Not only can you not sell after that date but you must also be able to demonstrate that your product complies with the regulations. Its not just lead either, cadmium,mercury, hexavalent chromium, PBBs and PBDEs. You need to start to get all the documents from your component suppliers and replace what doesnt comply.
A question to the Europeans : Am I allowed to sell a gadget containing lead after the
1.July of next year when it was produced before that date ? I guess not. But if so, for how long after the 1.July.2006 ?Rene
-- Ing.Buero R.Tschaggelar - http://www.ibrtses.com & commercial newsgroups - http://www.talkto.net
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If this gadget has been 'put on the EU market' (EU customers could buy it) before 1 July you can. You can also continue buying and using (old) parts that contain lead, to produce this particular gadget, as far as I understand. A new gadget that has never been on the market before, would need to be RoHS compliant. There are excemptions too, for networking gear etc.
For eternity I'd think. RoHS should not turn existing stock into worthless junk. Existing (!) stock will end up in landfills either way so it does not make sense not allowing to sell and use it. I suppose EU hopes that, over time, old stock will run out, and new equipment will contain less lead. Practically, that is *all* they can hope for.
It's all pretty vague stuff and many different interpretations of the directives float around.
Just my 2 cents.
-- Thanks, Frank. (remove \'q\' and \'invalid\' when replying by email)
Depends on what sort of gadget it is. Contrary to a lot of press reports, it does not apply to all electronic equipment. The broad categories included are large & small household appliances, IT and telecom equipment, consumer electronics, lighting, tools, toys & leisure and automatic dispensers.
There is a lot of industrial, lab and test equipment that is not included in the above.
The full details are annex 1A of the WEEE directive :
RoHs applies to sections 1 to 7 and 10 of the above, as stated in 'scope' :
Does "this gadget" now refer to the product, or the single item ? From what you tell, it is the product. N of it already sold, M of it still on stock. Great. I would hate to have the remaining stock thrown into the landfill.
That is what my impression was too.
Rene
From my point of view it is the product. Part of the game is scaring the shit out of everybody with piles of unreadable stuff and nobody knowing for sure how the directive should really be interpreted in individual cases. Still, the directive is a succes, because soon components will only be available in lead free. Certainly 'they' expect a period where the directives are violated, manufacturers getting rid of their old stock of components. It's not worth chasing that.
I wonder how the directive applies to PC motherboards. Practically every motherboard has an ethernet interface onboard. Voila -> network gear.
-- Thanks, Frank. (remove \'q\' and \'invalid\' when replying by email)
Rene Tschaggelar schrieb:
You're right.
No. You might only use non-RoHS parts for repair.
The date limit is valid for every *individual* gadget being sold. AFAIK this means "sold to the final, private customer". Industrial customers might be able to still buy and use non-RoHS devices. This is one of the details that are still rather unclear, AFAIK. But they (government) really don't care about the parts (or completely produced gadgets) you (or any dealer) have on stock.
But that exactly is what this stupid directive says. :-(
Makes no sense, but this is law meanwhile.
That's why the directive was published a few years ago, to allow the concerned companies to switch to RoHS components and materials *before* July 2006.
However, problem is that many parts still are not available in a RoHS version, and the soldering process is the last to turn lead-free (to avoid lead contamination from the parts). This makes stock management a difficult thing today.
Yes, many details have to be discussed further...
-- Dipl.-Ing. Tilmann Reh http://www.autometer.de - Elektronik nach Maß.
The background of the question is what about the stock of products resting on my shelf. I have them produced by 20, 50, 100, whatever and they rest on my shelf rather long until sold out. This due to the cost pressure from the customers. I cannot have them produced in smaller lots. They'd be too expensive.
Rene
Did you see category 9 in Annex IA, and the corresponding examples in IB?
Best regards, Spehro Pefhany
-- "it\'s the network..." "The Journey is the reward" speff@interlog.com Info for manufacturers: http://www.trexon.com Embedded software/hardware/analog Info for designers: http://www.speff.com
If it's the same as for the CE marking issue ( which common sense dictates ) , the rule was that the non-compliant product had to be 'in the supply chain' - such as in stock with a distributor or shop - before the cutoff date. Therefore non-compliant product can continue to be sold after the cut-off date.
You can't allow any non-compliant goods out of your 'factory' after that date.
Graham
Interesting, that appears to exclude everything we, and our customers, make (industrial test & control equipment, basically).
-- John Devereux
Yes, but that is in the WEEE directive. I was more concerned with the RoHS directive, which seems to prohibit even the manufacture of certain goods. I gather that the WEEE directive is more concerned with disposal, placing the costs onto the manufacturer? I have no idea what to do about this yet... Perhaps we could send our UPS account number out with each item, then the customer can ship it back to us in 20 years time when they have finished with it!
-- John Devereux
How come network gear is exempted ?
Graham
Yes, but....
Some components are becoming _only_ available in lead-free form. Lead-free BGAs are not compatible with a lead based process, and vice versa. Other components will be very difficult to adapt to lead-free processes due to the higher soldering temperatures (electrolytics, some relays etc).
Even if your products are outside the RoHS regs, you may still have a problem.
Regards Ian
Or maybe lobbying from Alcatel or whoever.
Best regards, Spehro Pefhany
-- "it\'s the network..." "The Journey is the reward" speff@interlog.com Info for manufacturers: http://www.trexon.com Embedded software/hardware/analog Info for designers: http://www.speff.com
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Mission critical stuff ;)
-- Thanks, Frank. (remove \'q\' and \'invalid\' when replying by email)
Hello Tilmann,
It seems they also do not care much about what that does to the European economy. Which isn't in a stellar state to begin with.
That will probably also become a punishable deed. Possibly by tar and feathers because they may not be able to use prisons if the lock system electronics aren't RoHS compliant.
today.
Which means there will be some electronics that Europeans and the companies there can no longer have for a while. What an economic stimulator. For Asia ...
It would be nice if politicans became smart enough to realize that details need to be discussed and agreed upon before a law goes into effect and not afterwards. Reminds me of when I read about how they began to ban the flat-taxed small jobs in Germany. Unemployment started to sky-rocket and you could hear some politicians exclaim "oh s--t", in public.
Regards, Joerg
Burocrats. They have no idea what all can be mission critical when it fails. But you're right I guess.
Rene
Hello Spehro,
This RoHS business is certainly going to snuff out a lot of small enterprises over there. The big companies are unlikely to take over many of the laid off employees because they are largely outsourced.
Considering that many countries in Europe are seeing unemployment rates above 10% I am puzzled about how that law ever passed. It seems small biz didn't establish enough of a lobby.
Regards, Joerg
Hello John,
If that were so, I guess we'll soon see razors, electric toothbrushes and all sorts of stuff with "network capabilities" ;-)
Regards, Joerg
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