Hi all I think the RoHS issue has been flogged as much as it can be.
I also think Elecrafts position is being confused a bit (as I understand it anyway). As far as I can see there is no claim that the kits are RoHS compliant. This blossomed from the price increase thread where I believe Elecraft mentioned they were buying RoHS compliant parts which are costing more but they had to do it as they were mainstream available and leaded parts were becoming harder to find. There is no coc, no documentation and no audit trail claiming RoHS compliance, so regardless of the dialogue here, due diligence has not been observed at any level therfor the importer will be liable for non conformance (the EU importer, NOT Elecraft) if applicable. Not sure what Elecraft will do for PCB finish but I would guess rather than switch to ENIG or similar the plating will still be Sn/Pb HASL as the preferred solder alloy is still going to contain lead. So forget the parts. The SSB adapter board I have here with DC 23/06 says RoHS on it but the plating looks like HASL SnPb to me (not compliant) and if it is just a pure tin finish (Pb Free) then it makes no sense for Elecraft to say Pb Free solders void warranty as SAC305 alloys in Kester or Multicore will flow just as easy when fluxed. For rework some drill hole apertures will need to be enlarged and if the PCB material is sub standard you risk lifting some lands due to the slightly higher temperatures involved when applying the iron or desoldering tool. As long as a single component inside the box is not compliant (remember that also includes any plastics and plated metals) then forget about it. Assemble with SnPb solder, forget about it. All roads to non compliance. The only issue not fully investigated is if the kits actually have to conform, as a finished product placed on the EU market commercially, yes they do, regardless of country of origin. EU manufacturers are responsible for the audit trail and compliance measures (usually wrapped up inside a formal QC system) but anyone importing parts or products into the EU (parts) to be placed on the market not only take responsibility for their own actions, but those of the external EU manufacturer also. Regulations vary country to country, they are not uniform across the EU as their enforcement methods are different, but the term due diligence is used quite a bit and to demonstrate its execution is not so easy, is the part compliant?, yes, how do you know?, the suppliers says so, can the supplier be trusted? Does the supplier have lot traceability back to the factory? How was the materials tested? Which method was used...are there certified lab results.. You would hate to see the flowchart / decision tree out of our QC system at work.... We also had to drop any suppliers unable to meet the audit trail requirements as well as scrap / remove from site all non compliant inventory as contamination of complaint stock was also a risk. That's risk assessment at its best. It is really a big can of worms to open. It kind of takes the fun out of the whole building deal I can tell you! A few hours of working the front panel of the K2 and using the mic helps put the fun back in it for a while :-) John _______________________________________________ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
