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?
|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.