Re: ROHS - are the exemptions useful?

John Devereux wrote:

z180@xxxxxxxxxxxx (Peter) writes:


Hi All,

Like everybody here in Europe we have to face lead-free components and
solder from July 2006.

The list of exemptions (e.g. www.rohs.gov.uk) is however interesting.
Monitoring and control equipment is exempt, for example, and this
could cover a LOT of stuff.

What I wonder however is whether this will be useful. Like similar
scams (ISO9000 and CE being good examples) these tend to be run (in
big companies, anyway) by less than brilliant people who are just damn
grateful for having a job pushing bits of paper, and they will ignore
the exemptions and demand literal compliance. It's like requiring a
vendor of toilet paper to have ISO9000 - a common thing in many big
firms where some dickhead has built themselves an empire around this.

Would it be legal to issue a certificate of compliance which is false,
but in fact the product would have been exempt anyway (or a convincing
argument could be made for it to be exempt), or is a differently
worded certificate mandatory in such cases? In general, for example in
personal taxation in the UK if no tax is actually due, one cannot
prosecute for a false declaration if nothing is actually wrong.



Well I would think that you could not legally "issue a certificate of
compliance which is false". However, it might not *be* false to say
something with lead in it is "RoHS compliant" if it is the RoHS
legislation *itself* that specifies the exceptions.


I am already seeing the expected alarmist news articles, coming out of
the usual axe grinders, saying that a certificate of compliance will
not be sufficient and that a purchaser needs to do a bit more
(suprise, suprise, this is then explained as paying a specialist x-ray
lab to physically verify) that the stuff one is buying is really
lead-free.

It's the CE (EMC compliance) axe grinding circus all over again. 


If it is anything like that, then we can expect the deadline to be
delayed by several years... But in fact I think this will be
different.

- the device manufacturers and distributors seem to be pushing it. I
  don't think they want to make/stock both lead and lead-free
  versions of product.

- Assemblers won't like to mix the processing because of the potential
  for cross-contamination. They will want to just go one way or the
  other.

And then there is the fact that a given "RoHS" part may have totally different and non-compatible dimensions compared to the "old" part...
Just gloss over the additional possibility that other parameters may also cause havoc...
BTW, put head in sand concerning the three different ways that tin can grow (shorting) shiskers...
.

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