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RoHS Directive
Old 12th March 2006
  #61
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ulysses's Avatar
Quote:
Originally Posted by brianroth
For reasons NON RoHS, I've been using stainless steel fasteners for the past umpteen (OK, maybe 10+) years.

However, I don't know if the "generic aircraft grade" SS parts are compliant. There might be some "secret sauce" involved in the manufacturing.
I've been using SS hardware for the most part, especially on the outside of the box. But there's a part here and there that has been zinc plated because it was available. Now it's time to revisit that. The good news is it gave me a chance to discover a really good local source for fasteners at better prices (and their city desk is open 24 hours - that's ridiculous but awesome).

It appears that basically all stainless steel is going to be inherently compliant. It has to have a particular composition in order to be stainless steel, and the RoHS substances aren't part of the picture.
Zinc-plated steel, on the other hand, is generally coated in hexavalent chromium (hence the term "zinc-plated") which is one of the RoHS no-nos. It sounds like they're going to have to change that stuff over to Trivalent chromium, which apparently is less hazardous, or at least less banned, than hexavalent. Who knew. But then there's all the other stuff like nickel-plated brass, yellow chromate, and all the other crap you have to talk to the lonely metallurgist guy at the manufacturer to find out about. The problem I'm having is that I'm getting strong and wide reassurances that certain hardware is clean, but what I'm not getting is Certificates of Compliance. Unfortunately it looks like the documentation package (which will end up in a landfill) is the real key to compliance with the law. But it also looks like self-declaration will be accepted until such time as a complaint or allegation is made against a product's compliance. At least, that's how the UK is asserting things.
Old 14th March 2006
  #62
Quote:
Originally Posted by Tim Farrant
Some interesting reading that may point to the fact that manufacturers of outboard equipment for recording studios are exempt under the ROHS Directive here...

RoHS info

Read section 15 iv. I am interested to hear from other manufacturers if you feel we fall into this exemption. Dan? Vince? EveAnna?

Cheers
Tim
Isn't this a nightmare?

I think it is a good thing, as this year alone, there will be more than 1.5 MILLION pounds of lead dumped into the landfills from computer motherboards and cell phones.

At the same time, none of us build enough equipment to make any difference. My conversations with the EU have returned basically the following:

Since the industry has know about this changed for several years, not being ready is not a valid reason to not comply. Since we are within 6 months of the directive being enforced, you will not be able to get your issues heard by the committee over seeing these issues. My only advice is to comply"

So there you go.

We have to get a large enough group together to show that we are the following:

1 Professional and not Commercial
(the don't have a clear definition of commercial)

2 Products lasting for more than 5 years and have a warranty that backs it up.

3 Since the accelerated testing has brought about the exemptions for computer products because they have doubts about the safety and reliability (the EU said this), we need to show several things:

a If we offer a warranty for 5 years and the long life expectancy of lead-free solder does not hold up, who pays?

b If there is a true safety issue, how will insurance companies provide product liability insurance when the EU has it's doubts about the safety.

c If the power sections fails and fails because of a lead-free related issue, is the EU going to take the liability?

4 Our products are not consumer products, because the definition of consumer products is "Consumable" which means you use them and throw them away. We are better described as "Durable Goods" which are products that are purchased to last 5 years or more. These products include cars, washers and dryers, etc.

5 Our contribution may hinge on proof that our (meaning the upper end, of which we all try to be, not the N-Box of the year type products) products are designed to last for extended periods of time and are for fixed installations or fixed in a portable package (truck or rack) for outside use.

We also have to find out how the inspection is being done, and if it is self certified.

I know that the reason the CE is self certified is because it was not created by any government, but by request by the EU and the companies that make the test equipment wrote it in such a way to sell test equipment, so the actual regulation is that you are required to have a CE sticker on the box or unit. That is the limit. Now, if someone dies and you faked it, you are dead meat.

I doubt the RoHS limits will be as relaxed, but testing would mean destroying the unit.

I know that the RoHS wave solder systems cost on in the area of $20K for a full load of solder, and the solder has to be sampled and sent out for testing on a regular basis, and if it is found to be contaminated with lead, they have to pitch it.

Also, I have a few product that are not yet RoHS, like my optos and pots, so I don't know what to do other than to ship $500K worth of stuff to my German distributor before the dealine.
Old 23rd March 2006
  #63
Moderator
 
EveAnna Manley's Avatar
 

A new 5th Consultation is out.

Go read that.
Click on some links and read what others have submitted.
Read the docs.

Go contribute some more stakeholder exemptions....
Old 23rd March 2006
  #64
I have just submitted this. Read it and use the template for your own.

Paul
Attached Files
Old 23rd March 2006
  #65
Moderator
 
EveAnna Manley's Avatar
 

Now go read this one and prepare to be impressed. Incredible work. Highly detailed. And backed up with facts, numbers, and references.

060209.39 RoHS stakeholder.pdf

That's a convincing presentation, boys...
Old 23rd March 2006
  #66
Quote:
Originally Posted by EveAnna Manley
Now go read this one and prepare to be impressed. Incredible work. Highly detailed. And backed up with facts, numbers, and references.

060209.39 RoHS stakeholder.pdf

That's a convincing presentation, boys...
Well, Evana, you are now part of EU history... the reference to "Variable-Mu" will, in 1000 years, make the finders wonder if we actually figured out how to make cows sing.

I would hope that with 77 references, these people will see that even though CE didn't work to kill imports, this just might.

I think one problem is that the industries that have exemptions are able to show technical information, and ours, even though we like to think we are smart, have few people that are as smart as George. I talked to Anna several months ago and she said that there is a 6 month lag in response and told me "good luck in getting this looked at before the dealine". Maybe GMs factual report will put some light on it's urgency.
Old 23rd March 2006
  #67
Moderator
 
EveAnna Manley's Avatar
 

Kudos are due to Jeffrey Warren who researched and wrote that exceptional presentation. Let his example inspire all of us.
thumbsup
Old 24th March 2006
  #68
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Wes Kuhnley's Avatar
 

Quote:
Originally Posted by Dan Kennedy
It's the blatant political stupidity and hypocrisy...we are talking about politicians, aren't we...
It's those damn Dem's isn't it? fukkin liberals...
Old 24th March 2006
  #69
The problem is that we are dumping millions of tons of lead and cadmium into the landfills each year. If they had done a more gradual process years ago, it wouldn't be so bad, but remember, the EU is only a few years old, before they were just called "europe". If the US cared more, we would have started this. But, since we will sit by and watch, we will also reduce our wastes because of this. The so the resulting problem is that it is too much too fast now and it has many flaws.
Old 24th March 2006
  #71
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I know, I know, but like your stuff, and EveAnna's and GML's, unless it was some bits I disposed of here at the shop, I can't think of any of it that's hit the dumpster anywhere else in the world.

And we're all controlled by hazardous waste issues already at the plants.

Jeffrey's application for exemption was certainly awesome. Didn't know he had that many words in him
Old 24th March 2006
  #72
Moderator
 
EveAnna Manley's Avatar
 

Exactly Dan.

In support of one point Jeffery made in his presentation, I also have serial number and ownership data going back to 1993 representing over 18,000 products sold. There also exists thousands more units produced between 1988-1992 at the old joint for which I do not have records for. Out of those records I do not have one example of a customer ever throwing away a Manley or Langevin unit we have ever built.

We buy annually approx 500 lbs of solder in bar form and in spool form. Discounting the weight of the rosin in the spool rosin core the annual lead
content represents about 82Kg, pretending that ALL the bar solder in the wave tank actually ended up on the boards.

Out of this 82Kg, approximately 40% of all our Manley and Langevin gear is
exported. So we export 32.8Kg of lead per year, and out of this perhaps 50%
goes to Europe, which brings us down to 16Kg of lead sent to Europe,
slightly more than my medium sized dog Max weighs, of which NONE of that ever has ended up in a landfill!

Amazing!

I would vote for Jeffery to be given a doctorate's degree based on his amazing thesis paper he drafted for the exemption committee... truly excellent work.
Old 25th March 2006
  #73
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ulysses's Avatar
I read through some of those applications and got discouraged rather quickly. Although there are some very good points in all of them, I'm pretty sure the whole pile will get tossed wholesale rather quickly on the basis of a few points the EU has made clear they don't consider valid.
For example, the "We need more time" excuse has been explicitly documented as a Lame Excuse by the European Powers That Be. In their thinking, "We passed this in 2003. Why are you now, 3 years later, telling us you need more time?"
Another example is the use of the "no suitable alternative" excuse in some of these applications. When they say "no suitable alternative" they mean, "will a ceramic capacitor still function without lead?" whereas some of the exemption applicants mean "Toshiba discontinued that part and I haven't found a stock replacement I care for." Not the same thing. If that particular component is so essential, then market forces ought to force a compliant version to market. At least, that's the logic in play. If Pro Audio is too small a niche to drive development of suitable compliant replacements, then it's too small a niche to dilute RoHS over.
I really do hope the good ideas get some serious attention though, because the argument that some EEE are not consumer electronics and not disposable is a good argument. I just don't know how you come up with a litmus test that exempts stuff like Manley and Great River (and little old RMS maybe?), without accidentally exempting the "pro audio gear" that is in fact disposable, because there's plenty of that being sold right alongside the "durable goods."
At this point, the things that bother me most are a) the documentation necessary for compliance will have a larger environmental impact than the number of good pro audio products headed for the landfill; 2) lead is hardly the most important element on a circuitboard to be kept out of landfills - what about the gold, silver, and copper? The WEEE directive makes much more sense - recycle the whole thing, reclaim and recycle the elements, eliminate the hazardous waste; and iii) we lose sleep about getting hit with a $5000 fine in the event a zinc-plated washer finds its way into the wrong unit, meanwhile UPS's are compliant because they removed the 4 grams of lead from the circuitboard beside the 4-pound lead-acid batteries.
Whatever. I'm just getting on board and not looking back. It's a pain in the ass, but this time next year it'll be a done deal and before long you'll hardly have to think about it. I'm not of the opinion that lead-free solders don't work. They will be made to work. We figured out how to make pencils and paint work without it. Not to mention gasoline. In the 21st century, circuitboards are way more ubiquitous than pencils or paint (maybe not gasoline). Like they told Indiana Jones, "We've got Top Scientists looking at it as we speak." Who? Top Scientists.
Old 25th March 2006
  #74
Lets all not forget that, yes they passed this in 2003, but when they refer to US, it isn't US, it is our suppliers. US are trying to comply. It's the old US vs. THEM again...
Old 25th March 2006
  #75
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vince @ speck's Avatar
 

Hi Guys,

Thanks for all the great posts.

I'm on this thing too, but I'm taking a slightly different approach. I've been talking to our local Department of Commerce contact here in San Diego. Personally, I just think it's too difficult of a task to handle alone without some "big-guns" on my side.

To be sure, the D.O.C. are well aware of the impact on the smaller manufacturer and our ability to export products. From my conversation with Carrie Brooks, the International Trade Specialist at our local D.O.C. office, the calls received from San Diego alone are in the 1000's.

Here is our government’s contact in Belgium. They are there to give us assistance on this RoHS predicament.

Rosemary Gallant - Commercial Officer
Chris Sherwood - Commercial Specialist
U.S. Commercial Service
U.S. Mission to the European Union
Rue Zinner 13
B-1000 Bruxelles
Fax: 32 2 513 1228
e-mail: [email protected]

I encourage you guys to contact your local Dept. of Commence office for assistance.
Old 29th March 2006
  #76
Here is a graph of compliance issues. Personally, I don't think we fit any of the requirements, as the chart shows, the closest we have is consumer products, which we are not. I think a company like Mackie or Yamaha, even Digi might have this problem, as they sell to the general public. We need to focus on the fact that we are not a consumer products and co-ordinate our efforts. I would suggest that we all place the statement on our web sites that says:

Professional Audio Products

Or

Equipment for the Professional Audio Industry

Etc.

At the same time, the directive is a good thing for the future, so doing as much as possible is helpful.
Attached Thumbnails
RoHS Directive-web_graph1.gif  
Old 29th March 2006
  #77
Lives for gear
dude....

accoridng to that chart there are tons of loopholes to think about...

-for instance 'Main Power source is electricity'. seems that passive components would be excluded. aren't caps and solder considered passive components?

-Less than 1000v AC : I thought most of my gear was about 18v ?

-my favorite : 'Forms part of equipment not included in product categories'.

Why not just say that your preamp is actually part of a computer? who would know the difference?



.....should I be stocking up on gear right now?
Old 29th March 2006
  #78
Quote:
Originally Posted by stellar
dude....

accoridng to that chart there are tons of loopholes to think about...

-for instance 'Main Power source is electricity'. seems that passive components would be excluded. aren't caps and solder considered passive components?

-Less than 1000v AC : I thought most of my gear was about 18v ?

-my favorite : 'Forms part of equipment not included in product categories'.

Why not just say that your preamp is actually part of a computer? who would know the difference?



.....should I be stocking up on gear right now?
The main power source is love...and tone...

Less than 1000 includes all that are less than...

I think it will backfire to some degree, as the manufacturers are not the problem, it's the suppliers not making parts, not able to make parts and not asking for wavers in time for parts that don't work without lead. We will have to see.

Currently, I am getting all PCBs, because I order 1000+ at a time, in a RoHS compliant form (high temp with Gold Emersion palting) just in case.
Old 29th March 2006
  #79
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Quote:
Originally Posted by stellar
-for instance 'Main Power source is electricity'. seems that passive components would be excluded. aren't caps and solder considered passive components?

.....should I be stocking up on gear right now?
Nope, just start mining plutonium. Clearly the next wave of gear will run on balanced current supplied by a small nuclear reactor.

That, or interns will start off shovelling coal to keep the mix session going.

I feel bad for all the builders. Classic case of know-nothings passing judgement as if they did, irrespective of dilligence due investigating the consequences.

Maybe you guys should claim you run off of kinetic energy applied selectively to conductive metals and the resulting ionization?
Old 29th March 2006
  #80


Actually, if you design your equipment to run off of 40-52Vdc from a bank of batteries, you don't have to be lead free. That big bank of Lead-Acid cells and whatever charges it may get regulated, though.




-tINY

Old 29th March 2006
  #81
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ulysses's Avatar
The batteries themselves don't have to be lead-free, but your battery-powered circuit still does. It doesn't say anything about the where the electricity comes from - the wall, batteries, a little nuclear power plant inside the device - it's still electricity.
Old 30th March 2006
  #82
Lives for gear
well if you go to court make sure to mention something like 'the beatles wouldn't have happened' ...
Old 30th March 2006
  #83
Gear Nut
 

So how does this apply to electronics resellers? Most of all sales at the shop are refurbished consoles. And quite a few are going to Europe. We've had problems in the past with pre-CE compliant gear being sent over there, luckily we were able to jump through hoops to prove that it would still be compliant before they were crushed, but this RoHS thing could destroy that market. Are there any exemptions for restoration of equipment? Shouldn't the reuse and recycling of these components be a better choice for keeping the harmful substances out of the landfills? All of our work is repair and refurbishing. If we can't get a hold of through hole components then more of the gear is going to end up being junked. Most of the stuff we do throw out or atleast deem unproductive to repair has all been either digital or SMT that was designed to just be tossed.
I really hope that some of the exemptions being written up by the audio community are encluding the extension of use for vintage gear. After all, most of us are still trying to copy it!!!!

-justin
Old 30th March 2006
  #84
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ulysses's Avatar
The RoHS doesn't apply to anything placed on the market before July 1, 2006. That means the European market, so the one thing I'm not sure about would be a vintage piece that had never been to Europe before. But used gear and replacement parts are specifically excluded.
Old 28th April 2006
  #85
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Rickeraptor's Avatar
 

Some will find this of interest.The post is by a "known" builder of home hi fi equipment who is EU based and has been on top of this fiasco from the start.Pretty much a lone voice in the wilderness :

http://rockgrotto.proboards39.com/in...ead=1146192462

There may be ways to work around the RoHs directive for the end product but how do we get around the fact that ALL new parts will be compliant garbage that by default will make all goods compliant anyway even if those products end up no more than high priced garbage ?
Old 26th May 2006
  #86
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gyraf's Avatar
 

Another very disturbing side-effect of the ROHS directive is the complete banning of Cadmium - an unreplaceable part of the (CdS) LDR resistor in audio-related optocouplers. Seems like optical compression is becoming a thing of the past!

Jakob E.
Old 26th May 2006
  #87
If the company shows them that the process does not work without it, then they can be excluded from the ban. It takes some effort on their part. You can also submit the paperwork when shipping.

They will allow tri-valent chromate plating, as it is less stable than hexa-valent chromate and breaks down into harmless compounds when in land fills. Hexa is very stable and breaks down into death.

Quote:
Originally Posted by gyraf
Another very disturbing side-effect of the ROHS directive is the complete banning of Cadmium - an unreplaceable part of the (CdS) LDR resistor in audio-related optocouplers. Seems like optical compression is becoming a thing of the past!

Jakob E.
Old 8th June 2006
  #88
Moderator
 
Tim Farrant's Avatar
 

Exclamation

Well only 22 days to go, has anyone here actually acheived full compliance?

From what I gather "professioanl audio equipment" is a proposed exemption, but is still waiting a formal review, what do we do in the meantime?
Old 8th June 2006
  #89
Quote:
Originally Posted by Tim Farrant
Well only 22 days to go, has anyone here actually acheived full compliance?

From what I gather "professioanl audio equipment" is a proposed exemption, but is still waiting a formal review, what do we do in the meantime?
There are 2 major things on the table right now that have not been approved but are being looked at.

1 Professional systems that have an extended life

2 A weight of .1% of the total weight of a part that can still be lead. This would mean that the main PCB with all parts soldered (not screwed) onto it is weighed, then you would be allowed .1% of the total weight of lead.

I see this as a way to use current parts, as long as you solder them in with leadfree solder, as their weight would be the minimal plating on the part, and would also include things like optos.

So far, it looks like Germany will be the tough ones.

For a violation, they have to get a complaint that has proof, then they have to buy a piece and then anylize it themselves. This was also the fear with CE but it never happened.

One thing that I have found. Gold immersion with gold plating on fingers is a pain in the ass. I lost a large contract because I couldn't deliver mic pres on time because the PC boards had to be re-made 3 times.

Also, make sure that you allow the SOLDER SIDE MASK to exclude the VIAs so they get solder flow if wave soldered. You can still mask over them on the COMP side if you prefer a cleaner looking board. It looks as if the feedthroughs will be a problem if the board is flexed.
Old 11th June 2006
  #90
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ulysses's Avatar
I just got my first batch of fully RoHS-compliant circuitboards assembled. They came out great. The solder joints aren't shiny like leaded solder joints, but examination of them confirms they're good solid solder joints. The boards actually look a lot better than the old ones because the high-temperature laminate required for lead-free solder process has eliminated the curling of the board that occurred with the old FR4 laminate in the leaded solder process.
I had to replace one component that was defective for reasons unrelated to RoHS, and I found that desoldering was quite a bit more difficult than with leaded solder. The desoldering station had no trouble melting the lead-free solder to a flowing liquid state, but the lead-free solder seems to have greater surface tension, so that more of the solder tends to remain on the pin & pad. I found this to be kind of a pain. It took a lot more time and a lot more heat to finally get the component out. On the upside, the high-temp laminate stood up to the extended rework without deteriorating like FR4 does.
So far, I'm completely happy with every compliant component I've used, and I'm completely sold on the high-temp IS410 laminate. I've also had lead-free boards assembled with leaded solder process, and that works just fine too. My only complaints right now are the documentation requirements, the failure of some American suppliers to produce compliant components in time for me to use them before July 1, and this relatively minor issue of desolderability.
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