Scott:

If the tests of the packaging were done to the RoHS Directive limits but the 
results fell under the Packaging Directive limits -AND- the testing done was 
analytically validated, the results would hold for the Packaging Directive 
just as well.  However, I need to qualify that statement with a big caveat - 
to this day, there are no standard methods other than BS EN 1122:2001 for 
cadmium in plastic, which allowed the Dutch to nail Sony for the now 
infamous violation of Netherlands law.  Some testing for lead, cadmium, 
mercury and elemental chromium may produce reasonably accurate results, but 
the tests need to be validated using reference materials, and the 
uncertainties of the tests need to be calculated from measurements of known 
reference materials and known measurement uncertainties of the equipment 
used during the tests.  Unfortunately, most testing to date has not taken 
into account the difference between mg/l and mg/kg units, which may be 
significant in any measurements using digestion techniques and dilution 
factors.  One very troubling void is the availability of tests for 
hexavalent chromium within packaging or RoHS materials - typically added as 
pigments.  Total chromium tests may allow determination of compliance below 
the legislated limits, but the lack of any valid means of determining 
hexavalent chromium in, for example, plastic does not allow conformity 
assessment when test results for elemental chromium are above the legislated 
limits.  This situation is comp-licated by the fact that many hexavalent 
chromium pigments are not water soluble and thus cannot be extracted with 
water as is common practice.  When the pigmented substrate is also not 
permeable to or soluble in water, even water soluble hexavalent chromium may 
not be extractable using water.  Thus there is a very big problem with the 
measurement of hexavalent chromium versus other forms (trivalent or 
elemental) of chromium.

That being said - the EU enforcement authorities don't know how to measure 
accurately, so you're probably safe with whatever results you have.  I have 
heard that the EU officials have about 250 cases of RoHS infractions they 
would like to bring against companies, but they cannot do so because they do 
not have standard test methods.  Any other tests they may have at their 
disposal will not at this time produce results that will hold up in court.

This is all due to the people writing and lobbying the legislation not 
knowing what they are talking about, but thinking they do.  It is a strong 
argument for getting real scientific organizations such as NIST and IUPAC 
involved in the debate before the legislation goes into effect.  Otherwise, 
this sad situation will be repeated over and over (California, anyone?). 
The very same lobbyists involved in the EU legislation are also involved in 
every other major RoHS-like proposal, and people tend to listen to those 
lobbyists because they come from big multi-nationals and talk very 
authoritatively.  I know for a fact that those very same lobbyists don't 
understand the technical issues, though they will never tell you that 
themselves.  Yet they are the ones creating all this mess, sometimes to the 
chagrin of the USTR.  And they do this in the name of others, while mostly 
acting on their own whims.

Tim  McGrady
Chairman, ASTM International Committee F40
Environmental Manager, LG Electronics


----- Original Message ----- 
From: "Scott Xe" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Saturday, September 15, 2007 6:05 AM
Subject: [LF] RoHS Directive vs Packaging Directive


> For packaging materials, they must be compliant to Packaging Directive
> 94/62/EC, not RoHS Directive for a simple reason that RoHS Directive
> excludes packaging materials.  Both directives co-exist for looking after
> different areas.  Once RoHS Directive becomes in force, lots of packaging
> material were tested to RoHS Directive.  Can the test report be considered
> acceptable if the sum of all 4 required hazardous substances is less or
> equal to 100 ppm although they are tested to RoHS Directive.  If not, what
> are the major concerns to be addressed?
>
> Thanks and regards,
>
> Scott
>
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