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RoHS in EU

Q

qbic

Jan 1, 1970
0
Hello,

Question, There is RoHS directive, (and so what) Is there present any
entity in yours country that can enforce this directive to stop
production or import of electronic equipment? Is there any standard
how RoHS compliance check should be preformed?

I've found only IPC norms regarding Materials Declaration Management
but i haven t found any information how RoHS audit should be
preformed.

I know there are several companies like UL that signs RoHS
certificates, maby you have some experience - how it was done in
your's company.

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?


Thanks for any help and suggestions..

Marek Kubel
 
D

dalai lamah

Jan 1, 1970
0
Un bel giorno qbic digitò:
Question, There is RoHS directive, (and so what) Is there present any
entity in yours country that can enforce this directive to stop
production or import of electronic equipment? Is there any standard
how RoHS compliance check should be preformed?

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

http://www.federlegno.it/servizi/una/raee/dlgs151-220705.pdf

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.
 
C

coals

Jan 1, 1970
0
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.


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

:)

enjoy
coals
 
W

Wimpie

Jan 1, 1970
0
Hello,

Question, There is RoHS directive, (and so what) Is there present any
entity in yours country that can enforce this directive to stop
production or import of electronic equipment? Is there any standard
how RoHS compliance check should be preformed?

I've found only IPC norms regarding Materials Declaration Management
but i haven t found any information how RoHS audit should be
preformed.

I know there are several companies like UL that signs RoHS
certificates, maby you have some experience - how it was done in
your's company.

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?

Thanks for any help and suggestions..

Marek Kubel

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
 
J

Joerg

Jan 1, 1970
0
Wimpie said:
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.

http://www.tetech.nl/
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...)
 
Q

qbic

Jan 1, 1970
0
http://www.tetech.nl/
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...)

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
 
J

Joerg

Jan 1, 1970
0
qbic said:
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.
 
W

Wimpie

Jan 1, 1970
0
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.


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
 
J

Joerg

Jan 1, 1970
0
Wimpie said:
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.



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.
[/QUOTE]

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.

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.

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.

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

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.
 
W

Wimpie

Jan 1, 1970
0
[previous text deleted]
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

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
 
C

Christopher Ott

Jan 1, 1970
0
Wimpie said:
[previous text deleted]
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

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:

http://rswww-uk.custhelp.com

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
 
M

mpm

Jan 1, 1970
0
On Jun 3, 8:19?pm, "Christopher Ott" <spamtrap at ottelectronics dot
com> wrote:

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.
 
R

Roger Hamlett

Jan 1, 1970
0
Christopher Ott said:
Wimpie said:
[previous text deleted]
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

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:

http://rswww-uk.custhelp.com

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'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:
http://www.pb-free.info/rohsexemptions.htm

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

Best Wishes
 
Q

qbic

Jan 1, 1970
0
Christopher Ott said:
Wimpie said:
[previous text deleted]
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
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...

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:http://www.pb-free.info/rohsexemptions.htm

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

Best Wishes

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
 

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