheme (www.weee-forum.org for Europe-wide help); pay a recycler and get proof of recycling; or go DIY and develop your own provision for recovery and recycling. There is no collection target as such, but you have to show you have provision to recover and to recycle.
End-user duty is to direct equipment appropriately at end-of-life. Your duty is to ensure the end-user knows how to return equipment or send it to your contracted recycler, waste company or compliance scheme - for example by including return contact details on the equipment or its instruction booklet.
Dr RoHS thanks RID UK and ECO3 for their help
November 30, 2005
This week I received two questions on related subjects
Dear Dr RoHS,
How does the Directive affect hardware service or repair for products supplied before July 2006, that may contain the banned substances?
For example are NiCad batteries to be withdrawn from sale as this would affect all the Braille notetaker products that I service, and are we expected to use lead-free solder on older boards that used tin/lead solder?
Dave Godfrey
Blazie
Dear Dr RoHS,
Can a lead-free component be converted to lead-compatible by re-tinning it? Some say yes, others say no.
I have a big problem with this: we are still servicing products made in 1950. In the music industry, things never become obsolete, they may go out of fashion for a few years, but they always come back.
Having to hold dual stock of spare parts is going to be a big headache.
Kevin Aston
Technical manager
JHS & Co
Answer
The RoHS Directive says that non-compliant parts and solder can be used to repair, refurbish or upgrade equipment put on to the market before the RoHS deadline next July. Batteries are specifically not covered in the RoHS Directive, as they are dealt with by separate battery Directives.
However, the WEEE Directive states all batteries must be removed during recycling.
The existing battery Directives do not ban NiCd cells, so Mr Godfrey can continue to use them. However it is thought that the incoming battery Directive, slated for 2008, will ban cells containing over 20ppm of Cd from portable equipment.
Is a Braille notetaker medical equipment? If so, it could be exempted in the forthcoming battery Directive - or how about re-designing for NiMH cells?
As for Mr Aston's question on tinning: lead-free components are completely compatible with lead-inclusive processing, with a few exceptions including BGA packages. For the record, if you want reliable joints and no solder bath poisoning, lead-inclusive products are incompatible with lead-free processing.
Dr RoHS, who thanks ERA Technology for its help
November 23, 2005
Dear Dr RoHS
When the RoHS compliance takes place in July 2006, is there a symbol that has to be present on the product that proves that it is abiding by these rules?
Craig McQuiston
Technical support engineer
Amperor (Europe)
Answer
The answer is no, there is no special symbol. All products have to be compliant - except for the few that are exempt from the Directive - so there is no need to differentiate between them.
However, items covered by the WEEE Directive, and produced after its deadline of August this year, should already be carrying the crossed-out wheelie-bin symbol.
Dr RoHS