I agree with Bev that intent has no bearing in RoHS.
However, automotive suppliers must contend with the ELV which contains
the intentionally added caveat.
----------------------------
a maximum concentration value up to 0,1 % by weight and per homogeneous
material, for lead, hexavalent chromium and mercury and up to 0,01 % by
weight per homogeneous material for cadmium shall be tolerated, provided
these substances are not intentionally introduced(1),
- a maximum concentration value up to 0,4 % by weight of lead in
aluminium shall also be tolerated provided it is not intentionally
introduced(2),
- a maximum concentration value up to 0,4 % by weight of lead in copper
intended for friction materials in brake linings shall be tolerated
until 1 July 2007 provided it is not intentionally introduced(3),
(1) "Intentionally introduced" shall mean "deliberately utilised in the
formulation of a material or component where its continued presence is
desired in the final product to provide a specific characteristic,
appearance or quality". The use of recycled materials as feedstock for
the manufacture of new products, where some portion of the recycled
materials may contain amounts of regulated metals, is not to be
considered as intentionally introduced.
-------------------------------
I happen to know that that Todd's employer supplies to Automotive
customers and must comply with ELV as well as RoHS.
If they are applying a single set of standards to their suppliers, they
must determine intent when material is present at ANY level.
In summary,
If one atom of Cr VI is intentionally added " where its continued
presence is desired in the final product to provide a specific
characteristic, appearance or quality" it cannot be used for an
automotive part but could be used on EEE up to the threshold level.
That is my interpretation anyway, which, with a couple of bucks might
buy you a cup of coffee. (or at least something to think about while
enjoying it!)
Dan Kallin
Program Director
EH&S Management, Consulting and Compliance
Earth Tech, Inc.
196 Baker Avenue
Concord, Massachusetts 01742-2167
Phone: 978.371.4155 Fax: 978.371.2468
Mobile: 978.760.0779
[log in to unmask]
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jerome Wagner
Sent: Friday, September 30, 2005 12:10 PM
To: [log in to unmask]
Subject: [LF] Lead: Intentionally added but below 1000 ppm?
I understand - and could endorse - Todd's perspective. On the other
hand, I
think that we can use the "black-and-white" wording which is presently
before us in RoHS directive and MCV decision and conclude that there is
no
explicit prohibition, at this time, on intentional content...
jw
!! God Blesses !!
Jerry Wagner Dept 0056 Environmental Engineering B096-1
x56275 pg 58888-0658 (607)755-6275 fax: (607)755-6282
Huron Real Estate Associates, LLC and Endicott Interconnect
Technologies,
Inc.
Via the Internet: [log in to unmask] [NOTES: Jerome
Wagner/Huron/EIT]
Hi Ken,
We have heard this as well from several of our suppliers who have
claimed to be below the thresholds with intentionally added materials
and we simply will not accept this as a valid compliance approach. While
the Directive does not specifically use the words "intentionally added,"
the intent of RoHS to ensure EEE products do not contain the 6
restricted substances is abundantly clear. The MCV thresholds are simply
an acknowledgement of the inevitable, unavoidable presence of
impurities. This is precisely the reason for defining the thresholds at
the homogeneous level rather than at the component or assembly level,
for instance, because I have yet to see an intentional use that would
pass this definition.
Remember, too, that the burden of proof is on the producer, not the
supplier. In at least one case where a supplier of ours sought our
approval for intentional use of Cr+6 where they claimed to be below the
threshold, we found that they tested incorrectly. When properly measured
at the homogeneous level, they were an order of magnitude over the
threshold. We don't want to conduct that level of scrutiny throughout
our supply chain.
We believe that intentionally adding non-exempted substances is a
misinterpretation or a nuancing of the Directive that could be risky.
We're not going there.
Todd
-------------------------------
Todd MacFadden
Component Engineer
Bose Corporation
508.766.6259
-------------------------------
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kanaiyalal Patel
Sent: Thursday, September 29, 2005 8:32 PM
To: [log in to unmask]
Subject: [LF] Lead: Intentionally added but below 1000 ppm?
All,
What is your take - if my supplier is saying the lead content is well
below 1000 ppm threshold but it was intentionally added? Will it be
considered RoHS compliant or non-compliant?
Any clarification will be highly appreciated.
Re,
Ken Patel
---
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