Chris,

You're right. I am talking about differences in due diligence requirements
and enforcement country to country. UK allows some level of due diligence;
Netherlands says "either it complies or it doesn't - who cares about what
your suppliers say".

Regards,
Mike

-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: Thursday, May 19, 2005 8:43 AM
To: (Leadfree Electronics Assembly Forum); Michael Kirschner
Subject: RE: [LF] Data gathering and maintenance requirement for RoHS
compliance


RoHS is a single market directive with the requirements being the same
in all states. So no state can have "more or less draconian
requirements".

The WEEE may vary with only deminimus levels defined.

Regards,
Chris
____________


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner
Sent: 19 May 2005 16:16
To: [log in to unmask]
Subject: Re: [LF] Data gathering and maintenance requirement for RoHS
compliance

Blair,

There are two issues:

1. Legal due diligence
2. Supply chain due diligence

The directive doesn't say anything about either; the UK law has been
described here before; other EU member state laws may be more or less
draconian in their requriements. Note that whatever the laws are, they
don't
care about anything other than the 6 materials. So for legal due
diligence
you simply have to concern yourself with the 6 materials (in their
myriad
forms) in homogeneous materials as defined by the TAC.

On the other hand, supply chain due diligence at this point in the game
is a
necessity, and has different requirements. Understanding how well your
suppliers understand "homogeneous" and RoHS requirements is key to
ensuring
that your products will comply with the laws. We have found, and
continue to
find, significant misunderstandings within our clients' supply base.
These
manufacturers must either come up to speed or be dropped from the
AML...which is happening.

Regarding EuP, it does seem to define the need for more complete
material
composition reporting, but don't expect that to be described more fully
until later this year or early next, and even then it won't be a legal
requirement until and unless "implementing measures" are adopted. It's a
framework directive, and, if the industry doesn't pull it's act together
voluntarily, directives affecting specific product classes will be the
next
likely step.

By the way, John Burke, your message below saying that "you will need it
to
prove a route to compliance unless you are using a contract manufacturer
in
which case you can get him to do it" is wrong in one sense. The
"producer"
needs to prove due diligence. What avenue the producer (OEM) chooses to
take
to do that is up to them, but they'd better use a trusted and
knowledgeable
source to do it. Very few contract manufacturers have any capability to
do
this, much less the knowledge to do so (in my experience only a couple
of
the top five can).

Mike

On Thu, 19 May 2005 05:22:51 -0700, Blair K. Hogg
<[log in to unmask]> wrote:

>Thanks all for the replies.
>
>Chris and Nigel are saying that I don't need the ppm data, if all of my
suppliers cert that the parts are compliant, I'm OK. I'm leaning towards
agreeing with them.
>
>On this side of the pond MA/NY DDave is suggesting that I do need the
ppm
data. So we have a difference of opinion. BTW, Dave, I was up in your
area
two weeks ago, checking out new SMT equipment at NepCon.
>
>I don't see what having the ppm data gets me, if the directive applies
to
individual parts. But I know how govt agencies can work when enforcing
these
kind of regulations, so I'm worried.
>
>Blair
>
>
>
>>>> [log in to unmask] 05/19/05 08:05AM >>>
>Yes you will need it to prove a route to compliance unless you are
using a
>contract manufacturer in which case you can get him to do
it.....someone has
>to do it to show due diligence in case there are any issues downstream.
>
>Here is another link to get the data validated....
>
>http://www.rohsusa.com
>
>You can also get software through companies like E2open, worth checking
out
>for larget corporations.
>
>John
>
>------------------------------------
>Avanex
>John Burke
>Senior Manager RoHS Compliance
>[log in to unmask]
>40919 Encyclopedia Circle
>Fremont
>CA 94538
>tel: 510 897 4250
>fax: 510 979 0189
>mobile: 510 676 6312
>------------------------------------
>
>
>-----Original Message-----
>From: Leadfree [mailto:[log in to unmask]]On Behalf Of Blair K. Hogg
>Sent: Wednesday, May 18, 2005 12:05 PM
>To: [log in to unmask]
>Subject: [LF] Data gathering and maintenance requirement for RoHS
>compliance
>
>
>Avnet (US distributor) was here today making a presentation on a
service
>they are offering to customers (either free or for a fee, based upon
level
>of service) that will collect and organize data for RoHS compliance.
>Something in their presentation stirred up a few brain cells and I
decided
>to go to this forum to see how everyone else is approaching compliance,
or
>demonstration of compliance.
>
>Avnet will supply the materials content in ppm for each of the RoHS
>substances, along with other component data such as weight.
>
>I'm wondering if I really need this information.
>
>The directive covers "homogenous materials" as needing to be compliant
and
>the accepted interpretation is that everything down to the plating on
the
>leads of a resistor must be compliant. I don't see where the breakdown
in
>ppm per part and weight are important. If I was taking the approach
that my
>product weighed 25kg, I could have 25g of lead and be at the 100 ppm
level,
>however, with the homogenous materials approach this doesn't matter.
>
>So what I am looking for is a statement from the supplier or
manufacturer
>that the part is RoHS compliant in itself. If all of the parts I use
are
>compliant, and my processes are compliant, then the assembly is
compliant by
>default.
>
>Do I need the materials content data for anything? I have heard that
some
>customers are asking for this, as opposed to simply asking for a
statement
>of compliance.
>
>Thanks,
>
>Blair Hogg
>QA Manager
>GAI-Tronics Corp
>

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