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ROHS enforcement getting more forceful

August 12, 2008

Recently, there have been signs of increased ROHS enforcement activity across the European Union.

In particular, and maybe not surprising, the Scandinavian ROHS authorities have been busy. Their investigations included visits to manufacturers, importers, and retailers across Denmark, Sweden, and Finland and resulted in 22 cases of non-compliance, one of which led to a prosecution.

Three cases of non-compliance were in Sweden from 60 products analyzed, six in Denmark from 29, and 13 in Finland from 63 investigated. The main causes for non-compliance included lead in plastic and lead in solder.

The prosecution involved a Swedish importer bringing in non-branded glue guns from China that contained lead in the plug casing above permitted concentration values. Authorities focused on short lifecycle products and small household appliances, as well as acting on “tips” via their hotline.

ROHS enforcement is more visible in the second year with the UK enforcement authorities issuing two formal cautions, where cases were brought to justice, 12 compliance notices and more than 40 improvement plans for companies. There are also examples of activity in other EU Member States including Denmark, Belgium, Holland, and Finland. Both the Scandinavian and UK authorities cited weak, incomplete documentation as a problem.

Post your comments on ROHS enforcement below.


About the author
As director of legislation and environmental affairs, Gary Nevison is Newark’s and Farnell’s spokesperson and customer interface on legislation that affects the electronics industry, such as the ROHS (all variations around the world, including China ROHS), REACH, EuP, and WEEE directives. For more on Gary, click here.

Posted by Gary Nevison on August 12, 2008 | Comments (8)

August 29, 2008
In response to: ROHS enforcement getting more forceful
Kiran M R commented:

Ron, The DDR memory devices are predominantly RoHS 6/6 compliant..how is this getting addressed? Is the telecom industry using a mixed SMT process to handle these exceptions? -Kiran


August 29, 2008
In response to: ROHS enforcement getting more forceful
Ron T commented:

It's interesting that the telecom industry is specifically instructing suppliers to continue with lead solder. In the last update from AT&T "Equipment submitted for approval for use within any AT&T networks shall not be RoHS 6/6 compliant. Specifically, tin lead solder shall be used for circuit board assembly per Telcordia Notice to the Industry, November 2006, Reliability Concerns with the Use of Lead (Pb) Free Solder in Telecommunications Products."


August 28, 2008
In response to: ROHS enforcement getting more forceful
Kiran M R commented:

Gary, For the telecom industry, still lead exemptions in Solder are applicable..what is the roadmap for this? The next review will be in 2010 and most telecom companies use this lead exemption in solders. Kiran M.R. Component Engineering Manager Bangalore, India


August 15, 2008
In response to: ROHS enforcement getting more forceful
Tom W commented:

thank you for this information, Gary. It's hard to find elsewhere.


August 14, 2008
In response to: ROHS enforcement getting more forceful
Gary Nevison commented:

In response to QA aerospace The issues of manufacturability and reliability with lead-free solders are complex, particularly with RF circuits. This isn't to say though that production using lead-free solders is not possible. Some commercial RF telecommunications equipment is made with lead-free solders because it is in scope of RoHS and there has not been any outcry from these manufacturers that they cannot use lead-free or that it is unreliable although these products have been in use for only a relatively short period of time. Military applications are somewhat different, reliability is very important and at present, there is still some uncertainty over long term field reliability. Lead-free solders are too new for 15 years of field data unlike tin/lead. One of the main concerns with lead-free solders is the susceptibility to high G-forces, particularly what happens if the equipment is dropped or subjected to intense vibration. Research shows that under extreme vibration conditions, lead-free is inferior to tin/lead and so either cannot be used or additional measures are needed to avoid damage. Most RF telecom products do not see high G-forces but military equipment may do.


August 13, 2008
In response to: ROHS enforcement getting more forceful
Gary Nevison commented:

In response to the first point I am afraid that your source / "grandfather" clause is not correct.RoHS does not relate to design, or model number etc. All equipment, within the 8 product categories, put on the market on, or after, July 1st 2006 fall within the scope of RoHS. Equipment put on the market before that date can however, be upgraded or repaired using non compliant components.


August 12, 2008
In response to: ROHS enforcement getting more forceful
QA aerospace commented:

As a supplier of synthesizers, converters, and receivers for both Defense and Commercial markets in the RF industry up to 26 GHz, it's not practical for us to support ROHS. ROHS processes for RF performance is a big question mark - especially in terms of reliability and Ruggedized performance from COTS products. (There's a reason why our defense customers specify non-ROHS). Even a simple power supply built from ROHS process is not as durable as Tin/Lead solder. Since high end electronics are controlled, why should they be subject to ROHS requirements? It's the consumer throw-away items that need the regulation.


August 12, 2008
In response to: ROHS enforcement getting more forceful
ROHS Enforcement commented:

Can you advise on "grandfather" clause. We were told that if the design hasn't changed, you are allowed to continue with the product until a new design or new version of the product is made.

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