Why the redundant legislation?  WEEE requires recycling lead-tin solder?  Why ban lead in
solder under RoHS, also?
Are you aware that the alternatives--using copper and silver-- are also toxic to life and
far more bio-available in all their forms?  Have you considered the deterioration of
reliability that will send these more toxic products to the waste stream much more quickly
than products made with tin-lead solder, used successfully in the electronics industry for
over 50 years with NO documented impact on human or other life form health?  Have you
considered the 25% increase in energy required for reflow of these substitute,
questionably -reliable alloys?  Have you considered the resultant CO2 release?  Have you
considered the diversion of energy and money that the counter-productive ban on lead in
solder is costing to worthwhile efforts to fight pollution, such as WEEE?
Ms. Wallstrom, we are talking about using questionable soldering alloys in aircraft black
boxes and life-saving medical equipment.  Who will assume the liability-- the EC, which
you head?  Finally, are you aware that lead in electronic solder represents only 0.5% of
total lead usage?

Harvey Miller
Fabfile Online


----- Original Message -----
From: "Davy, Gordon" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Wednesday, January 19, 2005 7:13 AM
Subject: [LF] Who will be ready in time for RoHS?


At Kay Nimmo's suggestion, I went to the European Leadfree website. It is required to
become a member to enter. After I did this (it's free), I did a search on "RoHS" and found
57 articles. I had hoped to find more about progress of EU member states in implementing
the enabling legislation, but didn't.
when
I did find two entries I thought interesting, which were links to articles on other web
sites, along with a brief synopsis. I present excerpts from these articles below and
follow with questions.

Excerpt of a press release dated 13 August 2004 from the official European Union's web
site, http://europa.eu.int/rapid/pressReleasesAction.do?reference=IP/04/1033
<http://europa.eu.int/rapid/pressReleasesAction.do?reference=IP/04/1033&format=HTML&aged=0
&language=EN&guiLanguage=en> &format=HTML&aged=0&language=EN&guiLanguage=en.

Environment Commissioner Margot Wallström said: "We are buying and then throwing away more
and more electric and electronic products. They pose real problems in the municipal waste
stream because they are often made up of hazardous materials. The two new directives will
put an end to this - but only once they are transposed into national law. I am
disappointed that 24 Member States have missed today's deadline and urge them to speed up
the legislative process. We need to act quickly to stop the damage that electric waste is
creating."

Only Greece has met the deadline for transposing the Directives into their national
legislation. Most other Member States are currently adopting legislation. Once the Member
States have sent their legislation to the Commission, it will check it for compliance and,
if necessary, take further action. The Commission can open infringement procedures against
Member States that do not meet transposition deadlines.

Excerpt from an article in Electronic News, December 16, 2004,
http://www.reed-electronics.com/electronicnews/article/CA488297.html?industryid=21372.


According to internal studies conducted by EMS provider Solectron Corp., 38 percent of its
suppliers are not expected to be compliant with lead-free regulations on time. The
deadline for compliance with the European Union's Restriction of Hazardous Substances
(RoHS) regulations is July 1, 2006. Problem is, companies are currently designing products
that will be sold after the RoHS deadline. So component suppliers that are not already
producing products that are free of lead, mercury and four other hazardous materials may
miss the boat on getting their parts included in new product designs... "Our customers are
aware of the lead-free situation, but they're busy competing with Dell. It's not their
core competence," Art Morgan, senior manager, technical marketing at Solectron, said.

Questions:

Ms. Wallström, what is the damage that electric waste is creating, and why do the member
state legislators - other than the Greeks - not share your dismay?
Why is it necessary to threaten them for failure to act, when it is supposedly in their
own best interests to act?
Will all twenty-five member states have their enabling legislation in place in time for
producers to know what they have to do to verify compliance?
Since the real losers from lack of enabling legislation are the producers, why are they
not clamoring for responsible legislative behavior?
Will the enforcement authorities in the twenty-four EU member nations that missed their 13
August 2004 deadline be lenient with producers who miss their 1 July 2006 deadline?
How will producers that are ready by the deadline respond to enforcement laxity towards
their competitors who are not?

Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399


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To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
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