RoHS (Reduction of Hazardous Substances) Ensuring banned substances, no matter the quantity, do not make their way into your products. Even if you purchase commodity goods.

Because RoHS extends throughout the entire supply chain, it could very well affect non-European businesses. Both are starting to be pushed in the US, and may actually be in place in the near future (within 5 years).

RoHS (Reduction of Hazardous Substances) Ensuring banned substances, no matter the quantity, do not make their way into your products. Even if you purchase commodity goods.

Because RoHS extends throughout the entire supply chain, it could very well affect non-European businesses. Both are starting to be pushed in the US, and may actually be in place in the near future (within 5 years).


I won't say from who, but we have already filled out some surveys for U.S. companies.

RoHS (Reduction of Hazardous Substances) Ensuring banned substances, no matter the quantity, do not make their way into your products. Even if you purchase commodity goods.

Because RoHS extends throughout the entire supply chain, it could very well affect non-European businesses. Both are starting to be pushed in the US, and may actually be in place in the near future (within 5 years).


Some of the US and Japanese OE customers have been requesting (mandating) my clients to reduce or eliminate Hazardous Substances, though I don't know if it was linked to RoHS directly.

RoHS (Reduction of Hazardous Substances) Ensuring banned substances, no matter the quantity, do not make their way into your products. Even if you purchase commodity goods.

Because RoHS extends throughout the entire supply chain, it could very well affect non-European businesses. Both are starting to be pushed in the US, and may actually be in place in the near future (within 5 years).

Please don't mistake me for pointing this out; the expansion of RoHS is "the restriction of the use of certain hazardous substances in electrical and electronic equipment"; there is a subtle difference between "Reduction" and "Restriction". That needs to be appreciated while interpreting RoHS directives. I agree that in the day-to-day working people use the phrase "Restriction of Hazardous Substances". Please also note that this restriction is for electronics and electrical equipment that need less than 1000 V (AC) or 1500 V (DC) for their normal functioning not for ALL commodity goods.

Best wishes,

Ramakrishnan

Hi all,

I'm new here. I would like to know where can I get myself the RoHS standards? Do I need to make a purchase for this?

Thanks for your time.

BR,
LyregI

Hi all,

I'm new here. I would like to know where can I get myself the RoHS standards? Do I need to make a purchase for this?

Thanks for your time.

BR,
LyregI

What you should do is to do a search by typing 'rohs'. We have several pages of items/threads discussed previously. Anyway these are some of the links:
RoHS Enforcement Guidance Document - Released May 2006 (http://elsmar.com/Forums/showthread.php?t=16824)
Is RoHS just for the electronics industry? (http://elsmar.com/Forums/showthread.php?t=13242)

RoHS standards are not copyrighted. Look at the attachments in the links. You can download it from many sources in the web.

I work in metal finishing, and we just love :notme: RoHS. Chromium 6, which is a reportable substance, had to be changed to a Trivalent. As we changed over to the Tri chromates we are finding that in the lab of the suppliers the corrsion resistance is very high, better tha hex (chromium 6) but in production runs the results are half of the stated results. How fun, automotive is going off of tests from the labs when in production we can not achieve the same results. I thought it was just us but the supplier say we are not the only one. Here I go again ... but change has a good and bad side to it. Love or hate it RoHS is here to stay.

Glen

I work in metal finishing, and we just love :notme: RoHS. Chromium 6, which is a reportable substance, had to be changed to a Trivalent. As we changed over to the Tri chromates we are finding that in the lab of the suppliers the corrsion resistance is very high, better tha hex (chromium 6) but in production runs the results are half of the stated results. How fun, automotive is going off of tests from the labs when in production we can not achieve the same results. I thought it was just us but the supplier say we are not the only one. Here I go again ... but change has a good and bad side to it. Love or hate it RoHS is here to stay.

Glen

Amen! Typically have to add "sealers" (practically equivalent to clear paint) to pass corrosion tests, or the plating bath chemistries have to be watched like a hawk (how long after the corrosion test do you suppose that will happen?) Also, you would be surprised how many components wander into the items specified on the RoHS restriction list - and therefore need certified.

Wonder when the first US company will be prosecuted by the EU for failing RoHS. That will be an interesting legal knot.

Wonder when the first US company will be prosecuted by the EU for failing RoHS. That will be an interesting legal knot.

I know this is getting off topic but PLEASE DON'T IT BE US!!!

Wonder when the first US company will be prosecuted by the EU for failing RoHS. That will be an interesting legal knot.

http://www.rohs.gov.uk/content.aspx?id=7

This link gives an indication of the legal processes in the UK for enforcement of RoHS. In fact the whole site is worth reviewing if it's an important subject for you.

I haven't come across any organization being prosecuted yet. Has anyone else heard of a case?

RoHS has one bizarre twist to it - the manufacturer is responsible for eliminating the problem. In the US - and especially TS16949 certified companies - there is this notion of "design responsible". Therefore, if the customer print states Cr+6, you cannot simply remove it and replace with trivalent. It is their decision - contractually. The customer is 'responsible', but you are 'responsible'. Oh, great. There is a recipe for disaster - especially for some reason the customer is not aware of their need for compliance. :bonk:

I worked for a company that had customers ask what our 'plan' was to remove Cr+6. We told them our plan was to wait for them to redo the print and specs, and get our requote from the contract review prior to a new purchase order. Ouch!

RoHS has one bizarre twist to it - the manufacturer is responsible for eliminating the problem. In the US - and especially TS16949 certified companies - there is this notion of "design responsible". Therefore, if the customer print states Cr+6, you cannot simply remove it and replace with trivalent. It is their decision - contractually. The customer is 'responsible', but you are 'responsible'. Oh, great. There is a recipe for disaster - especially for some reason the customer is not aware of their need for compliance. :bonk:

I worked for a company that had customers ask what our 'plan' was to remove Cr+6. We told them our plan was to wait for them to redo the print and specs, and get our requote from the contract review prior to a new purchase order. Ouch!

AMEN I Know the feeling.

I worked for a company that had customers ask what our 'plan' was to remove Cr+6. We told them our plan was to wait for them to redo the print and specs, and get our requote from the contract review prior to a new purchase order. Ouch!


I am curious to learn the customers response?

Depending on the customer, they either sent us a new print with a new callout and an updated purchase order, or at least updated their purchase order with a note to supersede the print with exceptions. Then - with a PO change, we could start negotiation on cost change, Cr+3 performance changes, etc. (I love the contract review requirement.) Honestly, once they were reminded that it was their responsibility to tell us to change to Cr+3 - because we shipped to their specification, not ours - they accepted that and completed the process. It is a good idea to find an acceptable plater (price and quality) that provides Cr+3 ahead of time, though, to offer up some suggestions in the negotiation process. Other things to consider during negotiation - who is going to pay for the qualification process (samples, corrosion testing, repetitions to get it right, etc.)?

I work in metal finishing, and we just love :notme: RoHS. Chromium 6, which is a reportable substance, had to be changed to a Trivalent. As we changed over to the Tri chromates we are finding that in the lab of the suppliers the corrsion resistance is very high, better tha hex (chromium 6) but in production runs the results are half of the stated results. How fun, automotive is going off of tests from the labs when in production we can not achieve the same results. I thought it was just us but the supplier say we are not the only one. Here I go again ... but change has a good and bad side to it. Love or hate it RoHS is here to stay.

Glen

I am not a metal finishing expert, but in audits of companies who buy plating services, this topic has come up often.

I am a bit puzzled by the comments. Three or four years ago, I know platers had quite a struggle getting Tri-chrome to work well, and customers were reluctant to approve it.

However, these same clients report now that their Tri-chrome issues have been resolved and fully validated, and many customers have fully switched to Tri-chrome. One in particular, I watched as audit after audit they were 40% out of Hex-chrome, 60%, 80%, etc. Their Japanese customers were pressing them, and the Big 3 slowly followed.

Are you saying that the whole plating industry still is not getting good results, or just certain platers?

Are you saying that the whole plating industry still is not getting good results, or just certain platers?

From my experience, there are some companies that are doing very well and others that are struggling. Plating companies always vary in quality depending on how well they monitor their baths, and how well they clean parts prior to the plating baths, etc. They sloppier they are, or the more shortcuts they take to get out production, the poorer the results - with any plating system. Also, you get what you pay for.

That said, to get acceptable results with Cr+3, it takes meticulous bath monitoring and product handling. Also, there are some chemistries that perform better than others, but there is a cost penalty there, too. They may be meeting the Cr+6 requirements, but usually it took something different, such as a sealer or more expensive chemistry. That may be how the "issues have been resolved and fully validated." This is what the platers and chemical suppliers I was dealing with were telling me only a couple years ago, and that certainly is not everyone in the industry.

I was pushing to move everything possible to Cr+3 to get benefit of volume, but with thousands of part numbers and hundreds of customers you have to make sure the performance did not adversely affect any customer. There was the rub.

From my experience, there are some companies that are doing very well and others that are struggling. Plating companies always vary in quality depending on how well they monitor their baths, and how well they clean parts prior to the plating baths, etc. They sloppier they are, or the more shortcuts they take to get out production, the poorer the results - with any plating system. Also, you get what you pay for.

That said, to get acceptable results with Cr+3, it takes meticulous bath monitoring and product handling. Also, there are some chemistries that perform better than others, but there is a cost penalty there, too. They may be meeting the Cr+6 requirements, but usually it took something different, such as a sealer or more expensive chemistry. That may be how the "issues have been resolved and fully validated." This is what the platers and chemical suppliers I was dealing with were telling me only a couple years ago, and that certainly is not everyone in the industry.

I was pushing to move everything possible to Cr+3 to get benefit of volume, but with thousands of part numbers and hundreds of customers you have to make sure the performance did not adversely affect any customer. There was the rub.


The ones who reported success did mention that it was more expensive. Perhaps that links to the "more expensive chemistry."

The ones who reported success did mention that it was more expensive. Perhaps that links to the "more expensive chemistry."

I think so - but some of the customers are not picking up on that point. Price increase? C'mon...:cool:

I work for a contract manufacture company who build systems for power suppliers, medical, and sound systems. In regards to RoHS and metal parts used for housings or front panels of electrical components and systems, our customer that have supplied the drawings and source to get the parts. However, we end up being responsible to verify the materials are acceptable per RoHS requirements. We ended up purchasing a XRF unit to validate the certifications we would get to be on the safe side.
The RoHS changes for the PBB & PBDE in circuit boards have caused us a lot money and time to correct hidden issue causing failures in test and cosmetics, not to mention the companies that do not what RoHS but all the parts are changing and you now have to pay more if you want Lead (Pb) parts. It a bit of a pain but to ship units even in California you need to fit into these guidelines.

Once they have told you that they want the RoHS compliant parts - and you have agreed to supply it, you are obligated to ensure they meet the requirements. We have used supplier certifications that either state lead free, Cr+6 free or whatever other evil chemical free, or (better yet) RoHS compliant. If I were the supplier, I would cite Cr+6 free (for example) rather than RoHS compliant, because I believe will hold more of a legal weight stating RoHS compliant. Many of the certifications I have seen from customers want the highest corportate officer to sign the certification. But, you can't always get what you want - especially with family owned companies. If, as a quality professional, you are requested to sign the certification, DON'T. You may be held legally liable for the results. If you don't have a good umbrella insurance policy, you could be hit hard. No, I am not a lawyer - but I can sure figure out the inference. Remember, RoHS IS NOT A STANDARD - IT IS A LAW.

Are you saying that the whole plating industry still is not getting good results, or just certain platers?

The issue that is being learned is that tri chromates do not self heal like the old hex chromates did. Processing in a barrel process causes scratches in the chromate from the tumbleing process. When using silica sealers this helps tri chromates with the scratch issue. The only problem is that when the chemical company's sold the chromates they never stated that the sealers might be need until process was in production mode. Now comes the same problem as the switch from hex to tri, you need to have the change accepted by the end user.

You are absolutely correct - that is what I heard about Cr+3, also. I just didn't want to get that deep into it. Some folks will carefully plate the part, such as rack plate - then gingerly handle the part as it goes to the lab for corrosion testing to avoid scratches. It will pass the test, but that is not how the parts are really handled. I suspect many parts would fail if they they were taken out of a shipped sample and tested.

A US company cannot be prosecuted by an EU country for non RoHS compliant goods. The EU country would prosecute the importer of the goods into that particular EU country.

Dont quite know how that works with distance selling, however i believe they would firstly go after some local embodyment of that US company, then i guess if the end user is the buyer by distance selling (lets say e-bay) then I guess they become the importer, hence liable for RoHS compliance ??!!

Hi Marc,
Just some questions please about this ROHS thing if you won't mind; we are a service company, a freight forwarder at that. We have a client that store their "electronic parts" in our warehouse. We recently been given an "OFI or observation" by the certifying body and said that we consider the ROHS standard or requirement in storing our client's goods. May I ask as to how are we going to "consider" the said requirement in our freight forwarding and warehousing business? What's the connection of its requirement/standard to ISO 9001:2000?

Thanks so much,
Grace

Hi Marc,
Just some questions please about this ROHS thing if you won't mind; we are a service company, a freight forwarder at that. We have a client that store their "electronic parts" in our warehouse. We recently been given an "OFI or observation" by the certifying body and said that we consider the ROHS standard or requirement in storing our client's goods. May I ask as to how are we going to "consider" the said requirement in our freight forwarding and warehousing business? What's the connection of its requirement/standard to ISO 9001:2000?

Thanks so much,
Grace

Grace
I think your auditor has gone mad. The legislation applies to manufacturers, retailers and importers to the EU. Not to freight transport companies.
Ask the auditor to justify his comments in terms of ISO 9001 and share his response with us. I could do with a laugh.

Grace
I think your auditor has gone mad. The legislation applies to manufacturers, retailers and importers to the EU. Not to freight transport companies.


Agreed with tyker. Typical example of 'too little knowledge is dangerous'.

However, sometimes, observations are made in 'good faith'. Especially in situations where the auditor felt that the client does not know much of what they are doing - in this case, how RoHS is affecting them and perhaps the auditor himself is not sure of the subject also (nothing wrong to highlight something which may affect the client subsequently).

My understanding of OFI is that it is something to investigate further - whether it will affect the company/product or not is a question mark at the time of the audit. In this case, if upon investigation you find that RoHS does not involve you, so be it. Just let him know during the next audit.

And before we bash him further, it will be good if the OP can let us know exactly how the OFI is worded.

Agreed with tyker. Typical example of 'too little knowledge is dangerous'.

However, sometimes, observations are made in 'good faith'. Especially in situations where the auditor felt that the client does not know much of what they are doing - in this case, how RoHS is affecting them and perhaps the auditor himself is not sure of the subject also (nothing wrong to highlight something which may affect the client subsequently).

My understanding of OFI is that it is something to investigate further - whether it will affect the company/product or not is a question mark at the time of the audit. In this case, if upon investigation you find that RoHS does not involve you, so be it. Just let him know during the next audit.

And before we bash him further, it will be good if the OP can let us know exactly how the OFI is worded.


Harry
You display a fairness of mind which does you credit.
I maintain an intolerance to ignorant auditors which causes occasional vexation but tends to keep the audit report short.
I have always believed that an auditor who doesn't know what he's talking about shouldn't be talking. If he does make that mistake, he shouldn't compound the error by putting it in writing.
One day, I may even apply these rules to myself.

Unless you are repackaging or adding items to the produce it is not your problem. The only issue may be if you are packing the product the marking or WEEE requirements. But I agree with the other is should not be you issue and the observation is OK as just an information thing but not an action you need to worry about.:2cents:

I maintain an intolerance to ignorant auditors which causes occasional vexation but tends to keep the audit report short.
Now then, Tyker. You don't mean you put pressure on the auditor do you. ;)
I have always believed that an auditor who doesn't know what he's talking about shouldn't be talking. If he does make that mistake, he shouldn't compound the error by putting it in writing. Amen to that. If only some people could see themselves as others see them.

I refuse to name names ... unless it's over a beer.
One day, I may even apply these rules to myself. What? :mg:

One of my big complaints with RoHS is that several of our customers require a Certificate to RoHS compliance even though the parts we manufacture for them are not electrical componenets and have nothing to do with the manufacture of such components. One example is springs for analog scales.

Doug

One of my big complaints with RoHS is that several of our customers require a Certificate to RoHS compliance even though the parts we manufacture for them are not electrical componenets and have nothing to do with the manufacture of such components. One example is springs for analog scales.

Doug

You're right, there's a lot of badly informed customers out there. Our components are not electrical although many do end up in electrical machinery. Supplying via stockists, as we frequently do, means we have no idea where the component is going to finish up so everything has to be RoHSted.

Still, it's easier than getting a beer out of Paul Simpson.:notme:

As uneducated as people are to RoHS, it pales in comparison to the lack of knowledge about the requirements of Specialty Metals as defined in DFARS 252.225-7014. It is astonishing what I have been asked to provide DFARS compliance on. :confused:

Still, it's easier than getting a beer out of Paul Simpson.:notme:
I thought I bought last time! Just spent a couple of hours with a couple of ex colleagues of yours - over a beer!:agree1:

And I paid! :(

Grace
I think your auditor has gone mad. The legislation applies to manufacturers, retailers and importers to the EU. Not to freight transport companies.
Ask the auditor to justify his comments in terms of ISO 9001 and share his response with us. I could do with a laugh.

Hi Tyker
Fist of, thanks for being the 1st one to reply to my post... I never expected such reaction... or we're just too ignorant about RoHS that we didn't know how to counter the auditor's "observation" :bonk: ... guess that's the reason why the auditor had written such observation in the 1st place :biglaugh: Well, atleast he had something to write on the report :rolleyes: Seriously, thanks for the inputs ...

Agreed with tyker. Typical example of 'too little knowledge is dangerous'.

However, sometimes, observations are made in 'good faith'. Especially in situations where the auditor felt that the client does not know much of what they are doing - in this case, how RoHS is affecting them and perhaps the auditor himself is not sure of the subject also (nothing wrong to highlight something which may affect the client subsequently).

My understanding of OFI is that it is something to investigate further - whether it will affect the company/product or not is a question mark at the time of the audit. In this case, if upon investigation you find that RoHS does not involve you, so be it. Just let him know during the next audit.

Yup, Harry.. 'too little knowledge is indeed dangerous' ... perhaps I should really be visiting the forum ever so often so that I wouldn't be missing out on some "new" and "in" thing nowadays.. :read: I'll consider your advice.. thanks! :applause:

Grace, I found out that some 'RoHS' customers (depends on the product) do require their goods to be stored in a seggregated area in the ware house. If such needs do arise, they should be communicated to you in the form of 'customer requirements' or as a requirement in the contract of service. But if nothing is mentioned, then it does not apply.

I think it's good to know that there are such requirements - especially for your contract review purpose.

I maintain an intolerance to ignorant auditors which causes occasional vexation but tends to keep the audit report short.
I have always believed that an auditor who doesn't know what he's talking about shouldn't be talking. If he does make that mistake, he shouldn't compound the error by putting it in writing.

Me too! But I do have on many occasions come across good auditors who try to prod business owners to be more alert on what is happening around the business environment. One major difference between small businesses here and the developed countries is that business owners here tend to be more ignorant and many laws such as safety is not well enforced. As a result, sometimes auditors need to open their mouth when they see fundamental breaches or bad practices. Most will communicate it verbally especially at the closing meeting and not have them recorded in black & white.

Who can change the thread title to "Restriction of Hazardous Substances" as it should be .....

Grace, I found out that some 'RoHS' customers (depends on the product) do require their goods to be stored in a seggregated area in the ware house. If such needs do arise, they should be communicated to you in the form of 'customer requirements' or as a requirement in the contract of service. But if nothing is mentioned, then it does not apply.

I think it's good to know that there are such requirements - especially for your contract review purpose.

Yes, Harry.. I'll first check with Sales if such requirement is stipulated in the contract; otherwise we can just say so in the next audit ... I agree with you that perhaps the auditor was just raising our awareness when it comes to RoHS. Thanks again! :bigwave:

It would benefit everyone whom is asked to comply with the RoHS directive to also understand the WEEE directive. Both directives can be found on the UK Government's links page (http://www.rohs.gov.uk/content.aspx?id=9). The products/commodities that should be RoHS compliant are listed in the WEEE directive.

I won't bias anyone with my interpretation but I will say that we have successfully educated several customers until they dropped their RoHS compliance requirement. They did not understand that this legislation did not apply to their end product nor does it apply to the products that we produce.

Who can change the thread title to "Restriction of Hazardous Substances" as it should be .....

I Googled both versions - they come up about even in hits, but the official EU document uses 'Restriction', so I changed the thread title.

I sat through two very good webinars this month -one on RoHS and the other on WEES. Things I learned from the webinars include:

RoHS/ WEES-like regulations are being implemented not only in the EU, but also throughout the world market ---Canada, Japan, Korea, China, etc. And each country is doing it differently.
RoHS will be an impact on the way we (USA) design products. Some products are exempted from the EU RoHS now, but are expected to be regulated in the future. Other countries may have different exemptions (looks like doesn't intend to exempt anything)
For the WEES requirements, it looks like manufacturers are going to have to find waste disposal sites that meet the verious requirements of each country (including the various EU countries)
And don't forget California's SB 20, the Electronic Waste Recycling Act of 2003 or SB50 Electronic Waste Recycling Act .....

I have been researching/following WEEE & RoHS for a few years now. I have developed three WEEE & RoHS compliant systems within the EU.

If you have any questions i would be happy to assist. :)

RoHS Compliance Problem

I am working (ISO compliance) with a small value-added assembly company. The company is a parts distributor and does value-added assemblies for medical device manufactures.

Problem:
The customers (medical device manufactures) are requiring that the RoHS status of the parts and assemblies be assured.

Information:
The parts and components for assemblies are specified by manufactures part number by the customer.

The company cannot change any part numbers without revised customer specifications, i.e., drawings.

The RoHS compliance of a part can only be assessed and assured by the manufacture of the part. (My assumption.)

The company can only determine and assure that the specified parts and assembly components are supplied.

Preliminary inquires show that part manufactures DO NOT, in general, include RoHS compliance as a specification for the parts. Some will provide certificates, some will email statements, etc. (Electronics part manufactures will state 'Lead free".)

Control by part number does not assure the parts are green. For example, a survey on the Arrow web site indicates that 36 out of 108 manufactures did not control by part number change. Some controlled by date code, some by prefix/suffix, and some with no change to part identification at all. Thus the part RoHS compliance cannot, in all cases, be tracked through the MRP and factory floor.

Full compliance with this customer requirement would require system wide changes; e.g, testing facilities, MRP system changes, materials handling, etc.

Comments, discussions, etc.?

Added note: Medical devices are currently exempt and are expected to remain so until 2012 although 2016 has been recommended.

Statwonk

Yes, what Arrow stated is correct, they way we handed it was all parts where separated in inventory, ROHS and Non-ROHS.
It was hard work and that includes and investment of floor space and equipment to separated production and inventory. Added test equipment to verify production had soldering stations where not cross contaminated, to validate received materials where per the manufactures C of C. We even located a local testing lab for items that required a third part review to break any dead lock between our supplier and our findings.

Yes it is a lot to set up but after all the training and segregation is in place it fall right into out standard process of inspection and verification processes.

The audits we had by customers and our ISO registration auditor all indicated that we are meeting the requirements for ROSH material.