Hi Scott,
In answer to your question regarding potential exemption of your product, we
would offer the following observations.
It could be argued that video routers and switchers for the broadcast
industry, fall within the scope of the WEEE and RoHS Directives under
category 3 -
“3. IT and telecommunications equipment”
which goes on to specify
“…and other products or equipment of transmitting sound, images or other
information by telecommunications”
In terms of exemptions regarding this type of product, there is an exemption
within the RoHS Directive annex -
“10. Within the procedure referred to in Article 7(2), the Commission shall
evaluate the applications for:
— Deca BDE,
— mercury in straight fluorescent lamps for special purposes,
— lead in solders for servers, storage and storage array systems, network
infrastructure equipment for switching,
signalling, transmission as well as network management for
telecommunications (with a view to setting a
specific time limit for this exemption), and
— light bulbs,
as a matter of priority in order to establish as soon as possible whether
these items are to be amended accordingly.”
However, this exemption is for lead in the solders only, (it does not refer
to lead in components) and it is subject to urgent status review.
With reference to a response from Matthew Trend -
“Even if the tuner is not lead-free, will the total percentage of lead in
the finished product be less than 0.1% (or whatever the cut off point is),
and is that the whole product including the chassis, or is it only the PCB
assembly?”
I would quote from a recent European Commission paper proposing -
“A maximum concentration value of 0.1% by weight in homogeneous materials
for lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and
polybrominated diphenyl ethers (PBDE) and of 0.01% weight in homogeneous
materials for cadmium shall be tolerated. Homogeneous material means a unit
that can not be mechanically disjointed in single materials”.
It would seem that the maximum concentrations apply to each “homogeneous
material” and not the total % of lead (Pb) in the finished product overall.
I hope this helps. If you have any further queries please let me know.
Best regards
Paul Chinery
Managing Director
Dionics PLC
[log in to unmask] <mailto:[log in to unmask]>
www.dionics.co.uk <http://www.dionics.co.uk>
Tel: +44 (0)24 76 71 33 66
Fax: +44 (0)24 76 71 44 88
Dionics Plc accepts no liability for the content of this email, or for the
consequences of any actions taken on the basis of the information provided,
unless that information is subsequently confirmed in writing. Any views or
opinions presented in this email are solely those of the author and do not
necessarily represent those of the company. E-mail transmission cannot be
guaranteed to be secure or error-free as information could be intercepted,
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The sender therefore does not accept liability for any errors or omissions
in the contents of this message, which arise as a result of e-mail
transmission. If verification is required please request a hard-copy
version.
Dionics Plc is registered in England and Wales No. 2568427.
Registered Office is Fletchworth Gate, Coventry, CV5 6SP, United Kingdom
Tel. +44 (0) 24 76 71 33 66
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Scott Lefebvre
Sent: 22 January 2004 22:23
To: [log in to unmask]
Subject: [LF] ROHS EXEMPTIONS
We manufacture high end video routers and switcher for the broadcast
industry, we do not manufacture any consumer electronics. At one time I
read and have also been told that we are excepted from Lead Free
requirements. Does anyone have any new information concerning this issue?
Scott Lefebvre
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