There is nothing under RoHS which makes it a requirement to know the
exact ppm of RoHS regulated substances in any components, or any other
regulated hazardous substance. To be qualified as RoHS compliant you
just need them to be constructed of "homogenous materials" which are
below the limits for the regulated substances. There may be other non-EU
legislation which will go this way in the future, but due diligence in
keeping data to show each and every one of your components and processes
used in the construction of a product placed on the market in the EU is
qualified as RoHS compliant is all that is required currently.
There is a third party defence at least in the UK that says that if you
used non-RoHS compliant components or substances which your supplier had
claimed and documented as compliant, then they are at fault not you -
however it does not say whether you might still have to withdraw your
products from the market if they are found to be non-compliant because
of this.
The "homogenous material" definition has not been published in the
official journal yet as far as I am aware, but its pretty safe to assume
this is what we have to work with.
Nigel Burtt
Production Engineering Manager
Dolby Labs Inc - European HQ
Email: [log in to unmask]
Tel: +44 (0)1793 842132 [direct line with voicemail]
Fax: +44 (0)1793 842101
-----Original Message-----
From: MA/NY DDave [mailto:[log in to unmask]]
Sent: 19 May 2005 04:30
Subject: Re: Data gathering and maintenance requirement for RoHS
compliance
Hi Blair, IPC LF Listservers,
Let me take a stab at your note, and hopefully others might add.
<Avnet will supply the materials content in ppm for each of the RoHS
substances, along with other component data such as weight. > <I'm
wondering if I really need this information.>
Yes, You will need this information someplace in your files.
<The directive covers "homogenous materials" as needing to be compliant
and the accepted interpretation is that everything down to the plating
on the leads of a resistor must be compliant. I don't see where the
breakdown in ppm per part and weight are important. If I was taking the
approach that my product weighed 25kg, I could have 25g of lead and be
at the 100 ppm level, however, with the homogenous materials approach
this doesn't matter. >
The last I knew "homogenous" (which I can't stand as a technical term)
is almost, or maybe is, in one of the follow on directive EU documents.
So yes you should be concerned. By the Way, if you find the exact
release date in the OJ (Official Journal) please let me or us know.
<So what I am looking for is a statement from the supplier or
manufacturer that the part is RoHS compliant in itself. If all of the
parts I use are compliant, and my processes are compliant, then the
assembly is compliant by default. >
Well Yes, yet if you are a prime "brand name" or other manufacturer or
supplier into the EU you have to, or should I say should, get down to
the detail level of ppm. (More yet that is the short of it)
<Do I need the materials content data for anything? I have heard that
some customers are asking for this, as opposed to simply asking for a
statement of compliance. >
Yes, If asked by an appropriate EU group, etc, you should be able to
present your compliance in detail terms.
Yours in Engineering, Dave
YiEngr, MA/NY DDave
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