The RoHS directive is Environmental legislation aimed at reducing the amount of hazardous materials used in electronic products - It covers Lead, mercury, cadmium, hexavalent chromium and specific flame retardants (PBB and PBDE), requiring a wide range of product types sold on the European market to be virtually free of these materials (to aid recycling and reduce nasties getting into the environment).

To any organisation manufacturing electronic or electrical equipment that is to be sold into the E.U (and other areas), the current and future status of products covered by RoHS (or RoHS-like) legislation will be of great importance. If product containing the restricted materials is released onto the market , then prosecution and a possible unlimited financial penalty may follow.

The deadline for compliance of our products is 01 July 2006, which is not very far away at all

Some links below give some additional information.

http://www.cfsd.org.uk/seeba/Europe/RoHS%20Fact%20Sheet.htm

And California's own equivalent legislation:

http://www.ciwmb.ca.gov/electronics/act2003/

There's also a 'China RoHS' but that's been put back six months......

So the question is, who's doing what, and how far down the line are you... are you finding obsolescense a problem, are smaller suppliers going to get buried?

I am getting heavily involved in this (currently working for an organisation manufacturing test and inspection equipment) and the more that I focus on the RoHS directive, the bigger a job it becomes..... :mg:

The biggest problem that we are having is getting all of our components in RoHS compliant form (some of the major component manufacturers are still working on their product lines).

We believe that we have a process that is capable (has been tested on some test boards), but are unable to validate Pb-free / RoHS compliant product reliability until we can build a completely RoHS compliant product.

We are an OEM for electronic motor controls and drives.

The company that I work for is pretty well advanced as we supply into many distribution companies. Our products have been compliant since the beginning of January. We still have some minor outstanding issues such as the use of lead as a lubricant in the manufacture of VX grade pvc, but in the main we have full compliance. We broke down every part that we sell to its constituent part numbers, verified materials used in the processing and manufacture, modified drawings, carried out tests and then used the First Off system to verify the introduction of changes. All stores stock has been segregated and we are now debating the issue of piece part and finished goods obsolescence.

One of the stupid things with the RoHS Directive is that there is no really managed introduction in that you have a fixed date for compliance rather than comply when stock is rotated (I have been informed that this was due to Swedish objections during drafting). This means that businesses need to decide what to do with product that does not conform, you will not have a buyer (unless used for maintenance/repair) and therefore the product that was one day good will be of nouse or value. In effect you will be throwing good product into the bin to satisfy a piece of legislation designed to save the planet.

Frank Trott

The company that I work for is pretty well advanced as we supply into many distribution companies. Our products have been compliant since the beginning of January. We still have some minor outstanding issues such as the use of lead as a lubricant in the manufacture of VX grade pvc, but in the main we have full compliance. We broke down every part that we sell to its constituent part numbers, verified materials used in the processing and manufacture, modified drawings, carried out tests and then used the First Off system to verify the introduction of changes. All stores stock has been segregated and we are now debating the issue of piece part and finished goods obsolescence.

One of the stupid things with the RoHS Directive is that there is no really managed introduction in that you have a fixed date for compliance rather than comply when stock is rotated (I have been informed that this was due to Swedish objections during drafting). This means that businesses need to decide what to do with product that does not conform, you will not have a buyer (unless used for maintenance/repair) and therefore the product that was one day good will be of nouse or value. In effect you will be throwing good product into the bin to satisfy a piece of legislation designed to save the planet.

Frank TrottSome one will get stuck and it will still not do any good until stock is depleted.

One thing to keep in mind is that spare parts for equipment manufactured before July 1, 2006 will not have to be compliant.

Therefore much of the current non-compliant stock can be used for spare parts or for non-RoHS markets.

That said the smart companies will phase to compliant products and not try to track a compliant and noncompliant product line.

Chris Harden

MDSMap-Tetra Tech

We are all set with RoHS compliance. It took about 8 months of babysitting 10 hours a week, but I finally converted all the bills of material to RoHS, and our contract manufacturer has converted their lines to lead-free. We're just a small business, so I can imagine the big ones are still working it.

I found a huge disparity in the way the component suppliers communicated the RoHS compliance of their products. I had to treat each one as a separate entity and make a lot of phone calls when I could not find what I wanted on websites.

--QG

Upon starting this job about 2 months ago I inhertied the RoHS compliance.
Before I started, the company got a jump on RoHS by hiring a consulting firm to work on the details. As a result we have a blanket statement that we send to customers stating that all product manufactured in this facility is RoHS compliant.

the question is... would this blanket statement fly with you?

Most of our customers accept it. Some, however, insist on more detail.
One in particular wants us to complete a fairly involved spreadsheet for the product we sell them broken down into component parts. That's a lot of work... especially if said customer only places one or two small orders a year.

We are seeing the same thing. We manufacture dome enclosures for the security industry and I have just finished completing material declaration letters for the paint, stainless steel and gold used to coat the domes.

If you had to stand up in court and demonstrate due dilligence as a defence for shipping unknowingly RoHS non-compliant products do you think that your piece of paper from your supplier would help your defence ?

There is a certain onus on you within your position in the supply chain to not take declarations of compliance at face value unless you are very sure of the source.

i.e. a declaration such as this from RS Components might be taken at face value, however such a declaration from Billy Bodgits Electronics in Taiwan might require further delving.

If you had to stand up in court and demonstrate due dilligence as a defence for shipping unknowingly RoHS non-compliant products do you think that your piece of paper from your supplier would help your defence ?

There is a certain onus on you within your position in the supply chain to not take declarations of compliance at face value unless you are very sure of the source.

i.e. a declaration such as this from RS Components might be taken at face value, however such a declaration from Billy Bodgits Electronics in Taiwan might require further delving.

I understand what you're saying, but is this not the same as accepting a boilerplate C of C from a supplier?

I can understand that if we are a new supplier that they may want more than a declaration, but what of customers one has done business with for years?

all these regs kind of undermine supplier/customer trust... but that's a whole other issue.

I have an opposite problem to most of you guys. The company I'm working with does not sell outside of the USA; therefore no requirement to comply (right?). Except that our board suppliers are having a lot of problems; as our specified leaded components are being phased out of production due to declining usage. We currently have a list of several components each month that need alternative components, either a new leaded part number or release to use the RoHS compliant replacement.

Bob Schiller

Our major problem is that we deal with a lot of small suppliers and they have no idea what RoHS is so I find myself having to walk them through the process and I am no expert on the subject.

Does anyone know of any training classes in Georgia, USA or online?