ROHS: using up non-ROHS component stocks

The product in question has been on the market for about 10 years.

It uses a microcontroller which is single sourced, and moreover is discontinued. It is not lead-free.

The manufacturer has stock of the chip for about another 10 years.

What is the ROHS situation?

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|3. This Directive does not apply to spare parts for the repair, |or to the reuse, of electrical and electronic equipment put on |the market before 1 July 2006.

also

|(11) Exemptions from the substitution requirement should be |permitted if substitution is not possible from the scientific |and technical point of view

appears to suggest that one can continue building this product.

To be entirely realistic, manufacturers of long established products, which use a chip that isn't ROHS, can't possibly just discontinue the product. That would wipe out the whole business of many smaller companies.

Am I missing something obvious?

Actually, the product I refer to falls under the "control and monitoring" exemption anyway...

The funny side of all this is the way the UK electronics trade press delights in ROHS, carrying scary articles about ROHS inspectors being equipped with portable x-ray machines. The press is probably "owned" by electronic component distributors and it is in their interest to make everybody chuck out their old stocks.

Reply to
Peter
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In message , dated Fri, 15 Sep 2006, Peter writes

Not owned, but distributors provide a very large amount of advertising income.

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OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
There are benefits from being irrational - just ask the square root of 2.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
Reply to
John Woodgate

I think it suggests you can apply for an exemption. A while ago linked somewhere from the Farnell site I looked at the complete list of current applications (to whoever the f*ck it is in the eu) for exemptions, there were about 30 of them..

One application was from an industrial printer manufacturer asking that they be allowed to continue building a particular printer for 12 months using their existing last time buy stock of about 3000 NEC V50 processor chips. They estimated the total amount of lead placed into the 'environment' would be 100g.

That 'whoever the f*ck it is in the eu' gives a shit or has a clue?

The funny side for me was watching a garden makeover program on TV a few days ago where they added a 'water feature' consisting of a large square lead bucket so heavy two men struggled to lift it and then a second one used as a planter. Recent TV adverts for a 'Lord of the Rings' chess set intricately cast in solid lead also made me laugh (or cry).

Reply to
nospam

Yes, that's why I put "owned" in quotes :)

Reply to
Peter

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Why would it put smaller companies out of business ? Is it that hard to design and manufacture leadfree ? Not really. It rather creates new opportunities. We want to build new things.

Rene

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Ing.Buero R.Tschaggelar - http://www.ibrtses.com
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Reply to
Rene Tschaggelar

Makes you REALLY wonder what is going on.. It's not like that lead will contain itself..

Reply to
pbdelete

snipped-for-privacy@nospam24.com (Peter) wrote in news: snipped-for-privacy@4ax.com:

You not the only company (small or large) that has had to redesign a product due to RoHS. The most common situation is that a part is EOL (end of life) and not available at all.

It seems that in your case, you don't have an immediate problem. I would plan for your next generation and start converting your inventory to RoHS.

We can all rant about how silly the whole RoHS rules are but it will not change anything. Its too bad that we are spending billions of dollars withoutany actual positive benefits to the environment.

--
Al Clark
Danville Signal Processing, Inc.
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Reply to
Al Clark

The problem is if you have an end of life processor (but you have enough stock of it to last you for years) which has many man-years of software in it, all written in assembler, or not portable to a newer processor for some technical reason.

It's not practically possible to redesign the product.

Christ, Amen.

Reply to
Peter

In message , dated Fri, 15 Sep

2006, snipped-for-privacy@spamnuke.ludd.luthdelete.se.invalid writes

... except the holy lead on the roofs of churches and cathedrals, of course. The run-off from those doesn't go into the environment but straight to Heaven.

But that doesn't apply to the organ pipes, which won't get back into the environment for maybe hundreds of years. They have to be lead-free.

--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
There are benefits from being irrational - just ask the square root of 2.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
Reply to
John Woodgate

In message , dated Fri, 15 Sep 2006, Rene Tschaggelar writes

It is if you can't get the lead-free parts to make them.

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OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
There are benefits from being irrational - just ask the square root of 2.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
Reply to
John Woodgate

Really,

look at a car, we are removing a few milligrams of lead from the electronics while the battery still contains pounds of lead...

Mark

Reply to
Mark

That is a similar situation to me. I use an H8/325 processor, 64-pin QFP. The annoying thing is that it may well be lead-free, but Hitachi (Renesas) "will not talk to anybody but one of their distis", and their distis either aren't interested (if you didn't buy the stock from them) or they say they can't find out. Japan moved to lead-free soldering in many areas some years ago.

What this process means is that if one can apply for such an exemption (and actually get it) then simply building the product (and declaring it exempt) isn't too bad because if somebody does pick you up for it (very unlikely) you can apply for the exemption then. There is little to lose.

If there are just 30 applications, then clearly most affected people are not bothering to apply!

As with the EM emissions/immunity regs, the only people likely to shop you are your competitors. So... the question is: who are your enemies? If you are working in a niche market, you may not have any.

All stuff I build is covered by the "control and monitoring" exemption. The indications (from the trade press) are that the electronic distribution business is lobbying the EU to block this exemption, but it will take a number of years at least. A *lot* of companies rely on the exemption; many of them are vast companies making industrial control gear (names like Siemens, ABB, Emerson, etc) and their combined turnover is more than the size of many countries.

Eventually, as with CE / ISO9000 / etc the fuss will die down, everything will acquire an ROHS sticker, and once people move to lead-free soldering it will be possible to build with leaded processor chips and nothing short of an x-ray will catch you out. And of somebody does, we have the c/m exemption anyway so no prosecution will actually be possible.

Reply to
Peter

What about the windows?

--
  Keith
Reply to
Keith

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Where ?

There are no ROHS inspectors afaik.

And yes the DTI's position is that your company should go to the wall if you can't comply. What's your product anyway ?

Draw your own conclusions.

Graham

Reply to
Eeyore

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Because small companies don't have the resources of the big ones to deal with the new problems.

It creates new opportunites for jobsworths and nothing useful whatever.

Is that all ?

Graham

Reply to
Eeyore

Very likely increasing damage to the environment in fact !

Graham

Reply to
Eeyore

Some ppl don't have the tiniest clue do they ?

Graham

Reply to
Eeyore

Anything that *has* to contain lead is exempt of course !

Graham

Reply to
Eeyore

WTF has it got to do with *THEM* ????

What a total waste of everyone's time.

Graham

Reply to
Eeyore

Electronics Weekly is a good place to start looking (the front cover)

Reply to
Peter

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