You are unlikely to get anyone to commit to a definitive answer on any RoHS issue. The grey areas will be sorted out eventually by legal precedent as the “unfortunates” get taken to court and either win or lose their case. Thus no one will give a definitive answer for fear of legal action should their advice be wrong.
The best way forward is through forming your own reasoned and documented justification if you believe your products to be exempt. The book will only be thrown at those that sit back and do nothing. i.e. if you can prove due diligence in relation to your responsibilities then I doubt very much that enforcing agencies will come down hard on anyone. There are plenty of resources for free advice and the UK DTi will give you advice and current thoughts on the interpretation of the aspects. I would actually be wary of anyone who claims they do have exact answers on grey area issues. If you justifiably believe you do not need to comply, but will be pushed into using compliant parts you will run into process issues in any case. If you can continue to build a hybrid product partly converted then you are fortunate. Many of the “trip ups” will be on the non electronic parts - currently compliant nut & bolt type hardware seems to be in short supply and even basic hook-up wire does not seem to be widely available. Regards, Chris ____________ _____ From: [email protected] mailto:[email protected]] On Behalf Of Chris Maxwell Sent: 21 April 2005 16:39 To: POWELL, DOUG; [email protected] Subject: RE: RoHS and WEEE Many of the replies are similar to Doug’s (below) in that most people say that they are going for RoHS compliance even if they are excluded. It’s a good idea and one that we would follow (if I had my way) even if our equipment were determined to be excluded. However…it still is very important to determine if your products are excluded under the following scenario… Let’s say that we at Nettest go for RoHS compliance regardless of whether we are excluded from the directive or not. Let’s say that we get to the drop dead date (date of implementation of the directive) and we still have some components that we can’t get RoHS compliant parts for… If our equipment were excluded; then we could still ship and work on cleaning up these components. If our equipment weren’t excluded; then we would have to go on stop shipment for the products containing non-RoHS parts. That’s a big difference…ultimately the difference between eating and not eating, …if you know what I mean. The answers that I am getting are just as confused and varied as I am (although I still appreciate them greatly). This just goes to show the level of confusion out there. Where is the ultimate authority that can answer questions about the directive? There are “consultants” popping up all over the place; but I don’t see why companies should pay “consultants” for RoHS “opinions” (as opposed to EMC consultants who usually have some physical knowledge, or have equipment to measure specific physical properties…”opinions” are usually just a part of what they provide.). We at Nettest can come up with our own “opinions” about RoHS and word them just as elegantly as any consultant. This is strictly an applicability issue that needs to be addressed by an ultimate authority. The questions that I and others are asking have to do with the intentions of the writers of the Directive…there needs to be some kind of way that manufacturers can pose their questions to the writers…or to the technical committee that sponsored them…even if there was a fee involved. At the very least, there should have been a guidelines document, whereby the authors of the directive gave reasoning for the exemptions that they allowed. This would allow us to make decisions based upon similar context. Does anybody know of such an avenue where a company can get direct information regarding the applicability of RoHS to their products? (i.e. can the IEEE technical committee be contacted?) We’re down to considering calling the “heavy hitters” at 1-800-LAW-1010…maybe they can answer our RoHS questions and get me some money for the carpal tunnel syndrome I’m suffering from due to all of this typing :-) Chris Maxwell Nettest _____ From: POWELL, DOUG [mailto:[email protected]] Sent: Thursday, April 21, 2005 11:04 AM To: Chris Maxwell; [email protected] Subject: RE: RoHS and WEEE Chris, For reasons other than yours, my company is excluded from the scope of the directive; however we have decided to go through the steps to compliance. This was a well though out decision and we have decided to go ahead. We have a few compelling reasons: 1) Our OEM customers are requesting compliance. 2) It won’t be long before component parts will become unavailable. 3) It is viewed as a marketing advantage. Maybe I’m dating myself but I began work in the elctronics world in the early 70’s near the time when transitors were replacing vacuum tubes. Item #2 is reminiscent of that time. Doug Powell Staff Engineer Corporate Compliance Dept. Advanced Energy Industries Inc. _____ ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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If you are not the intended recipient, disclosing, copying, distributing, or taking any action based on this message is strictly prohibited. ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
