This another one of the EEC SnAfUs in failing to have consistency
through all similar directives. In contrast the End of Life Vehicle
Directive clearly states:
- 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),
Where footnote 1 says:
(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.
This as everyone clearly points out is not in RoHS although I believe
many feel that to meet the spirit of the directive one should apply it
and possibly any ruling may take this line also (IMO). No doubt in some
future amendment the two directives will be brought in line, and I know
where I'd place my bet.
Do what you want but don't cry later.............
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jerome Wagner
Sent: 30 September 2005 17:10
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]
"MacFadden, Todd"
<Todd_MacFadden@B To:
[log in to unmask]
OSE.COM> cc:
Sent by: Leadfree Subject: Re: [LF] Lead:
Intentionally added but below 1000 ppm?
<[log in to unmask]
>
09/30/2005 07:52
AM
Please respond to
"(Leadfree
Electronics
Assembly Forum)";
Please respond to
"MacFadden, Todd"
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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