Joe,

I read it several time myself and thought it very odd but as it was their most recent statement it needed to get seen by folks here.
I've sent it to a person on the NEMA board of directors who to get them to clarify the message.

Bob 

-----Original Message-----
From: Kane, Joseph E (US SSA) [mailto:[log in to unmask]] 
Sent: Tuesday, March 16, 2010 12:09 PM
To: Bob Landman; [log in to unmask]
Subject: RE: [LF] The Brainstorm: Should the U.S. employ RoHS-like standards for imported products?

Bob:

I couldn't find a coherent set of opinions here, so I checked the link.
It seems like this "brainstorm" presents differing opinions from
5 different "industry leaders", though even that's not clear, and the leaders aren't identified.

-Joe 

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bob Landman
Sent: Tuesday, March 16, 2010 11:49 AM
To: [log in to unmask]
Subject: [LF] The Brainstorm: Should the U.S. employ RoHS-like standards for imported products?

This is a response to those opposing the House bill in the Congress on exemptions for lead in NEMA products.  IPC is against the bill as is AIA.

Bob Landman
H&L Instruments, LLC

http://www.nema.org/media/eiextra/20081020b.cfm

Should the U.S. employ RoHS-like standards for imported products?

Regulatory officials in the U.S. would have a hard time justifying RoHS-like thresholds for imported products only because a standard that applies just to foreign-made products would constitute a serious barrier to trade for overseas manufacturers. Furthermore, it would imply that products manufactured in the U.S. are held to a lower standard of "safety" than imported products. This is not the kind of message consumers expect to hear from our government.

On the other hand, it's clear now that the European RoHS thresholds are becoming a de facto global standard, influencing markets far beyond the EU. If the U.S. does not address this trend, it could find itself a "dumping ground" for products that can no longer be sold elsewhere as more and more countries adopt a RoHS approach. From this standpoint, standards on imported products could serve to protect consumers while simultaneously encouraging domestic manufacturers to develop "greener" products as a means to compete.

So what's the solution? At NEMA, which represents the electrical product industry in the U.S., we believe that if a product standard can be justified on the basis of science, safety, and product performance, it should be applicable to a product regardless of where it is manufactured - imported or domestic. We also recognize the impact of RoHS-type rules on the worldwide regulatory arena and believe manufacturers should stay ahead of the trend, employing their expertise in product design and development to control events as much as possible.

For these reasons, NEMA is striving to introduce Federal legislation that would establish hazardous substance thresholds for many electrical products sold in the U.S., effective July 2010. When enacted, this legislation would apply to all participants in the market and would preempt states from enacting different standards. This will ensure a level, consistent playing field without compromising safety or performance.

The U.S. should definitely employ RoHS-like standards for imported products. The world, and particularly the United States, is now making a valiant push to go Green. Eliminating hazardous materials from products in our homes, workplace, and the landfill is vital to this effort.

The U.S. is still the largest consumer in the world. If we demand higher standards, it will help raise the bar for manufacturers around the world who depend on our business. If we do nothing, it undermines those who are trying to make a difference and improve our lives and our planet.

AOS is a Swiss company, and we have experience with RoHS. For us it applies to electronic products in the European Union (EU) whether made within the EU or imported. AOS manufactures in Switzerland and draws from worldwide resources. Adopting RoHS created a lot of challenges for our company and many other electronic manufacturers in the European Union.

Modifying components and retooling was not an easy process, challenging our quality and process management to avoid unacceptable delays while maintaining the same product quality and reliability. Changing entailed a great deal of negotiation, planning and additional cost. It is not a trivial thing.

AOS's U.S. office is located in California, a state which passed SB 20: Electronic Waste Recycling Act of 2003. This act follows many of the EU RoHS standards for electronic products being sold in California, but across a much narrower scope. It only is a start and the nation should follow suit.

Arguments can be made for or against it. In fact, within DCA the best we could do is reach consensus that it would be relatively straightforward, low cost, and harmless to implement (and not just for imported product, but for domestic as well; if implemented for imported product only it would be readily shot down as a trade barrier).

Implementing RoHS in the U.S. would be relatively easy because the supply chain infrastructure is in place for it and most products (in terms of volume) are already RoHS-compliant. Companies (particularly those with products in high volume and consumer markets) build one product for the world, and any localization is based on software and maybe a power cord.

However, the fact is that RoHS is a point chemical regulation - it addresses only a few chemicals in a narrow range of applications. Implementing it here would still leave us several steps behind the EU's leadership in environmental policy - they have a "federal" WEEE (Waste Electrical and Electronic Equipment) policy, a product energy policy (EuP - Energy-using Products), and a new overall chemicals policy (REACH - Registration, Evaluation, Authorization, and Restriction of Chemicals).

The U.S. federal government therefore has a long way to go in order to just put itself in a position to harmonize with environmental regulations and policies in the EU and other parts of the world, much less eventually regain its leadership role in environmental policy. Implementing RoHS in the U.S. might put us on the path, but it is far from the endgame.

The health risks and recycling difficulties associated with the materials covered by RoHS are well known, but the product life-cycle impact from the use of alternative manufacturing materials like lead-free solder is just starting to be understood.

Although some manufactures, like Motorola, have been successfully using lead-free solder since 2001, others have had serious difficulties. In 2006, Swatch watches experienced a nearly 5 percent failure rate due to the development of "tin whiskers" (small thread-like strands that can sprout from lead-free solder and cause short circuits) on circuit boards forcing a nearly $1billion dollar re-call.

Creating reliability and product life-cycle issues will affect safety, consumer satisfaction and ultimately increase the amounts of waste generated. This is why long-lived, mission critical equipment like medical devices and monitoring and control systems are currently exempt from RoHS compliance.

Practically speaking, the fact that California passed the Electronic Waste Recycling Act in 2003 means we have already adopted these standards - very few foreign companies can afford to sell into the U.S. and not sell in California.

As a nation though, we should wait and watch a couple more years of data from RoHS compliance overseas. Once the real effect and the potential engineering workarounds are better understood we can more rationally assess the benefits.

So RoHS-like compliance will come, but let's not be in such a hurry to make recycling easier that we create more garbage in the process.

The answer is "No," unless it is the same as the RoHS-Directive (2002/95/EC) in letter and intent. Europe's RoHS directive, published in February 2003 and implemented in July 2006, led to a tsunami of products produced in the global electronics and electrical market, to be distributed across the USA. Destined to regulate consumer electronics and electrical products and, more importantly, exempt industrial, medical, aerospace and national defense systems; it has unfortunately swallowed everything in its wake.

U.S. manufacturers now produce many (but not all) RoHS-compliant products for the global market. Why should we develop our own version, when the European Community has already influenced the global market in this regard?

Visit any consumer-electronics, office supply store or Wal-Mart, and you will see a number of electronic and electrical products that carry the WEEE Wheelie Bin and some form of a RoHS symbol. Like it or not, legislation in the USA will not change the fact that many RoHS-compliant components, assemblies and products are already in circulation here.

Some naysayers and alarmists in the industry warn against the potential for failure of RoHS-compliant products with their lead-free make-up and increased tin-whisker risks. There are those who would have us support a motion to reduce the potential risks and allow for a better technical assessment of a RoHS-compliant U.S. Their response would be to support a BAN on RoHS-compliant products entering the U.S.

As a member of the G8 and WTO, however, we cannot introduce a potential trade barrier on imported products and simultaneously protect U.S.-manufactured products. The RoHS-Directive is an emotionally charged topic in certain quarters, but so far no serious problems have become evident in the U.S. consumer electronics market.

=============================
 
Bob Landman
H&L Instruments, LLC



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