Gordon,
No, not very comforting.
The IPC Materials Declaration Team has sent a letter to the appropriate EU personnel asking for clarification of some of these issues, but to the best of my knowledge Fern has still not received an answer. This is probably because they (EU) had not thought that far ahead when they drafted the dreadful thing in the first place. As more than one wag has stated, we will probably have to wait for clarification when that first unfortunate company is dragged into court. Then we MIGHT get definitive answers.
regards,
Bev Christian
Research in Motion
-----Original Message-----
From: Davy, Gordon [mailto:[log in to unmask]]
Sent: May 5, 2004 4:26 PM
To: [log in to unmask]
Subject: Re: [LF] Lead in resistors
Bill Haas has noted that 0402 surface-mount "lead-free" resistors were found to contain more than 1000 ppm Pb, and that the suppliers assured him that this is OK per the RoHS legislation. Bill wanted to know where it says in the directive that what the resistor manufacturers told him is so. Annex item 7 exempts Pb in "electronic ceramic parts (e.g. piezoelectronic devices)", so it looks as if this is what they are referring to.
What the Directive doesn't say anywhere, of course, is that for components not exempted by the Annex the maximum allowable level is 1000 ppm, or how the limit (whatever it turns out to be) is to be calculated - i.e., what is to be used as the fraction denominator: termination finish, component as a whole, assembly as a whole, equipment as a whole. Article 4 paragraphs 1 and 2 say that there can't be any Pb at all except per the Annex, and paragraph 3 puts manufacturers on notice that they may have to eliminate other stuff later.
Also not spelled out is how users of components - such as Bill - are expected to document that the equipment items that they are selling are Pb-free: will the envirocops be satisfied if the equipment manufacturer can produce upon demand a certificate of compliance from the manufacturers of each component? If not, how diligent does the original equipment manufacturer have to be to ensure that no Pb above the to-be-determined limit (except as permitted by the Annex) has crept into his product?
As an analogy, hardware destined for space has long had a prohibition against pure tin plating. Yet every time a satellite has been audited, cases of pure tin plating have been found, due simply to human error. Can you imagine the jeopardy of the manufacturer of an electronic system, wondering if a particular item will be randomly selected to find out if it contains Pb? (X-ray fluorescence will be useless for levels of 1000 ppm, so if that's the level that is finally chosen, we're talking serious chemical analysis.)
Article 8 specifies that the penalties are to be "effective, proportionate, and dissuasive." I don't see any language describing how disagreements are to be resolved, or what happens to the equipment while the matter is being settled. Not very comforting.
Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399
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