But what do you think of the Japanese companies which begun to ban the lead
from solder about 5 years ago, under people pressure, with no specific
legislation ? Are the Japanese "stupid" as well ?

About medical and transportation, they are exempted because of reliability.
But they need the consumer market to progress, and then they are obliged to
study lead-free. A sort of paradigm which can become a trap.

Pascal Guihéneuf




-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Harvey Miller
Sent: mercredi 19 janvier 2005 17:26
To: [log in to unmask]
Subject: Re: [LF] Who will be ready in time for RoHS? Otherr questiosn for
Ms. Wallstrom--


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&form
at=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?industr
yid=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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