Hi Bob,
While not all of RoHS is bad, your points are well taken.
So lets concentrate on the real bad part—the Pb ban.
We should actually turn the argument around. Since it now is clear, that all the substitutes for SnPb are environmentally more damaging—less sustainability, more energy use, worse in land fills, more scrap to go into land fills, lower reliability, tin whiskers, ravaging tin mining, etc. etc., the USA should ban electronic imports that contain Pb-free solders [unless their use can be explicitly justified] on those grounds. That would put USA products on a higher plane than those problematic Pb-free electronic products with the arguments of more environmentally products that are also more reliable.
Werner

 


 

 

-----Original Message-----
From: Bob Landman <[log in to unmask]>
To: [log in to unmask]
Sent: Tue, Mar 16, 2010 11:48 am
Subject: [LF] The Brainstorm: Should the U.S. employ RoHS-like standards for imported products?


This is a response to those opposing the House bill in the Congress on 
exemptions for lead in NEMA products.  IPC is against the bill as is AIA.

Bob Landman
H&L Instruments, LLC

http://www.nema.org/media/eiextra/20081020b.cfm

Should the U.S. employ RoHS-like standards for imported products?

Regulatory officials in the U.S. would have a hard time justifying RoHS-like 
thresholds for imported products only because a standard that applies just to 
foreign-made products would constitute a serious barrier to trade for overseas 
manufacturers. Furthermore, it would imply that products manufactured in the 
U.S. are held to a lower standard of “safety” than imported products. This is 
not the kind of message consumers expect to hear from our government.

On the other hand, it’s clear now that the European RoHS thresholds are becoming 
a de facto global standard, influencing markets far beyond the EU. If the U.S. 
does not address this trend, it could find itself a “dumping ground” for 
products that can no longer be sold elsewhere as more and more countries adopt a 
RoHS approach. From this standpoint, standards on imported products could serve 
to protect consumers while simultaneously encouraging domestic manufacturers to 
develop “greener” products as a means to compete.

So what’s the solution? At NEMA, which represents the electrical product 
industry in the U.S., we believe that if a product standard can be justified on 
the basis of science, safety, and product performance, it should be applicable 
to a product regardless of where it is manufactured – imported or domestic. We 
also recognize the impact of RoHS-type rules on the worldwide regulatory arena 
and believe manufacturers should stay ahead of the trend, employing their 
expertise in product design and development to control events as much as 
possible.

For these reasons, NEMA is striving to introduce Federal legislation that would 
establish hazardous substance thresholds for many electrical products sold in 
the U.S., effective July 2010. When enacted, this legislation would apply to all 
participants in the market and would preempt states from enacting different 
standards. This will ensure a level, consistent playing field without 
compromising safety or performance.

The U.S. should definitely employ RoHS-like standards for imported products. The 
world, and particularly the United States, is now making a valiant push to go 
Green. Eliminating hazardous materials from products in our homes, workplace, 
and the landfill is vital to this effort.

The U.S. is still the largest consumer in the world. If we demand higher 
standards, it will help raise the bar for manufacturers around the world who 
depend on our business. If we do nothing, it undermines those who are trying to 
make a difference and improve our lives and our planet.

AOS is a Swiss company, and we have experience with RoHS. For us it applies to 
electronic products in the European Union (EU) whether made within the EU or 
imported. AOS manufactures in Switzerland and draws from worldwide resources. 
Adopting RoHS created a lot of challenges for our company and many other 
electronic manufacturers in the European Union.

Modifying components and retooling was not an easy process, challenging our 
quality and process management to avoid unacceptable delays while maintaining 
the same product quality and reliability. Changing entailed a great deal of 
negotiation, planning and additional cost. It is not a trivial thing.

AOS’s U.S. office is located in California, a state which passed SB 20: 
Electronic Waste Recycling Act of 2003. This act follows many of the EU RoHS 
standards for electronic products being sold in California, but across a much 
narrower scope. It only is a start and the nation should follow suit.

Arguments can be made for or against it. In fact, within DCA the best we could 
do is reach consensus that it would be relatively straightforward, low cost, and 
harmless to implement (and not just for imported product, but for domestic as 
well; if implemented for imported product only it would be readily shot down as 
a trade barrier).

Implementing RoHS in the U.S. would be relatively easy because the supply chain 
infrastructure is in place for it and most products (in terms of volume) are 
already RoHS-compliant. Companies (particularly those with products in high 
volume and consumer markets) build one product for the world, and any 
localization is based on software and maybe a power cord.

However, the fact is that RoHS is a point chemical regulation — it addresses 
only a few chemicals in a narrow range of applications. Implementing it here 
would still leave us several steps behind the EU's leadership in environmental 
policy — they have a "federal" WEEE (Waste Electrical and Electronic Equipment) 
policy, a product energy policy (EuP - Energy-using Products), and a new overall 
chemicals policy (REACH - Registration, Evaluation, Authorization, and 
Restriction of Chemicals).

The U.S. federal government therefore has a long way to go in order to just put 
itself in a position to harmonize with environmental regulations and policies in 
the EU and other parts of the world, much less eventually regain its leadership 
role in environmental policy. Implementing RoHS in the U.S. might put us on the 
path, but it is far from the endgame.

The health risks and recycling difficulties associated with the materials 
covered by RoHS are well known, but the product life-cycle impact from the use 
of alternative manufacturing materials like lead-free solder is just starting to 
be understood.

Although some manufactures, like Motorola, have been successfully using 
lead-free solder since 2001, others have had serious difficulties. In 2006, 
Swatch watches experienced a nearly 5 percent failure rate due to the 
development of “tin whiskers” (small thread-like strands that can sprout from 
lead-free solder and cause short circuits) on circuit boards forcing a nearly 
$1billion dollar re-call.

Creating reliability and product life-cycle issues will affect safety, consumer 
satisfaction and ultimately increase the amounts of waste generated. This is why 
long-lived, mission critical equipment like medical devices and monitoring and 
control systems are currently exempt from RoHS compliance.

Practically speaking, the fact that California passed the Electronic Waste 
Recycling Act in 2003 means we have already adopted these standards - very few 
foreign companies can afford to sell into the U.S. and not sell in California.

As a nation though, we should wait and watch a couple more years of data from 
RoHS compliance overseas. Once the real effect and the potential engineering 
workarounds are better understood we can more rationally assess the benefits.

So RoHS-like compliance will come, but let's not be in such a hurry to make 
recycling easier that we create more garbage in the process.

The answer is "No,” unless it is the same as the RoHS-Directive (2002/95/EC) in 
letter and intent. Europe’s RoHS directive, published in February 2003 and 
implemented in July 2006, led to a tsunami of products produced in the global 
electronics and electrical market, to be distributed across the USA. Destined to 
regulate consumer electronics and electrical products and, more importantly, 
exempt industrial, medical, aerospace and national defense systems; it has 
unfortunately swallowed everything in its wake.

U.S. manufacturers now produce many (but not all) RoHS-compliant products for 
the global market. Why should we develop our own version, when the European 
Community has already influenced the global market in this regard?

Visit any consumer-electronics, office supply store or Wal-Mart, and you will 
see a number of electronic and electrical products that carry the WEEE Wheelie 
Bin and some form of a RoHS symbol. Like it or not, legislation in the USA will 
not change the fact that many RoHS-compliant components, assemblies and products 
are already in circulation here.

Some naysayers and alarmists in the industry warn against the potential for 
failure of RoHS-compliant products with their lead-free make-up and increased 
tin-whisker risks. There are those who would have us support a motion to reduce 
the potential risks and allow for a better technical assessment of a 
RoHS-compliant U.S. Their response would be to support a BAN on RoHS-compliant 
products entering the U.S.

As a member of the G8 and WTO, however, we cannot introduce a potential trade 
barrier on imported products and simultaneously protect U.S.-manufactured 
products. The RoHS-Directive is an emotionally charged topic in certain 
quarters, but so far no serious problems have become evident in the U.S. 
consumer electronics market.

=============================
 
Bob Landman
H&L Instruments, LLC



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