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January 2005

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Subject:
From:
"Stobbe, Irina" <[log in to unmask]>
Reply To:
Date:
Fri, 28 Jan 2005 18:45:42 +0100
Content-Type:
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Hello again,
CE-compliance requires a range of procedures for assessing the conformity of
industrial products to the objectives or "essential requirements"
particularly with regard to safety, public health or consumer protection;
The EU Directive  93/465/EEC of 22 July 1993 lays down rules for affixing
the "CE" conformity marking provided for in the technical harmonisation
Directives concerning the design, manufacture, placing on the market, entry
into service or use of industrial products.
Each Directive for harmonisation requires a conformity test, even one test
for all, in which enterprises and authorities can test the conformity of a
product or process. 
RoHS is not a directive of the harmonisation type, I guess, that is why
there is no test until now, that proofs the limits of lead and the other
restricted materials in homogeneous material and that can provided all over
the world.
Without conformity test (given in the Directive itself) - no CE-marking. 
How it will be with the EuP Directive, is not foreseeable. But EuP will give
only a framework for other Directives with the harmonisation approach. So
the difficulties move to a later time. Possible, that in some more years the
RoHS will be moved into this framework, if we have enough experience and
know, how to measure or describe the safety for the environment and provide
conformity assessments.
Until this time we need the Diamond or something in this manner.

Irina Stobbe

European EFSOT Project 
http://www.efsot-europe.info
IMS Project EFSOT
http://efsot.info 
*******************************************************************
BeCAP - Berlin Center of Advanced Packages
    a cooperation between
Technische Universität Berlin
    Fak. IV Elektrotechnik/Informatik,
    Forschungsschwerpunkt Technologien der Mikroperipherik and
Fraunhofer Institut
    für Zuverlässigkeit und Mikrointegration (IZM)

Dr. Irina Stobbe
    c/o Fraunhofer IZM
    Dep. Environmental Engineering
    Gustav-Meyer-Allee 25, Gebäude 17
    D-13355 Berlin

Access:S1,S2 - Humboldthain, U8 - Voltastraße
Tel:   +49 (30) 46403-156,  -130, Fax: +49 (30) 46403-131
mailto:[log in to unmask], [log in to unmask]
www:   http://mst.tu-berlin.de  , http://www.izm.fraunhofer.de/ee/
*******************************************************************




-----Ursprüngliche Nachricht-----
Von: Leadfree [mailto:[log in to unmask]] Im Auftrag von Kallin, Dan
Gesendet: Freitag, 28. Januar 2005 16:36
An: [log in to unmask]
Betreff: Re: [LF] RoHS Labelling again!

My understanding is that compliance to the next big gorilla, the EUP is
demonstrated thought the CE mark.

http://europa.eu.int/comm/enterprise/eco_design/index.htm

Dan

-----Original Message-----

From: Leadfree [mailto:[log in to unmask]]On Behalf Of Kay Nimmo
Sent: Friday, January 28, 2005 8:38 AM
To: [log in to unmask]
Subject: Re: [LF] RoHS Labelling again!


Hi paul

That would have been good, and it was considred, but it is not possible for
some legal reason that I cant remember.

Kay

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of to Paul Taylor
Sent: 28 January 2005 13:34
To: [log in to unmask]
Subject: Re: [LF] RoHS Labelling again!







Thanks to everyone for their comments and information:

I have one idea that has stuck in my mind, but I don't know if it is to late
to implement it or whether its workable:

Why couldn't the RoHS be incorporated into the CE mark? We already have this
label and mark in use, and it covers a multitude of equipment with different
variances (i.e from medical, power supplies, telecom etc to plastic cups).
It covers the low voltage directive and also different EMC specifications
for different types of equipment.
The right to place the CE mark is audited and financed, therefore it is sort
of self policed, the CE mark is place on the final equipment (like where we
want to place the RoHS label). With the conversation around about haw will
we know if the supplier has been diligent in saying that his equipment is
RoHS complaint this would mean that when the manufacturer applies for the
right to place the CE mark, he would also have to show that he was RoHS
compliant.  This procedure is the same for UL as well.
using
the CE mark to include RoHS would also allow manufacturers to list
non-compliant levels by exemption (an example here would be cadmium in high
power switches which are exempt)

This solution would be a way out for the EU directive people as at the
offset of the directive, it should have been spelled out how the directive
was to be administered and policed, and one of the key points in that is
identification of compliant product!! In other words the same as CE

Is there anyone from the DTI still on the forum that could answer this?

Do other members think this is a good idea?

note:The WEEE  label is different as its not connected with manufacture more
with end of life and I believe that a separate label for this is the correct
way to move forward

regards

paul




Paul R Taylor
Senior Engineer, Product Supply Group
email: [log in to unmask]
website: www.pb.com




             Kay Nimmo
             <kay.nimmo@TINTEC
             HNOLOGY.COM>
To
             Sent by: Leadfree         [log in to unmask]
             <[log in to unmask]
cc
             >

Subject
                                       Re: [LF] RoHS Labelling again!
             26/01/2005 09:01


             Please respond to
                "(Leadfree
                Electronics
             Assembly Forum)"
             <[log in to unmask]
             >; Please respond
                    to
                 Kay Nimmo
             <kay.nimmo@TINTEC
               HNOLOGY.COM>






If you would like to know more about labelling then look at the documents on
our website;

www.lead-free.org /information/supply chain issues/marking and
labelling.....
or direct
http://www.tintechnology.biz/soldertec/soldertec.aspx?page_id=1637&Selec
tedMenu_ID=73

In particular, the January 2004 Soldertec Global European Pb-Free Marking
Survey and June 2004 paper and presentation on RoHS Marking - Lead-free
Components and Board Marking as Marking for Environmental Issues
(Electronics goes Green 2004). You may need to register (free) - I dont
know.

In fact it is the US standards bodies who are reluctant to agree on RoHS
marks proposed in Europe or Japan. If you can get them to change their mind
on the need for RoHS marking then that would be very helpful for everyone.
Kay


Soldertec-IPC Conference 'Towards Implementation of the RoHS Directive'
June 7-9, Barcelona, Spain
+++++ Visit our lead-free.org website +++++
Soldertec at Tin Technology Ltd, Unit 3, Curo Park Frogmore, St Albans, AL2
2DD, UK Direct dial: +44 (0)1727 871 312
Switchboard: +44 (0)1727 875 544
Fax: +44 (0)1727 871 341
[log in to unmask], http://www.lead-free.org
*****************************************************************



-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Shawn Vike (By way of
[log in to unmask])
Sent: 25 January 2005 22:54
To: [log in to unmask]
Subject: Re: [LF] RoHS Labelling again!


Paul,
It's nice to see that I am not the only dreamer. It only stands to reason
that we will eventually need some kind of labeling for RoHS compliance, and
a standard would be wonderful.
Maybe if people started to agree on a convention, like your "simple (light
)green "RoHS" in plain Arial text" suggestion, we could make it happen. I
would prefer to avoid specifying a color, as it is my intention to screen
this directly on the PCBs (when they are compliant) but the concept is good!
Shawn Vike
Operations Manager
Pathway Connectivity Inc.
[log in to unmask]

>> I know this subject has been banded about a couple of times, but i
was
>> interested in the direction some of you guys are going on this
subject.
>> The WEEE labelling appears to be sorted (crossed out wheelie bin
etc), and
>> so to is the PCB assembly identification (as supplied by Jedec), but
what
>> about RoHS?.

>> There appears to be no "general purpose label" for the RoHS
compliance on
>> the market, which I see as important, I think that the people who set
out
>> the WEEE label should have done a RoHS one as well at the same time,
its
>> not rocket science is it?.

>> The problem for many of you, like the company I'm working for, is
that
>> there is a long supply chain and multiple stores locations, we also
have
>> parts back in for refurbish and we out source both assembly work and
units
>> to sub-contractors and OEMs alike and we assemble in house as well,
in
>> general we have parts every where. We have many assemblies that are 
>> either "RoHS compliant" or will be either coming in "RoHS compliant" 
>> over
the
>> next
>> 17 months. We wish to label these as compliant so that we can ensure
that
>> our stocks have been properly stock turned and also to maintain 
>> traceability. Obviously we don't want to label every nut and bolt,
but we
>> do want to label the 'higher level assemblies' that are compliant,
and
>> also
>> importantly identify the outside of our units, as basically after 
>> conversion there would be no visible differences.

>> If other companies are labelling their units, what symbol is being
used?
>> As
>> one problem for our goods inwards is identifying the 'RoHS
compliancy'
>> label for every supplier!!

>> My suggestion would the a simple (light )green "RoHS" in plain Arial
text,
>> maybe the directive number in small print underneath, does any one
else
>> have any ideas.

>> regards

>> Paul


>> PS Perhaps I should patent my label!!!!!

>> Paul R Taylor
>> Senior Engineer, Product Supply Group Pitney Bowes Ltd
>> email: [log in to unmask]
>> website: www.pb.com
>>
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