RoHS in EU

Un bel giorno qbic digitò:

You should find the law for each EC member that acknowledges the european directive. For example this is the law for Italy:

Judging by article 15, it has been instituted a public committee (controlled by the parliament) that looks out for infractions. The sanctions are listed in article 16. There are "just" administrative sanctions (up to 100k euros), no jail.

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emboliaschizoide.splinder.com

100k euros? Oh my God!!! Or better "me coglioni!!!"

:)

enjoy coals

Hello Marek,

In the Netherlands there are several organizations that are involved with product safety (and are authorized to do investigation).

When it comes to products used by consumers (or assumed to be used by consumers) the "Food and Consumer Product Safety Authority (VWA)" ("Voedsel en Waren autoriteit" in Dutch) is responsible.

For radio equipment it is "Radiocommunications Agency Netherlands". When there is a direct link to financial or fiscal fraud or movement of goods, the FIOD-ECD will be involved "Fiscal Information and Investigation Service/Economic Investigation Service".

Airplanes and Ships are covered by "the Ministry for Transport and water supply"

Your sentence: "For my understanding with RoHS compliance is like with CE sign you can engrave it on your equipment until someone check it? Is it correct?" is not correct.

You are obliged to manufacture, sell or resell safe products. Most of the products can be self-certified, but that does not mean that you can do what you want. Many companies have tested their products by other parties to make sure that everything is OK, but that is not required in most cases).

When a product turns out to be unsafe, you can run into severe problems when you cannot prove that you did everything to make a safe product. Safe also means: not using hazardous materials. As a manufacturer you should be familiar with what material may and may not be used (included ROHS directive).

I am working as an independent consultant in the area of telecom and electronics, and I know there are companies that take risks to gain some additional profit.

Best regards,

Wim PA3DJS

Looks like we are working in almost the same technical area, just about

6000 miles apart. Do you also do EMI cases, possibly in Germany as well? I've got a real good EMI contact there now but it's at the Dutch coast, no idea where Maarsen is (yeah, I know, I should remember because I lived in NL...)

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Regards, Joerg

http://www.analogconsultants.com

RoHS directive also create obligations to importers in example you import equipment electronics ie. from China ... But the entity that really puts equipment to the market is the customs office. So in this case, the product which pass customs clearance, should be automatically considered as RoHS compatible :P Again - am i right or wrong? :) So who is really reponsible for RoHS : Distributor, Importer or customs officer in case of default (product checked by some enforced entity and result : RoHS test -failed). Or maby RoHS compliance documents are needed thru customs clearance process (but that i don't know).

Thanks for previous answers, im slowly getting the picture :) Marek Kubel

I am in the US so we don't have to deal with RoHS much. Probably they would go after the one they could get. For a company that does not have a subsidiary in Europe that might mean the distributor.

Don't forget one seriously motivated group: You competitors. If they suspected that something wasn't ok they might quietly buy some of your systems and run them through some lab tests, then report it if they find something wrong.

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Regards, Joerg

http://www.analogconsultants.com

Hello Joerg,

Yes you are right, competitors are an important group. I am working as a designer/consultant for 7 years now and had 4 events where competitors where involved.

I advised to change a design because of far to high near field H-field strength for a low frequency RFID design. The client wouldn't do it (they said "you with your regulations, we are doing this for years"). Almost one year later, a received a phone call from the client that they received an unpleasant phone call from a competitor.

Other 2 cases had to deal with electrical safety (EN60950). I advised a client to not use some components because of safety issues. My client disputed my advise because of 2 major manufacturers did use the same components, "so who are you to say we cannot use this components!". My client contacted one of the major manufacturers and discussed my statement. The major manufacturer is now changing his design, because they admitted they were wrong.

Another case had to do with Variable Frequency Controllers (3 phase) with 125 kHz RFID. They VFCs interfered with a circuit that I partly designed. Fortunately I could solve it by adding bulky common mode chokes and the VFC is still radiating... However, when more RFID units will be installed, the VFC installer will probably has to install the (costly) RFI filters (that he left out to be able to present a more attractive quotation).

Although this are no ROHS issue, I am sure someone doesn't like to miss turnover because of a competitor that is selling (cheaper) non- ROHS compliant goods.

For your information, Maarssen is 3 miles N of Utrecht (or about 22 miles SSE of Amsterdam). Although I do not advertise myself as an EMI specialist only, I do solve EMI problems.

I checked your site also, it is very difficult to resist clicking on "analogconsultants" when being an analog minded person myself.

Best regards,

Wim

Luckily my clients usually listen. Saves them lots of grief later, mostly the kind you just described. Occasionally they go back to stuff I had designed out like anodized aluminum which can be followed by an "oh s..t!" experience when deploying such equipment near a transmitter.

Thanks. Yes, I remember Utrecht as pretty much "the" relay point for your railways. No matter where I went the journey inevitably touched Utrecht or I had to change trains there.

Not much of a web site yet but so far serves the purpose. Clients just want a brief summary of what I do and did. But usually not even that because by the time 50% of them call their situation has percolated to emergency level, line stop or something like that. It's human, just like most of us easily procrastinate on a dentist visit until something hurts.

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Regards, Joerg

http://www.analogconsultants.com

[previous text deleted]

Hello, Marek,

When the product has been manufactured outside the EU (like China), the representative that brings the product on the EU market is responsible for the product.

When you drive to fast, you can't blame the police officer that he didn't give you a fine.

So if you are importing (and selling in the EU) a nice gadget and it turns out to be not safe (for example it sets the house in fire), you have to convince the authorities that your did everything to assure the safety of the product.

Best regards,

Wim

I've been digging around, trying to find some better info on this and came up with:

Even after reading through the FAQ, I'm still unclear on the method of enforcement. If I'm selling non-RoHS compliant electronics via a US website, and someone from Europe purchases an item and has me ship it to them, what realistic consequences would I be facing? Short of stopping future shipments at customs, I'm having a hard time seeing how this can be enforced upon anyone but the largest of manufacturers. Realistically, that's where the resources are most likely focused.

Incidentally, I don't really have a problem with the concept of RoHS, but the lead-free solders and manufacturing techniques currently available really suck. Weak solder joints, SMT connectors pulling right off the boards, and heat damaged parts are common problems I've seen on lead-free boards. The industry simply did not have enough time to come up with good replacements for lead solder and plating.

I have to wonder if this is going to become as big a joke as CE compliance? Self certification my ass...

Chris

I didn't read the whole thread, but I'll add (2) things.

First, I saw an ad recently for a piece of test equipment that (much like an infrared thermometer) you just point and shoot at the circuit board and it would tell you if it had lead, or hex-chrome, or whatever in it.

Presumably, this equip is targeted at RoHS enforcement agencies. Field teams, Customs, etc..

Next, I agree. What's the point? Bad solder, bad joints, less reliable products, etc... And for what.?!

Our product for example uses a 12-volt, 1.2Ah lead-acid battery!! That's exempt (as long as we also comply with WEEE).

But there is more lead in that single battery than in 5,000 of our actual products. So I guess as long as not more than 1:5000 forget to recycle dead batteries, we're still ahead of the game...?

Our testing agency actually wanted us to get the lead out of the inks used on our decals!! Where does the madness end?

Oh, one more thing. Apparently, if they catch you saying something is RoHS compliant when it is not, they have the right to bar your import (and your future imports!), and leave your stuff sitting at the docks. Fines we might have risked, but not the future inability to import.

Once again the idiots win.

I'd suspect you might be exempt!... Equipment sold for medical devices, or 'monitoring and control' instruments, is currently 'exempt' from the requirement to meet RoHs. The best description of all the exemptions as they currently stand, is at:

Note also, that it does not cover 'one off' equipment.

Best Wishes

messagenews:gMqdnY1137iPxv7bnZ2dnUVZ snipped-for-privacy@giganews.com...

at:

Yeah Lead free solders are pain in the ass - higher temperature, higher reactiveness with environment (faster oxidation) that leads to cold-joints. More over PB-free soldering tips that has thicker shielding and much shorter lifetime. Really crap.. Well was was told, that in several countries different institutions are enforced to check RoHS compliance. What bothers me most is that there are no rules how the audit of rohs compliance should be performed - only guidelines. I've found IEC draft IEC 62321 111/24/CD "Procedures for the Determination of Levels of Regulated Substances in Electrotechnical products" XD-XRF is standard for heavy weight elements like PB - well but in case of PBB and PBDE in case of uncertainty should be preformed by Mass spectrometry and Gas Chromatography or Liquid chromatography! In case of CR6+ there should be some kind of calorimetric testing ... For the full examination of company with product that consists about 1000 parts .. with this IEC guidelines, if this becomes obligatory, will be very expensive and time consuming. o_O

Is there any private institution in your country that can reliable determine if something is rohs compilant or not (certification agency, or whatever), in the sense that theirs results are honored by enforced government. Cheers Marek Kubel