The European Parliament enacted a document on May 15, 2001 that looks and
smells a lot like swiss cheese.

For example,  'Servers, storage..., voice and data transmission and
networking equipment" are exempted---- very broad because it implies no ban
on lead in solder used in components and assembly for all computer and
communications equipment.  What a manufacturing hodgepodge this would cause,
were other electronic equipment really be required to use lead-free
components and assembly!

The loopholes provided in the other amendments may delay any real
implementation or enforcement of the ban on lead in electronics forever.

 Amendments 6 (11)  finally calls for risk assessment to determine whether
subtitutes might not be worse, and whether there really is risk (from lead in
solder).  The result "should" permit more exemptions.  The same paragraph
would exempt lead (implied)  if substiturion is technically or scientifically
impossible.

There will be no problem demonstrating that lead in solder represents no risk
to the environment or to people.  Substitution will be close to impossible
(from a total manufacturing system point of view) simply because the billions
of dollars needed to make it possible are not and will not be available.

I believe that this is a hollow law that has been enacted to save face, with
very little enforceability.

But I also believe that it is necessary to continue the battle for
enlightenment, to bury the entire lead-ree nonsense at the next stage--
consideration by the member states.

Harvey Miller

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