You know its funny......I was thinking about the same exact scenario while drafting a response to mike's e-mail and included it in a list of questions to ask for a seminar I am attending next week on material declarations.
Amol Kane
M.S (Industrial Eng.)
Process Engineer
Harvard Custom Manufacturing, Inc.
941 Route 38 Owego, NY 13827
Phone: (607) 687-7669 x349
[log in to unmask]
www.harvardgrp.com
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bender, David R
Sent: Wednesday, July 19, 2006 9:10 AM
To: [log in to unmask]
Subject: Re: [LF] [TN] RoHS 5 and RoHS 6
Would like to add one comment to the previous note from Mike regarding
RoHS 5 or 5/6 Compliance.
While I agree with his concerns, this exemption "lead in solder for
servers, etc" is not quite the same as other "material" exemptions. For
example, as a component supplier I don't think is reasonable to say my
component is RoHS compliant using an exemption for lead in solder as the
component is not an end item (server)that is covered by the exemption
and in fact the component may be used in applications (e.g a desktop
computer) where that exemption is not allowed. So for a component
supplier, or purchaser of components, the RoHS 5 designation is very
useful.
The RoHS 5 definition that TE uses is that "component is RoHS compliant
except that it contains lead only in the solderable interface. This
component may be used in applications that qualify for the lead in
solder exemption." 5/6 compliance is handled more or less like this in
the IPC 1752 form as well where there is a separate designation for 5/6
compliant parts although term is not used directly - IPC 1752 says
"Item(s) does not contain RoHS restricted substances except lead in
solder and any other selected exemptions".
Dave Bender
Director - RoHS Program Mgmt.
TYCO Electronics
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner
Sent: Wednesday, July 19, 2006 1:04 AM
To: [log in to unmask]
Subject: Re: [LF] [TN] RoHS 5 and RoHS 6
Folks,
Let me be abundantly clear: there is NO SUCH THING as "RoHS 5". I
recommend
that you drop it from your lexicon and never speak of it again. ;o)
Your products, if they are within the scope of RoHS (EU), must comply
with
the maximum concentration values in homogeneous materials for all six
classes of restricted substances, taking in to account applicable
exemptions.
One of these exemptions is for "lead in solder for servers, storage and
storage array systems", and "network infrastructure equipment for
switching,
signalling, transmission as well as network management for
telecommunication". Read the Annex, paragraph 7, lines 2 and 3 and you
will
see this exemption.
When people speak (sometimes lovingly ;o) of "RoHS 5", they are
referring to
this specific exemption. It ONLY exempts lead used in solder; for
instance,
on PCB-mounted components, the PCB itself, and the solder used to join
them,
or wires to connectors. OTHER USES OF LEAD WHICH ARE NOT EXPLICITLY
EXEMPTED
BY THIS OR OTHER GRANTED EXEMPTIONS ARE NOT EXEMPT! Thus your products
may
not, for instance, contain lead in plastics (commonly used in flat
cables,
etc.). And you'd better check for this if you haven't yet...
So "RoHS 5" is a shorthand misnomer. It is misleading; one admittedly
very
significant exemption for lead does not exempt ALL uses of lead in
electronics. If you cannot tell yet, I really dislike this term because
it
is dangerously imprecise.
Also, Mr. Kane's statement below that you have to state anything is a
bit
misleading. To restate Chris' comments a bit differently, this is a
"self
declaration" process. You don't have to "state" anything; you don't have
to
"declare" anything; you don't need a mark of any kind anywhere including
a
"CE" mark in order to comply with EU RoHS. You simply have to explain,
when
asked by an enforcement authority or maybe a customer, why your products
are
the way they are (in scope/out of scope/able to take xyz
exemption/etc.)...
convincingly... with data...
Mike Kirschner
President
Design Chain Associates, LLC
www.DesignChainAssociates.com
www.ChinaRoHS.com
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: Tuesday, July 18, 2006 7:02 AM
Subject: Re: [TN] RoHS 5 and RoHS 6
RoHS 5 is a termed coined by industry. It is not in the legislation.
RoHS 5 is understood to mean you are claiming an exemption which permits
the continued use of lead. There is no provision you need to declare you
have used an exemption. However you would need to declare such on any d
of c you might be asked for and you are best advised to internally
document your decision for claiming the exemption for when the rohs
police with their xrf guns come a knocking...........
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kane, Amol (349)
Sent: 18 July 2006 14:34
To: [log in to unmask]
Subject: Re: [LF] [TN] RoHS 5 and RoHS 6
Hi Joel,
The EU legislation limits the use of 6 hazardous chemicals (Lead,
Cadmium, Mercury, Hex Chromium, PBBs and PBDEs). RoHS 6 compliant means
that all these 6 substances are below the permissible level in the
assembly. RoHS 5 means that 5, out of the 6 substances are below the
permissible level, and the 6th substance is above the permissible level,
but is covered by a RoHS exemption (thereby making the assembly RoHS
compliant). Usually lead is above the permissible level in RoHS 5
assemblies as there are lead solder exemptions for specific
applications.
If your assembly is RoHS 6, you need not declare a class, but if its
RoHS 5, you must state that it is RoHS 5 and then state the exemption
class that is applied to the product.
Regards,
Amol Kane
M.S (Industrial Eng.)
Process Engineer
Harvard Custom Manufacturing, Inc.
941 Route 38 Owego, NY 13827
Phone: (607) 687-7669 x349
[log in to unmask]
www.harvardgrp.com
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Joel Alexander
Sent: Tuesday, July 18, 2006 9:07 AM
To: [log in to unmask]
Subject: [TN] RoHS 5 and RoHS 6
Can anyone explain these two classes of RoHS and do you have to claim a
class or just declare that you product is RoHS compliant
Joel Alexander
APSCO Quality Assurance Manager
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