Edward,
You just nailed it right on the head. Enough about the rules,
interpretation about the rules, discussion of this and that person's
interpretation of the rules versus the other, references to papers on
the subject of interpretation of the rules, intention of the rules, etc.
Especially because all of the rules are based on a complete fallacy! Who
gives a rat's *ss! 

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Edward Szpruch
Sent: Thursday, July 20, 2006 1:19 AM
To: [log in to unmask]
Subject: Re: [LF] Spam:Re: [LF] RoHS 5 and RoHS 6

Hi all,
Just looking on the last chain of letters someone can get idea how such
a stupid and false idea of leaching out of lead in garbage stockpiles
can create such monstrous results.
Or maybe this is brilliant solution to reduce unemployment rate among
graduates from universities. What a new job opportunities for thousands
and thousands lawyers, language interpretators and even maybe few from
PCB area.
The recent discussion has nothing with technology - just how to
interpretate few unclear sentences written by "lawmakers" , followed by
"guidance writers" etc...
Edward



-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of MacFadden, Todd
Sent: Wednesday, July 19, 2006 7:42 PM
To: [log in to unmask]
Subject: Spam:Re: [LF] RoHS 5 and RoHS 6

Hi Folks, 

Great discussion. 

Related to Mike's and Dave's comments below about the
application-specific vs. component-specific distinction, I'd like to
clarify one subtle (but important) point about the Pb exemption (7 in
the Annex) because the latest DTi Guidance is slightly
confusing/misleading on this issue. 

In its description of Exemption 7 on p.18, the Guidance states: "the
term 'solder' also includes all materials that become part of the final
solder joint, including solder finishes on components or printed circuit
boards." Unfortunately, the Guidance does not distinguish the
application-specific exemptions (servers, networks) - where the
solderable termination finishes and PCB finish may contain Pb, since the
entire application is exempt - from the component-specific exemption
(high-T solder [>85% Pb] and Pb in ceramic parts) where the termination
finishes and the PCB finish MUST be Pb-free. 

Otherwise, the Guidance is quite good.

By the way, in case you haven't seen it yet, here is a link to the
latest Guidance:
<http://www.rohs.gov.uk/Docs/Links/RoHS%20Regs%20Guidance%20-%2021%20Jun
e%202006.pdf>


Todd

--------------------------------------
Todd MacFadden
Component Engineer
Bose Corporation
The Mountain, MS 31
Framingham, MA 01701-9168
508.766.6259
--------------------------------------


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Mike Kirschner
Sent: Wednesday, July 19, 2006 10:55 AM
To: [log in to unmask]
Subject: Re: [LF] [TN] RoHS 5 and RoHS 6


Hi Dave,

You're absolutely right; the paragraph 7, line 2/3 exemption for lead in
solder is application-specific based on the end-use product application;
it is somewhat different from most exemptions in that respect. I agree
that "RoHS 5" is convenient short-hand and TE's explanation below is
quite clear.

However, as this thread has shown, it is still not well-understood, or
at least well-explained. I hope its meaning has now been successfully
explained. I still don't like it ;o).

Mike

On Wed, 19 Jul 2006 09:09:42 -0400, Bender, David R
<[log in to unmask]> wrote:

>Would like to add one comment to the previous note from Mike regarding 
>RoHS 5 or 5/6 Compliance.
>
>While I agree with his concerns, this exemption "lead in solder for 
>servers, etc" is not quite the same as other "material" exemptions.
>For example, as a component supplier I don't think is reasonable to say

>my component is RoHS compliant using an exemption for lead in solder as

>the component is not an end item (server)that is covered by the 
>exemption and in fact the component may be used in applications (e.g a 
>desktop
>computer) where that exemption is not allowed. So for a component 
>supplier, or purchaser of components, the RoHS 5 designation is very 
>useful.
>
>The RoHS 5 definition that TE uses is that "component is RoHS compliant

>except that it contains lead only in the solderable interface. This 
>component may be used in applications that qualify for the lead in 
>solder exemption."  5/6 compliance is handled more or less like this in

>the IPC 1752 form as well where there is a separate designation for 5/6

>compliant parts although term is not used directly - IPC 1752 says
>"Item(s) does not contain RoHS restricted substances except lead in 
>solder and any other selected exemptions".
>
>
>Dave Bender
>Director - RoHS Program Mgmt.
>TYCO Electronics
>
>-----Original Message-----
>From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner
>Sent: Wednesday, July 19, 2006 1:04 AM
>To: [log in to unmask]
>Subject: Re: [LF] [TN] RoHS 5 and RoHS 6
>
>Folks,
>
>Let me be abundantly clear: there is NO SUCH THING as "RoHS 5". I 
>recommend that you drop it from your lexicon and never speak of it 
>again. ;o)
>
>Your products, if they are within the scope of RoHS (EU), must comply 
>with the maximum concentration values in homogeneous materials for all 
>six classes of restricted substances, taking in to account applicable 
>exemptions.
>
>One of these exemptions is for "lead in solder for servers, storage and

>storage array systems", and "network infrastructure equipment for 
>switching, signalling, transmission as well as network management for 
>telecommunication". Read the Annex, paragraph 7, lines 2 and 3 and you 
>will see this exemption.
>
>When people speak (sometimes lovingly ;o) of "RoHS 5", they are 
>referring to this specific exemption. It ONLY exempts lead used in 
>solder; for instance, on PCB-mounted components, the PCB itself, and 
>the solder used to join them, or wires to connectors. OTHER USES OF 
>LEAD WHICH ARE NOT EXPLICITLY EXEMPTED BY THIS OR OTHER GRANTED 
>EXEMPTIONS ARE NOT EXEMPT! Thus your products may not, for instance, 
>contain lead in plastics (commonly used in flat cables, etc.). And 
>you'd better check for this if you haven't yet...
>
>So "RoHS 5" is a shorthand misnomer. It is misleading; one admittedly 
>very significant exemption for lead does not exempt ALL uses of lead in

>electronics. If you cannot tell yet, I really dislike this term because

>it is dangerously imprecise.
>
>Also, Mr. Kane's statement below that you have to state anything is a 
>bit misleading. To restate Chris' comments a bit differently, this is a

>"self declaration" process. You don't have to "state" anything; you 
>don't
have
>to
>"declare" anything; you don't need a mark of any kind anywhere
including
>a
>"CE" mark in order to comply with EU RoHS. You simply have to explain, 
>when asked by an enforcement authority or maybe a customer, why your
products
>are
>the way they are (in scope/out of scope/able to take xyz 
>exemption/etc.)...
>convincingly... with data...
>
>
>Mike Kirschner
>President
>Design Chain Associates, LLC
>www.DesignChainAssociates.com
>www.ChinaRoHS.com
>
>-----Original Message-----
>From: James, Chris [mailto:[log in to unmask]]
>Sent: Tuesday, July 18, 2006 7:02 AM
>Subject: Re: [TN] RoHS 5 and RoHS 6
>
>
>RoHS 5 is a termed coined by industry. It is not in the legislation.
>RoHS 5 is understood to mean you are claiming an exemption which 
>permits the continued use of lead. There is no provision you need to 
>declare you have used an exemption. However you would need to declare 
>such on any d of c you might be asked for and you are best advised to 
>internally document your decision for claiming the exemption for when 
>the rohs police with their xrf guns come a knocking...........
>
>Regards,
>
>Chris
>
>-----Original Message-----
>From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kane, Amol (349)
>Sent: 18 July 2006 14:34
>To: [log in to unmask]
>Subject: Re: [LF] [TN] RoHS 5 and RoHS 6
>
>Hi Joel,
>The EU legislation limits the use of 6 hazardous chemicals (Lead, 
>Cadmium, Mercury, Hex Chromium, PBBs and PBDEs). RoHS 6 compliant means

>that all these 6 substances are below the permissible level in the 
>assembly. RoHS 5 means that 5, out of the 6 substances are below the 
>permissible level, and the 6th substance is above the permissible 
>level, but is covered by a RoHS exemption (thereby making the assembly 
>RoHS compliant). Usually lead is above the permissible level in RoHS 5 
>assemblies as there are lead solder exemptions for specific 
>applications.
>
>If your assembly is RoHS 6, you need not declare a class, but if its 
>RoHS 5, you must state that it is RoHS 5 and then state the exemption 
>class that is applied to the product.

------------------------------------------------------------------------
-------Leadfee Mail List provided as a service by IPC using LISTSERV
1.8d To unsubscribe, send a message to [log in to unmask] with following
text in the BODY (NOT the subject field): SIGNOFF Leadfree To
temporarily stop/(start) delivery of Leadree for vacation breaks send:
SET Leadfree NOMAIL/(MAIL) Search previous postings at:
http://listserv.ipc.org/archives Please visit IPC web site
http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional
information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100
ext.2815
------------------------------------------------------------------------
-------

-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------