I am getting forms from my customers asking for compositions of EVERYTHING in a complex product - resistors, caps, transistors, chips, everything.
There is no way to get the data together...
It is obvious that most companies just make up the numbers, fill in the form, sign it, and their customer has covered his ar*e and everybody is happy.
This is the biggest piece of stupidity to come out of the European f*cking "Union" - worse than ISO9000 (which few people give a damn about nowadays because everybody knows it is just a paperwork scam).
How do electronic product manufacturers here comply with this?
We stick ours in the component database along with the spec sheet. The problem we're having is that some components are listed as ROHS compliant but won't take the heat. :-0
Generally we don't... We explain to those customers that we do not have sufficient sales in their country/region to justify the costs of producing this documentation. If they are willing to cover all the costs (and we give an estimate) then we'll do it.
Well, that approach is certainly OK for a mail order business selling relatively small quantities *per customer*. These customers will never ask - in the same way as they don't care about ISO9000 etc.
The problem is if you [also] have one or two big customers. These will normally employ an in-house REACH person (usually, in the best British tradition, an anally retarded person) and these people have nothing to do all day except to make a supplier's life tricky. One has to go along with it.
What I don't get is how one collates all data on every component. And even if one did, one could never change the brand - think of doing that for say SMT resistors which come from a wide variety of different companies.
A google search turns up a load of REACH consultants - another great British tradition in the making :)
We're getting this from Japan, too. Forms to fill out, listing milligrams of stuff we never heard of.
We can't use solder coated boards for some customers, and tin coating is crap to solder. So we go with gold. But under the gold is a nickel barrier layer. And nickel is apparently bad stuff too
REACH applies to substances manufactured or imported into the EU in quantities of 1 tonne per year or more. Generally, it applies to all individual chemical substances on their own, in preparations[6] or in articles[7] (if the substance is intended to be released during normal and reasonably foreseeable conditions of use from an article)
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What do you sell that has more than a ton of any particular chemical in? If nothing REACH does not apply.
How about INTRASTAT? You have to report every inter-country sale/purchase inside EU so the damn bureaucrats can draw pretty pie charts. I hoped this bureaucratic crap and "green" idiocy would stop as soon as a serious crisis came, but it seems this one isn't bad enough.
If that is all there is to it, then this is fine. There is no way we use 1000kg of any particular chemical per year. In fact I doubt the total weight of our annual component usage - excluding PCBs and mouldings perhaps - is 1000kg.
I am amazed nobody has drawn attention to this!
However, reading the URL above:
"It is estimated that there are around 30,000 substances on the European Market in quantities of 1 tonne or more per year."
which suggests the 1000kg is the total amount entering Europe, not the total mount used by the one company.
One customer did say to me that REACH does not apply unless one is (paraphrasing) a supplier of substances e.g. solder, solvents, pastes, that kind of thing.
But this is not what my end product customers tell me...
I'm not sure either - but I have seen a several places that it is 1 tonne per importer per year. Having said that, this is the requirement for "registration". It might be that, once registered, if a chemical is "dangerous" ("of special concern" I think they call it), then *any* use has to be documented.
IANAL. My reading of REACH is things like pcbs are outside of its scope. It is haz chem legislation.
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If you manufacture or import any chemical substance in quantities above one tonne per calendar year and the substance is not exempt, you must register or pre-register it with the ECHA.
/end quote
I'm an importer into the EU so the above is all I care about and I ignore REACH.
An exporter to the EU would be in a different position. The importer would have to find out from all his non EU suppliers what chemicals they were supply so that the importer can check against their 1 tonne limit.
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Under REACH a printer cartridge is considered an article whereas an aerosol spray or a fire extinguisher are not articles but are containers with preparations. Some assistance in the form of guidance documents and a Manual of Decisions will be available but there will always be circumstances which are uncertain.
Most importantly, a producer or importer of an article has to register the substance(s) within an article if the substance is intended to be released during normal and reasonably foreseeable conditions of use and if the total amount of that substance exceeds one tonne per annum per producer or importer.
Well, I have found something which looks pretty clear.
I believe that REACH simply does not apply to companies who manufacture electronic products.
Please see this UK Govt site
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This explains clearly that REACH affects only
1) Chemical manufacturers, and
2) Importers of chemicals into the EU who import more than 1000kg per chemical, and
3) Users of chemicals (pains, solvents etc)
If this really is the case, then the electronics industry has been on a wild goose chase, driven by all the usual axe grinders (consultants).
I have a customer (the huge U.S. Emerson company) which is hassling their entire supplier base for safety data sheets, and is demanding that they prepare SDSs even for things like temperature controllers - basically a circuit board in a box. The SDS has to contain advice on what to do in case somebody eats it and crap like that. They have said there are NO exceptions.
You are right, consultant driven crap bought into by the big companies who's staff are semi trained clueless monkeys. Said monkeys request/demand SDS because they wouldn't know a hazard if it climbed up their leg and nested in their underwear.
Is it REACH or the WEEE recycling initiative. I would not have expected REACH to affect you unless you are selling bulk chemicals into the EU. But there are a few things in electronics that might raise eyebrows - BeO paste inside some high power devices and on heatsinks for instance.
You may be able to find enough info on the ECHA website to head off any ludicrous requests from halfwitted drudges who have probably sent the questionaire out to everyone they do business with.
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It was marginally better than BS5750 which was basically like ISO9000 but without the international recognition. All the costs of implementation and none of the benefits for international exports. My boss was very proud of the 2m^3 of controlled documentation that his new quality empire produced. I had to maintain my copy :(
Strange thing is that ISO9000 !=3D Quality. It may guarantee reproducibility if you are lucky and the operatives follow the procedures to the letter. They might even manufacture adequate product if the procedures are correct.
An ISO9000 heretics guide to making toast.
Insert thick sliced bread in toaster and switch on.
When flames and smoke are seen switch off.
Extract toast.
Extinguish flames.
Scrape blackened burnt parts off until toast is uniform brown matching shade card #1
You now have a reproducible ISO9000 procedure for making toast. ISTR there was some additional paperwork too.
I have seen manufacturing procedures that were not all that different. They enshrined existing bad practices in the "quality" procedures and then because it was too much hassle to change the paperwork it fossilised. Another take on ISO 9000/5750 from an even more jaundiced perspective is online at:
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The Japanese quality system works by encouraging small incremental improvements to both process and design. You would be surprised how effectively 100 1% improvements compound up (small changes that Western companies tend to ignore). 1.01^100 =3D 2.7x
You don't ignore INTRASTAT if you get caught by it unless you like paying fines. But you have to exceed a threshold of business to get dragged into it. I don't know the current threshold but I only got caught by it for one twelve month period a few years back.
I don't think WEEE is mandatory for electronic products sold to trade users. At least I see a lot of smoke but no sign of anything being made mandatory. If it was, the outcome would simply be that customers return the product to us and we chuck it in the skip. In reality, they will chuck it in their skip instead because the shipping charges are not worth it.
I think that is very good :)
Basically, under ISO9000 you could make a product which self destructs in 6 months, and provided that is written into your quality manual, you cannot be denied certification.
The basic problem is that all the firms which made crap, adopted ISO9000 first, and used it as a quality marketing tool. This debased it into a totally meaningless process.
It still lives on, because a lot of jobs (people not capable of doing a real job) are in it and these people are well dug in. But the pressure from customers to adopt it seems to have gone. I just don't see it anymore. Their QA man still sends you a questionnaire every year, where you tick boxes like "do you segregate defective product" (YES SIR, we mix it up with the good stuff and send it all out) because he is paid GBP 40k for doing it. But only the biggest customers give a damn. I imagine if you wanted to sell 100k telephone sockets / year to British Telecom you would need iSO9000.
I have occassionally looked at the avionics business too. I would avoid major-level products but there is a lot of PMA stuff one could make. PMA is like ISO9000 but harder, and hard to do in Europe because the inspectors have to come over from the USA.
ROHS is another one. A lot of smoke but it has settled. Everybody is now "compliant" - the Chinese stick ROHS stickers onto cartons of toilet rolls. The press still carries scary articles about enforcement, written by the usual axe grinders (ROHS consultants) but I doubt anybody reads them anymore.
Fortunately, Europe has never put any resources into enforcement of this crap. Places like Italy, Spain, France ignore the regs anyway. The UK tends to gold plate all regs but even the UK has never got hard on checks.
The Japs are more dedicated and seem to avoid Euro-style pointless job creation. Europe gets bogged down in cynical crap, supported by lots of expenses-paid conferences.
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