Chris,
It's 200K units in total put on the market, not per mfr. So even mfrs with
small volumes in high volume product markets targeted by EuP will have to
comply.
Problem is, there's nothing to comply with...there are no "implementing
measures" yet. That's where the rubber meets the road. Industry has to
convince the EU that it can accomplish this voluntarily to avoid them,
according to the directive (yet they're pressing ahead with some). Don't
expect Industry to do so or be successful. Once the implementing measures
are in place (next year?) expect a few years before they're in force to comply.
The impact of EuP can not be understated. What we went through with RoHS, at
least in terms of getting attribute data nobody had ever asked for to flow
down the supply chain, will be similar with both REACH and EuP. EuP requires
that energy attributes for potentially all materials (which indirectly could
drive material selection) will be required. REACH requires detailed
substance and application attributes to be shared up and down the supply
chain (there are serious IP and confidentiality issues here).
The electronics industry, IMHO, and our supply chain is poorly prepared.
So this brings me to yet another advertisement:
The US National Institute of Standards and Technology (NIST) is holding a
workship in late September entitled "Innovation and Competitiveness: A
Strategic Approach to Emerging Chemical Issues". Read more about it at
http://www.cstl.nist.gov/confs/emergingchemforum/index.htm
Yours Truly is presenting on what the electronics industry has gone through;
you'll hear what other industries (automotive, construction, etc.) have gone
through. We're not the only ones subject to the whims of the Environment
DG... I would enjoy meeting some of you there since the point of this
workshop is to discuss and brainstorm just how we get ahead of this, or at
least how to work more closely with these governments to implement more
sensible, and effective, product-focused environmental laws. Because we
ain't gonna stop it from happening. As Cowboy Neal Cassidy said, "you're
either on the bus or off the bus".
As I have said elsewhere, REACH could have a minimal effect on the
electronics industry (more PCNs and slightly lower reliability) or it could
have a dramatic effect. The industry has, to my knowledge, failed to perform
a comprehensive or even moderately so risk analysis and understand the
potential exposure. For instance, Bisphenol A could be restricted...suddenly
we have to find a new mold compound for "plastic" electronic components.
That could be as subtle and significant as replacing lead-based solder.
Mike Kirschner
On Wed, 30 Aug 2006 17:36:25 +0100, James, Chris <[log in to unmask]> wrote:
>Has
>Date is 11 Aug 2007 so even less time to comply John!
Has anyone had clarification on Art 15 2(a):
(a) the EuP shall represent a significant volume of sales and
trade, indicatively more than 200 000 units a year within
the Community according to most recently available
figures;
Does this mean 200k units per mfr or just 200k units from all mfrs?
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: 30 August 2006 17:07
To: [log in to unmask]
Subject: Re: [LF] REACH
Not really, it WILL impact the raw chemicals supply industry, but will
not
have the impact on the electronics manufacturing sector that lead in
solders
had.
You might want to be more concerned about the EuP laws which will have a
far
reaching impact and which have been passed as law already, they cut in
on
August 17th 2007.
John
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Paul Jackson
Sent: Wednesday, August 30, 2006 12:50 AM
To: [log in to unmask]
Subject: [LF] REACH
Is REACH going to be like RoHS... what does it mean for the industry as
a
whole....?
http://www.netregs.gov.uk/netregs/legislation/380525/1285481/?lang=_e
Paul Jackson
Hotline Purchasing Manager
Black Box Network Services
Tel: 0118 965 5225
Fax: 0118 9751 565
E-Mail: Paul <mailto:[log in to unmask]>
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Web: www.blackbox.co.uk
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