Not wishing to put anybody off, but the UK consultation
(http://www.dti.gov.uk/sustainability/weee/index.htm#Consultation_on_Governm
ent_implementation) requires response to go to
[log in to unmask]
I'm not going to be in DTI much before the closing date of 29 October.
I would strongly encourage those who will be hit be WEEE & RoHS to respond,
particulary with issues such as last time buys, legacy products etc.
Althought there is little opportunity of changing the draft UK RoHS
regulations themselves, the non-statutory guidance can be improved.
You should also lobby the European Commission and other member states to
consider widening the exemptions before its too late.
I believe the key point is not to argue against the gist of the directives
but to provide a clear and compelling argument to support the case you want
to make.
The guidance supplied by the commission follows:
Any request has to fulfill the requirements given in Article 5(1)(b) of the
directive which allows for 'the exempting of materials and components of
electrical and electronic equipment from Article 4(1) if their elimination
or substitution via design changes or materials and components which do not
require any of the materials or substances referred to therein is
technically or scientifically impracticable, or where the negative
environmental, health and/or consumer safety impacts caused by substitution
are likely to outweigh the environmental, health and/or consumer safety
benefits thereof'.
In order to ensure that requests give the required information you need to
be able to supply the information below:
1. Please describe the material / component of the electrical and electronic
equipment that contains the hazardous substance.Please indicate the type and
quantity of the hazardous substance used in the homogenous material. Please
indicate the quantity of the substance in absolute numbers and in percentage
by weight in homogenous material.Please indicate the functionality of the
substance in the material of the equipment. Please also provide an estimate
of the annual quantities of the hazardous substance used in this particular
application.
2. Please explain why the elimination or substitution of the hazardous
substance via design changes or materials and components is currently
technically or scientifically impracticable.
3. Please indicate if the negative environmental, health and/or consumer
safety impacts caused by substitution are likely to outweigh the
environmental, health and/or consumer safety benefits.If existing, please
refer to relevant studies on negative impacts caused by substitution.
4. Please indicate if feasible substitutes currently exist in an industrial
and/or commercial scale.Please indicate the possibilities and/or the status
for the development of substitutes and indicate if these substitutes will be
available by 1 July 2006 or at a later stage.
5. Please indicate if any current restrictions apply to such substitutes. If
yes, please quote the exact title of the appropriate legislation/regulation.
6. Please indicate the costs and benefits and advantages and disadvantages
of such substitutes.If existing, please refer to relevant studies on costs
and benefits of such substitutes.
7. Please provide any other relevant information that would support your
application for an additional exemption.
I recognise it sounds a lot but do urge you submit, either or both
individually or through your trade associations.
Regards
Nick 14/10/2003
From: Nick Jolly, Dept. of Trade & Industry
Electronics Unit
E-mail: [log in to unmask]
Tel: +44 (0)20 7215 1331
Fax: +44 (0)20 7215 1966
Mobile: 0787 640 7444
Snail: Bay 254
151 Buckingham Palace Road
London SW1W 9SS
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: 12 October 2004 17:41
To: [log in to unmask]
Subject: Re: [LF] Remediating Pb Components to Pb-free
Greg,
I can't directly answer your question but hav
Greg,
I can't directly answer your question but have heard it discussed.
I would however strongly urge individuals and companies to forward all
these RoHS implementation issues to both the DTi at the email below
before the 29th Oct 2004 which is when the final consultation period
ends (for the UK - but contributions from all and any will add weight)
AND to all trade associations to which you may belong and urge them to
put pressure on appropriate government channels to take sensible action.
The sudden obsolescence of components in the face of RoHS conversion is
beginning to escalate making decisions on redesign difficult if not
impossible to judge. We already know that some components are not
promised as RoHS compliant until very close to the deadline - how many
of those will turn into no shows?
How many of us big and small alike will be faced with finding the
critical component unavailable as RoHS compliant only days or weeks
before the deadline, no matter how much effort we have expended in
ascertaining otherwise?
FYI - there is a group of companies currently pursuing the exemption of
life time buy stocks - if you would like to join the group email me.
If the whole of the electronics industry had work in unison on this
issue from the outset then we would not be facing the predicament we are
now and would possibly have been able to comply. As it stands now there
are some very serious issues facing many companies, however unless there
is joint action by all concerned then there is absolutely no hope of
turning any of them around.
Email issues regarding WEEE & RoHS, giving justifiable reasoning and
practical solutions, to:
Nick Jolly, Dept. of Trade & Industry
Electronics Unit
E-mail: [log in to unmask]
Tel: +44 (0)20 7215 1331
Fax: +44 (0)20 7215 1966
Mobile: 0787 640 7444
Snail: Bay 254
151 Buckingham Palace Road
London SW1W 9SS
Regards,
Chris
____________________________________________________
Chris James
Engineering Services Manager
Dolby Laboratories, Inc.
Direct: 01793 842136
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Anderson, Greg (GE
Infrastructure)
Sent: 12 October 2004 16:50
To: [log in to unmask]
Subject: [LF] Remediating Pb Components to Pb-free
Forum:
With the more recent definition of homogeneous materials as less than 1%
of essentially any material in/on components, my company has found
itself backed into a corner. We have many existing designs with legacy
components that WILL NOT be manufactured "Pb-Free", but would be
economically unfeasible to redesign to incorporate newer, Pb-Free
components.
As an option, I was asked if it were feasible "to strip the Pb from the
component leads, and re-apply a Pb-Free coating."
So, ignoring the remaining questions regarding whether or not the
"internals" are RoHS compliant, or if the "internals" could survive the
higher soldering temperatures, I ask the forum:
1) Is it technically feasible to perform such a remediation?
2) Are there companies that are actually performing this work (either
for themselves or as a service?).
Thanks,
Greg Anderson
Manfacturing Engineer
GE Fanuc Automation
Charlottesville, VA
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