ROHS: using up non-ROHS component stocks

[Peter]

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?

http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00190023.pdf

|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.

 

[John Woodgate]

The press is probably "owned" by electronic component distributors and
it is in their interest to make everybody chuck out their old stocks.

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

 

[nospam]

|(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.

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 **** 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.

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?

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

The funny side of all this is

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).

--

 

[Peter]

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

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

 

[Rene Tschaggelar]

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?

http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00190023.pdf

|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?

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

 

[[email protected]]

The funny side of all this is

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).

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

 

[Al Clark]

[email protected] (Peter) wrote in

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?

http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00
190023.pdf

|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.

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.

Am I missing something obvious?

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

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.

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.

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.

 

[Peter]

Why would it put smaller companies out of business ?
Is it that hard to design and manufacture leadfree ?

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.

Not really. It rather creates new opportunities.
We want to build new things.

Christ, Amen.

 

[John Woodgate]

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

.... 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.

 

[John Woodgate]

Why would it put smaller companies out of business ?
Is it that hard to design and manufacture leadfree ?

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

 

[Mark]

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.

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

 

[Peter]

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 **** 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 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.

 

[Keith]

... 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.

What about the windows?

 

[Eeyore]

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?

http://europa.eu.int/eur-lex/pri/en/oj/dat/2003/l_037/l_03720030213en00190023.pdf

|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.

Where ?

The press is probably "owned"
by electronic component distributors and it is in their interest to
make everybody chuck out their old stocks.

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

 

[Eeyore]

Why would it put smaller companies out of business ?

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

Is it that hard to design and manufacture leadfree ?
Not really. It rather creates new opportunities.

It creates new opportunites for jobsworths and nothing useful whatever.

We want to build new things.

Is that all ?

Graham

 

[Eeyore]

[email protected] (Peter) wrote in


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.

Very likely increasing damage to the environment in fact !

Graham

 

[Eeyore]

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.

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

Graham

 

[Eeyore]

Really,

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

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

Graham

 

[Eeyore]

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.

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

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.

What a total waste of everyone's time.

Graham

 

[Peter]

Where ?

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