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September 2009

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From:
Bob Landman <[log in to unmask]>
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Date:
Thu, 17 Sep 2009 21:20:36 -0400
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Denny,

Yes, this was from Gary Nevison at EDN http://www.edn.com/blog/570000257/post/1930048993.html?nid=3614 (I meant to include the link)

Here are several more links to articles which confirm that some significant changes are in the works.

http://www.semi.org/cms/groups/public/documents/web_content/ctr_028917.pdf

http://www.tanzco.net/html/rohs_2.html (this is a very good article on the hazzards of RoHS "2")

Note that the proposal includes making RoHS a CE marking directive.

http://www.pb-free.info/cat8.htm

Lets not  throw the baby out with the bath water, lets drown the kid!

Bob Landman
H&L Instruments, LLC


  _____  

From: [log in to unmask]
To: [log in to unmask], [log in to unmask]
Sent: Thu, 17 Sep 2009 19:02:19 -0400
Subject: Re: [LF] New ROHS proposals seek to change scope to encompass all electrical and electronic equipment unless specifically excluded

  
Bob, the only thing I would add is that the information below is from Gary Nevison of Newark/Farnell, as a column or a commentary.  I have been nervous of Newark/Farnell since 2006 since they were the first I knew of to propose a US style RoHS to keep states from enacting their own patchwork of regulations.  (that has now happened with NEMA pushing for HR 2420 introduction in the US House.        
       
I am not disagreeing, just waiting for other interpretations.   Other recent EU notes have said maybe the EU parliatment elections made that body a bit more conservative leaning.  Bad news - the green party elected to the EU parliament is concentrating on running environemntal matters. Then again, there is the EU Commission noted here - and can someone on this forum explain how the Commission is appointed and who they report to, if not the EU Parliament      
       
Denny Fritz      
       
       
Gary Nevison, director of legislation and environmental affairs at Newark and Farnell, contributes his views on the electronics supply chain and environmental compliance's most critical topics -- ROHS (all variations around the world), REACH, EUP, WEEE directives, and on whatever else comes up in this ever evolving business channel.        

  
  
  -----Original Message-----
  From: Bob Landman <[log in to unmask]>
  To: [log in to unmask]
  Sent: Thu, Sep 17, 2009 4:53 pm
  Subject: [LF] New ROHS proposals seek to change scope to encompass all electrical and electronic equipment unless specifically excluded
  
        


New ROHS proposals seek to change scope  Sep 17 2009 8:50AM | Permalink |Comments (0) |        Following discussions between EU Member States and the Council of Ministers, new   proposals have been put forward by Sweden, which currently owns the EU   presidency, to amend the scope of the ROHS (Restriction of Hazardous Substances)   directive.  Under the proposals the scope will change to encompass all electrical and   electronic equipment unless specifically excluded. Currently there are eight   product categories with binding examples of what products fall within scope. A   recast, published in December 2008, also proposed the phased in addition of   categories 8 and 9 (medical devices and monitoring and control instruments).  Under the new proposals all electrical and electronic equipment (EEE) will fall   within scope, unless specifically excluded. Annex I (the 10 broad product   categories) and Annex II (binding list of product examples) have been deleted   from the text of the ROHS recast and=2  0will now sit, as before, within the WEEE   (Waste Electrical and-Electronic Equipment) directive, although Annex II is   referred to as indicative as opposed to a binding list.  There are new exclusions from the ROHS text such as large-scale stationary   industrial tools (LSIT), but the impact of the revised proposals is clearly to   include products that are not currently in scope.  It is also proposed to delete Annex III that lists four substances - BBP, DBP,   DEHP, and HBCDD for priority assessment, leading to possible restrictions.  However, the Commission intends to adopt a methodology for the review of the   restricted substances in Annex IV (the original six possible, but unlikely) and   new substances where deemed necessary in the future, based on the process set   out in Articles 69 to 72 of the REACH (Registration, Evaluation and   Authorization of Chemicals) regulations.  This would look to review a substance used in EEE, or the waste derived from it,   that poses a hazard to human health or the environment that is not adequately   controlled.  However, industry will be interested in the scope, where any product that relies   on electricity to function could be included, as well as the status of some of   the grey area products. No longer will there be the “is it in scope or is it   out” issues as with, for example, semiconductor development tools at present, as   everything will be within scope unless specifically excluded.  ROHS was previously   unclear, especially for fixed installations, and it is   probable that these proposals are an attempt to resolve this. However,   “equipment that is part of equipment that is out of scope is itself out of   scope” remains in the text so uncertainty is likely to continue.    Bob Landman  H&L Instruments, LLC    www.hlinstruments.com/          

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