Tim McGrady has ably pointed out the difficulty of determining RoHS
compliance of electronic products where no standard exists, and the
resulting manufacturers' vulnerability to "eco-zealous" enforcers. He
uses as example the difficulty of determining whether a brominated flame
retardant (which the products will all have) is one of the prohibited
ones.

Allen Ferry and others have commented on using "due diligence" as a
defense should compliance be challenged. I have three questions:

*    Is the fact that the prohibited BFRs cannot be purchased a
"diligent-enough" defense to show that they therefore cannot be present
in the product?

*    Who has the burden of proof under European law?

*    What happens to product while a challenge is being resolved?

Perhaps Brian or someone else can answer another question, this one
concerning the use of Pb-free solder in electronics being used for
airplanes. Given that the major airplane manufacturers are now
expressing concern about Pb-free electronics reliability, do they make
any distinction in their requirements between electronics whose failure
would affect safety of flight and electronics whose failure would
disappoint passengers because they couldn't view a movie? 

 

Gordon Davy 


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