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January 2005

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From:
Harvey Miller <[log in to unmask]>
Reply To:
Harvey Miller <[log in to unmask]>
Date:
Wed, 19 Jan 2005 09:33:36 -0800
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RE: [LF] Who will be ready in time for RoHS? Otherr questiosn for Ms. Wallstrom--Pascal

You have posed a very important question that requires much delicacy and respect in its answer-- the Japanese companies' motivations in support of the ban on lead in electronic solder.  No, stupidity is not part of the answer.

You suggest that it was driven by consumer demand, "people pressure".  That is an unwarranted assumption.  The SMART group from the UK journeyed to Japan a couple of years ago and  found almost no public consciousness of the issue of lead in solder.

One has to understand the path that countries who came late, took to catch up to Europe and America, in compressing 300 years of industrial revolution into 30.  That process could not be done from the bottom in a laissez faire, random way.  It had to be done from the top, by design, by prompting, by creating a sense of national mission.  Japan, in particular, was impelled by witnessing China's degradation after 1840, to march fast to a new beat.  The alternative was being colonized.  The entire culture reflects the new awakening, a unified purpose that pervades every thought and action that has no counterpart in the West, except in part, Germany, whose experience in the nineteenth century and before, was analogous to Japan's.

So the move to lead-free solder by the Japanese companies has to be viewed in that context.  It has absolutely nothing to do with the merits of the case, nor with science. It is an expression of environmental enthusiasm that I believe has gone a little too far.

Harvey Miller
Fabfile Online
  ----- Original Message ----- 
  From: Pascal Guiheneuf 
  To: 'Harvey Miller' ; [log in to unmask] 
  Sent: Wednesday, January 19, 2005 8:39 AM
  Subject: RE: [LF] Who will be ready in time for RoHS? Otherr questiosn for Ms. Wallstrom--
   



  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&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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