Hi Kay
I think it is important that any comments to your questions understand the
context in which it was first disclosed. The proposed statement
"Homogeneous material means a unit that can not be mechanically disjointed
in(to?) single materials" came from a draft guidance document that was
circulated at a Technical Adaptation Committee (TAC) meeting in January this
year. I can only guess it was intended to help member states agree on the
proposed maximum tolerated values, though from the comments I have seen so
far it appears to have confused an already ambiguous piece of legislation.
I agree with most of Joe's comments but would add a further separation of
'homogeneous' depending on your position within the supply chain.
For an original IC manufacturer, I would suggest a lead frames is a
homogeneous material. All of the elements used to fabricate the IC must
comply with RoHS (accepting obvious exemptions).
For an OEM, the IC itself is the homogeneous material as it is procured for
a specific function and would not normally be 'mechanically disjointed' into
its component elements.
An interesting point is that components (IC's) are not mentioned within
annex 1(a&b) of the WEEE directive and therefore they do not fall within the
scope of RoHS!
Kind regards
Paul
Paul Chinery
Dionics PLC
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-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Kay Nimmo
Sent: 06 February 2004 09:21
To: [log in to unmask]
Subject: [LF] imurity limits in RoHS
Following on from these comments from Paul I would be interested to get
some comments on what people understand by the terms used in this EU
proposed definition of impurity level. i.e. what is;
1. a homogeneous material?
2. a unit?
3. mechanical separation?
4. a single material?
It seems there are many different interpretations of this and I am
trying to discover which ones are most generally accepted. E.g. Paul
indicates in his message that a complete component is seen as
homogeneous since it may be difficult to mechanically separate. Others
seem to believe a unit is a complete circuit board, but it is also
possible that homogeneous means each material used to make up a
component.
Any comments? I would really like to get this clarified.
thanks
Kay Nimmo
-----Original Message-----
From: Paul Chinery [mailto:[log in to unmask]]
Sent: 28 January 2004 09:34
To: [log in to unmask]
Subject: Re: [LF] Understanding Homogenous term
Hi Cliff
In December 2003, the European Commission released the following
statement:
"The commission services have prepared a draft Commission decision
establishing maximum concentration values pursuant to Article5(1)(a) of
Directive 2002/95/EC. The proposed values have been discussed at the
Technical Adaptation Committee (TAC) meetings this year."
The values they refer to are the 0.1% for lead, mercury, hexavalent
chromium, PBB and PBDE and 0.01% for cadmium. They go on to clarify the
term homogeneous:
"Homogeneous material means a unit that can not be mechanically
disjointed in single materials".
To answer your question, my understanding is RoHS applies to each and
every individual component, as an assembly can be separated.
Kind regards
Paul Chinery
Dionics plc
www.pb-free.info
T : +44 (0)2476 713366
F : +44 (0)2476 714488
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Cliff Knudson
Sent: 27 January 2004 18:59
To: [log in to unmask]
Subject: [LF] Understanding Homogenous term
Hi folks,
Sorry if this has been covered. But I am currently discussing the .1%
lead by weight directive from EU. What is the majority view regarding
the definition of homogenous? If I build an assembly with soldered
components is this EU directive referencing the capacitor or assembly
level? I am assuming the component versus assembly.
Thanks,
Cliff Knudson
Component Engineer - Nokia
650-625-2245
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