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RoHS Directive
Old 2nd July 2005
  #1
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Tim Farrant's Avatar
 

Exclamation RoHS Directive

Many may or may not be aware of the RoHS Directive which takes effect 1st July 2006. In simple terms the Directive is:

The Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive was passed into law by the European Union (E.U.). It affects manufacturers, sellers, distributors and recyclers of electrical and electronic equipment containing lead, cadmium, mercury, hexavalent chrome, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE). After July 1, 2006 the use of these materials will be banned in new products sold in Europe. The RoHS Directive compliments the WEEE Directive.

There has already been some discussion on this subject in other threads, but I thought it might be useful for the manufacturers who frequent GS to discuss this issue and perhaps help each other with ideas on how we are going to deal with this.

For me, I have probably have 50,000 different components sitting my shelves (resistors, capacitors, seminconductors) which may not meet the Directive because they contain lead in the leads. What do I do about this - throw them away? Or do I stop exporting to Europe until I have used them all up?

This website has some very useful information on the subject...

http://www.pb-free.info/

Tim.
Old 2nd July 2005
  #2
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gyraf's Avatar
 

Not good at all..

It seems like all NOS tubes will be banned as well..?

Jakob E.
Old 4th July 2005
  #3
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Tim Farrant's Avatar
 

Quote:
Originally Posted by gyraf
Not good at all..

It seems like all NOS tubes will be banned as well..?

Jakob E.
Jakob,

You might be right, I am not 100% up on the construction and materials used in tubes, but no doubt they contain elements that will be restricted. Does this apply to newly manufactured tubes as well?

EveAnna, how will this effect Manley Labs' export to Europe?

Tim.
Old 4th July 2005
  #4
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Ummm....What about all the solder(which has lead in it) that keeps all this stuff together and connected?

Shane
Old 4th July 2005
  #5
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zmix's Avatar
 

Back to wire wrap...!!
Old 4th July 2005
  #6
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Tim Farrant's Avatar
 

Quote:
Originally Posted by Shan
Ummm....What about all the solder(which has lead in it) that keeps all this stuff together and connected?

Shane
Shane,

There are lead free solders becoming available now, so this is not a problem. However, from what I can gather, these solders require up to another 40 degrees C to melt compared to conventional solder. Whilst this might not seem like much, the impact it will have on surface mount construction is a major problem, because many of the small surface mount devices cannot handle the extra heat required and will simply cook.

Industry people are predicting that we will see an increase in the phyical size of some products due to this problem.

For those of us still hand soldering, we might need new irons with a bit more grunt, but at least most of the parts will handle the extra heat.

Tim.
Old 4th July 2005
  #7
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I have done (limited) experiments with the lead-free solder, and EVERY joint looks like a horrible "cold solder" result.

I am clueless about how anyone can determine if any solder joint is OK or bogus, since they now look the same.

Expect a SERIOUS loss of reliability with anything manufactured with lead-free solder since QC will be impossible. A product might test OK at the factory, but in a few months it will no longer work.

As of me, when the "writing is on the wall" here in the USA, I'll be stocking up on REAL solder...not the euro-crap!

Absolute madness...................!

Bri
Old 5th July 2005
  #8
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Tim Farrant's Avatar
 

mmmm, I must admit I have not tried the new solder - better test it out myself. Are you sure it was just not enough heat on the iron Brian?
Old 5th July 2005
  #9
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Yes, I upped the heat on my iron. Others I've communicated with also report that even a "good" solder joint looks all dull and crusty. Apparently there are great concerns about QC verification with lead free solder...all joints look equally bad!

Bri
Old 5th July 2005
  #10
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gyraf's Avatar
 

Re the vacuum tubes, I was told that the getter materials used to clean out the vacuum in nearly all tubes contains barium and cadmium. I haven't checked wether new-production tubes uses this as well, but I suspect that tradition dictates use of the same materials if available

The problem with the lead-free solder is a big one too. Not only because of the higher melting point - but simply because the strength of a lead-free solder joint is only 30% of a 60/40 one - when it's done right..!! This is why medical, telecommunication, and computer server systems are excluded from the directive. I expect much higher failure rates in commercial electronics in the years to come because of this.

Another problem is that you can't mix lead-free and 60/40 components - the metallurgy messes up and becomes very unpredictable. This means that ALL parts used should be either/or. And it will probably also be seriously problematic on the long term with repair jobs.

The optics guys are not much better off than us - they're currently fighting to get an execption on lead in optical glass (yes, "chrystal" glass is a lead/glass alloy)

Jakob E.
Old 5th July 2005
  #11
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EveAnna Manley's Avatar
 

Quote:
Originally Posted by Tim Farrant
Jakob,

You might be right, I am not 100% up on the construction and materials used in tubes, but no doubt they contain elements that will be restricted. Does this apply to newly manufactured tubes as well?

EveAnna, how will this effect Manley Labs' export to Europe?

Tim.
I think this whole thing will be a major PITA...
Our outside surface-mount shops have started changing over to Pb-free.
We haven't done much yet at our joint. The whole thought of it makes me cringe.
Old 5th July 2005
  #12
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vince @ speck's Avatar
 

If you create a “Top 10” list of the crap that we small manufacturers have to deal with, most of it comes from some bureaucracy. In this case, it's the EU bureaucracy. Small companies are in no position to fight these kinds of battles, so we should do the next best thing.... look for "loopholes" in the text of these directives and exploit them. I have found the U.S. Department of Commerce to be very helpful in these matters. When we were faced with the CE mark issue years ago, I was a little taken back (to say the least). I ultimately contacted our DOC and they took my request for help all the way to Washington DC.... for free.

The DOC wants us (U.S. manufacturers) to export as much product as we can, and they will put their team of bureaucrats to work, to fight against the EU team of bureaucrats.

Tim, I'm sure your country’s commerce counterpart feels the same.

What concerns me right now isn't exporting Speck products, but rather the future availably of raw materials for our production. We use mostly thru-hole components. I'm already talking to suppliers of connectors, resistors, capacitors that are getting a head start on RoHS compliance. They are telling me that a good chunk of they product line may be discontinued. Lead-free solder may be a moot point if we can’t get components to solder. It's just my option, but I think some vendors are looking for any excuse, such as the RoHS directive, to eliminate thru-hole components from their product line in favor of surface mount. I hope I’m wrong!
Old 6th July 2005
  #13
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Tim Farrant's Avatar
 

Vince,

I think you might be right. We use only thru hole components too. Recently I went to order some TL072 opamps in DIP package from our usual supplier. Suddenly, the MOQ from Texas Instruments had risen from 100 pcs to 20,000! Now, I am wondering if this is to do with Texas saying "well if you want us to continue making the TL072 in thru hole package pb free, then you gotta order enough to make it worth our while changing it".

I for one am going to look hard and see if I can find some loop hole in the Directive that might apply to us small manufacturers.

Tim.
Old 6th July 2005
  #14
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I performed the self assessment that is available here...

http://www.pb-free.info/survey/index.htm

There is one question in the assessment that asks;

Is the equipment part of a fixed installation?

A “fixed installation” may be a combination of several pieces of equipment, systems, products and/or components (parts) assembled and/or erected by a professional assembler or installer at a given place to operate together in an expected environment and to perform a specific task.

For example, elements of a larger permanent system that do not have a direct function (in isolation) away from the installation may be considered excluded from the scope of the Regulations.


I answered yes, thinking that most of the gear we make ends up in a studio which is generally a fixed installation with a whole lot of other interconnected equipment. This would seem to be an honest answer, a mic preamp is useless without a microphone, recorder, monitors blah blah... The self assessment returned this answer..

Your last response has indicated that your products either fall outside of the scope of RoHS, or are subject to an existing or proposed exemption.

Whilst you may apply any legitimate exemption to the products you manufacture, it should be recognised that exemptions may not be permanent and should not be relied upon as part of your overall RoHS implementation strategy. Proposed exemptions still require ratification by the European Commission.

Whilst your equipment may not be regulated by RoHS, you may be implicated in some way as the Directive will apply to the majority of volume electronics manufacturing. This may result in supply chain or other process related issues.


Could this be the loop hole we are looking for? Interesting.

Tim.
Old 6th July 2005
  #15
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2leod's Avatar
 

Wow...

Although I would think this legislation is aimed at consumer markets, I can see all kinds of issues. Could you buy, say, tubes in Hong Kong or Russia and bring into the EU with you? What about the Czech Republic and Yugoslavian tube makers - will they be able to continue manufacturing? NiCad batteries? This is a lot messier than Pb-free solder...
Old 6th July 2005
  #16
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My tirade about non Pb solder now seems short-sighted, based upon the type of work I do (custom one-offs, refurbs, rack-ups, facility construction)...I was mostly concerned about the $&*)*%^ solder required to do the projects.

The entire thought of huge amounts of through-hole catalog items simply going away is much more frightening than crappy-looking/unreliable solder connections!

Bri
Old 6th July 2005
  #17


Since I work for a huge corporation that sells $millions every quarter into Europe (though the server and Telecom exemptions may apply). We are gearing up to comply with the RoHS BS. Of course, when your production is large enough to get companies to change cataloged items, your problems are purely technological.

It sounds like recording studios and professional sound reinfrocement systems components are going to be exempted. Of course, anything that connects to the telephone system might be considered "Telecom Equipment" too.

Sounds like it might end up being a feel-good political move so the political leaders cand say "we care and we're doing something"


-tINY

Old 11th July 2005
  #18
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Larrchild's Avatar
 

http://www.pb-free.info/survey/8_popup.htm

exemptions. This looks like a real Swiss-Picnic coming soon.=(
Old 15th July 2005
  #19
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This interesting site came via one of the recordist.com mailing lists:

http://www.technosteria.org/

Bri
Old 22nd July 2005
  #20
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max cooper's Avatar
 

Quote:
Originally Posted by brianroth
I have done (limited) experiments with the lead-free solder, and EVERY joint looks like a horrible "cold solder" result.
I like to be obsessive about how my solder joints look, and I can't get the lead-free stuff to look better than a wad of chewing gum. Adding lots of heat is ok for terminating cables, but if I had to use the lead-free stuff on a board, I don't know what I'd do.

great link, Brian. Especially the article about the Military.
Old 22nd July 2005
  #21
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brianroth's Avatar
 

Max, so I'm not the only one who has decided lead-free connections look like poop!



I'm glad that lead has been removed from house paint (so as not to "harm the children") , but there seems to be a typical over-reaction to any perceived threat.

I've known more than a few "old salts" who have been breathing Kester for decades, with no ill results. OTOH, I guess that landfills loaded with broken CRTs MIGHT be a problem, although around my area, they line the landfills with clay or whatever, to keep the contents "inside".

Bri
Old 22nd July 2005
  #22
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gyraf's Avatar
 

Quote:
Originally Posted by brianroth
OTOH, I guess that landfills loaded with broken CRTs MIGHT be a problem
Yes, but CRT's are for some reason one of the very very few products excluded from the directive..!!

Jakob E.
Old 22nd July 2005
  #23
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Quote:
Originally Posted by gyraf
Yes, but CRT's are for some reason one of the very very few products excluded from the directive..!!

Jakob E.
OK, I'll admit NOT reading through the directive...1,495,800,479 page-long government bull-sh!t paper-wastes aren't my cup of tea!

So, let's see...batteries are excluded...so are CRTs? And now they're whining over the tiny amount of lead from solder????????

Geeez....no wonder the French and Dutch decided to bail/opt-out of the "union". If I'm understanding THIS tiny portion of the ...ahhh...BULL...then the entire Euro thing deserves to go flying down in flames.

From afar, in "the colonies", it is beginning to sound like a bunch of political control-freaks all got together to destroy the economy of Europe. The terrorists should be so lucky....they can save a LOT of money on explosives.

Bri
Old 28th July 2005
  #24
Quote:
Originally Posted by Tim Farrant
Vince,

I think you might be right. We use only thru hole components too. Recently I went to order some TL072 opamps in DIP package from our usual supplier. Suddenly, the MOQ from Texas Instruments had risen from 100 pcs to 20,000! Now, I am wondering if this is to do with Texas saying "well if you want us to continue making the TL072 in thru hole package pb free, then you gotta order enough to make it worth our while changing it".

I for one am going to look hard and see if I can find some loop hole in the Directive that might apply to us small manufacturers.

Tim.
Wow, I guess I better start saving all those TL072's I keep pulling from gear I refurb. Looks like a market is developing for these cast-offs. Damm, I gave away thousands of them to an artist that uses electronic components to do his "paintings". I now will save them for Tim and Vince.

Jim Williams
Audio Upgrades
Old 29th July 2005
  #25
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This came in an email earlier in the week:

http://www.newark.com/esource/jul200...C-5SV469362669

A "compliance guide" is linked from there. I haven't looked at it yet.

Bri
Old 9th September 2005
  #26
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Tim Farrant's Avatar
 

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
Old 13th September 2005
  #27
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ulysses's Avatar
Most of Section 15 applies to things that are a small part of a larger system that is not primarily an electrical system, such as a car or a train. Obviously that part wouldn't apply to us. Even if your recording studio were located on a train, it would still be covered by ROHS because the recording studio doesn't help the train to function.

Section iv discussed products that are part of a fixed installation, which could include professional recording studios but not home studios (the determining factor would be whether or not you hire a professional to install the gear). But being a part of a fixed installation is not an exemption, as far as I can tell. What they're trying to say is that if the product is part of an EXEMPT fixed installation, then the product might be exempt. Recording gear is explicitly included in the section "consumer equipment" which means that even as a fixed installation, a recording studio is not exempt.

However...
I did find a few other interesting exemptions. Ceramic components are exempt. That includes ceramic capacitors. So we could see mfgr moving over to NPO/COG caps. And "compliant pin connectors" are exempt, which sounds like it includes the likes of Molex headers and IC sockets. It looks like the solder connection to the circuit board is not exempt.

"High temperature solder" is exempt, which is solder that includes at least 85% lead by weight. Hopefully we won't see people increase the lead content to meet this exemption.

I noticed that Diodes, Inc is claiming that their 1N4007 diodes are exempt based on "4. RoHS revision 13.2.2003. Glass and High Temperature Solder Exemptions Applied, see EU Directive Annex Notes 5 and 7." It sounds like they've got some lead in the glass portion of the diode, and in the solder used internally, but that the solder finish on the leads is lead-free.

It should also be noted that spare parts for pre-ROHS gear is not covered, and neither is the resale of pre-ROHS gear.

I'm a bit skeptical about the ROHS directive actually succeeding in its goal of reducing hazardous materials in landfills. But there are industries with a whole lot more to lose who will make sure the solutions we need are found. I'm looking forward to working in a lead-free shop eventually. If that means moving to more SMT technology because it's what's available ROHS compliant, then fine.
Old 13th September 2005
  #28


Here's an angle I hadn't considered:

Today I heard a story about some jumpy managers at my (large) employer. It turns out that somebody ground up a prototype of an item soon to be released to production and found lead (oh, the horror!). In the end the lead was traced to a certain component (HF tranceiver part - didn't hear what).

It turns out that the component is exempt - and it's manufactured in the EU.....

So, it looks like a lot of this may be a protectionist racket where In-Europe manufacturers have an easier time getting an exemption.....

I should have figured.




-tINY

Old 14th September 2005
  #29
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ulysses's Avatar
It sounds more like your employer was excessively jumpy and neglected to discover they could omit the exempt components from consideration. If those components were made in the US they'd still be exempt. Nobody has to apply for exemption for their products so there's no issue of nepotism. You look at the rules, and determine whether or not they apply to your product. Suppose you make ceramic capacitors and you look at the rules and find that your product is exempt. You simply say "my product is exempt" and then other companies can use your capacitors in their otherwise lead-free products. They can then say "my product is ROHS-compliant - it's made out of lead-free components and exempt components." If the EU asks for proof, they show the documentation you provided with your capacitors and that gets them off the hook. If your declaration was wrong, that's another story. Self declaration is what makes this whole thing a lot less complicated and messy than it could otherwise be.
Old 14th September 2005
  #30


It sounds like a lot of work for nothing - certain parts are exempt. So, your RoHS compliant devices have lead in them because nobody has figured out how to make affordable NPO caps without lead or resonably long-lasting connectors without beryllium.

The self-declaration is an interesting twist. Does that mean that no-one is going to check to see if products actually are compliant?


-tINY

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