OK - let's petition the IPC to change the name of this forum to "Tin-Risk" not Lead-Free.  

Use the term Tin-Risk wherever you find Lead-Free now!!!!

Denny Fritz. 


-----Original Message-----
From: Werner Engelmaier <[log in to unmask]>
To: [log in to unmask]
Sent: Tue, Mar 16, 2010 10:01 pm
Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like standards for imported products?


 Hi Bob,
hile not all of RoHS is bad, your points are well taken.
o lets concentrate on the real bad part—the Pb ban.
e should actually turn the argument around. Since it now is clear, that all the 
ubstitutes for SnPb are environmentally more damaging—less sustainability, more 
nergy use, worse in land fills, more scrap to go into land fills, lower 
eliability, tin whiskers, ravaging tin mining, etc. etc., the USA should ban 
lectronic imports that contain Pb-free solders [unless their use can be 
xplicitly justified] on those grounds. That would put USA products on a higher 
lane than those problematic Pb-free electronic products with the arguments of 
ore environmentally products that are also more reliable.
erner
 


 
-----Original Message-----
rom: Bob Landman <[log in to unmask]>
o: [log in to unmask]
ent: Tue, Mar 16, 2010 11:48 am
ubject: [LF] The Brainstorm: Should the U.S. employ RoHS-like standards for 
mported products?

his is a response to those opposing the House bill in the Congress on 
xemptions for lead in NEMA products.  IPC is against the bill as is AIA.
Bob Landman
&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 
hresholds for imported products only because a standard that applies just to 
oreign-made products would constitute a serious barrier to trade for overseas 
anufacturers. Furthermore, it would imply that products manufactured in the 
.S. are held to a lower standard of “safety” than imported products. This is 
ot 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. 
oes not address this trend, it could find itself a “dumping ground” for 
roducts 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 
o protect consumers while simultaneously encouraging domestic manufacturers to 
evelop “greener” products as a means to compete.
So what’s the solution? At NEMA, which represents the electrical product 
ndustry in the U.S., we believe that if a product standard can be justified on 
he basis of science, safety, and product performance, it should be applicable 
o a product regardless of where it is manufactured – imported or domestic. We 
lso recognize the impact of RoHS-type rules on the worldwide regulatory arena 
nd believe manufacturers should stay ahead of the trend, employing their 
xpertise in product design and development to control events as much as 
ossible.
For these reasons, NEMA is striving to introduce Federal legislation that would 
stablish hazardous substance thresholds for many electrical products sold in 
he U.S., effective July 2010. When enacted, this legislation would apply to all 
participants in the market and would preempt states from enacting different 
tandards. This will ensure a level, consistent playing field without 
ompromising 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 
reen. Eliminating hazardous materials from products in our homes, workplace, 
nd the landfill is vital to this effort.
The U.S. is still the largest consumer in the world. If we demand higher 
tandards, it will help raise the bar for manufacturers around the world who 
epend on our business. If we do nothing, it undermines those who are trying to 
ake 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 
lectronic products in the European Union (EU) whether made within the EU or 
mported. AOS manufactures in Switzerland and draws from worldwide resources. 
dopting RoHS created a lot of challenges for our company and many other 
lectronic manufacturers in the European Union.
Modifying components and retooling was not an easy process, challenging our 
uality and process management to avoid unacceptable delays while maintaining 
he same product quality and reliability. Changing entailed a great deal of 
egotiation, 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: 
lectronic Waste Recycling Act of 2003. This act follows many of the EU RoHS 
tandards for electronic products being sold in California, but across a much 
arrower 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 
o 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 
ell; if implemented for imported product only it would be readily shot down as 
 trade barrier).
Implementing RoHS in the U.S. would be relatively easy because the supply chain 
nfrastructure is in place for it and most products (in terms of volume) are 
lready RoHS-compliant. Companies (particularly those with products in high 
olume and consumer markets) build one product for the world, and any 
ocalization is based on software and maybe a power cord.
However, the fact is that RoHS is a point chemical regulation — it addresses 
nly a few chemicals in a narrow range of applications. Implementing it here 
ould still leave us several steps behind the EU's leadership in environmental 
olicy — they have a "federal" WEEE (Waste Electrical and Electronic Equipment) 
olicy, a product energy policy (EuP - Energy-using Products), and a new overall 
chemicals policy (REACH - Registration, Evaluation, Authorization, and 
estriction of Chemicals).
The U.S. federal government therefore has a long way to go in order to just put 
tself 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 
ole in environmental policy. Implementing RoHS in the U.S. might put us on the 
ath, but it is far from the endgame.
The health risks and recycling difficulties associated with the materials 
overed by RoHS are well known, but the product life-cycle impact from the use 
f alternative manufacturing materials like lead-free solder is just starting to 
be understood.
Although some manufactures, like Motorola, have been successfully using 
ead-free solder since 2001, others have had serious difficulties. In 2006, 
watch watches experienced a nearly 5 percent failure rate due to the 
evelopment of “tin whiskers” (small thread-like strands that can sprout from 
ead-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 
atisfaction and ultimately increase the amounts of waste generated. This is why 
long-lived, mission critical equipment like medical devices and monitoring and 
ontrol systems are currently exempt from RoHS compliance.
Practically speaking, the fact that California passed the Electronic Waste 
ecycling Act in 2003 means we have already adopted these standards - very few 
oreign 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 
oHS compliance overseas. Once the real effect and the potential engineering 
orkarounds 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 
ecycling 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 
etter and intent. Europe’s RoHS directive, published in February 2003 and 
mplemented in July 2006, led to a tsunami of products produced in the global 
lectronics and electrical market, to be distributed across the USA. Destined to 
regulate consumer electronics and electrical products and, more importantly, 
xempt industrial, medical, aerospace and national defense systems; it has 
nfortunately swallowed everything in its wake.
U.S. manufacturers now produce many (but not all) RoHS-compliant products for 
he global market. Why should we develop our own version, when the European 
ommunity has already influenced the global market in this regard?
Visit any consumer-electronics, office supply store or Wal-Mart, and you will 
ee a number of electronic and electrical products that carry the WEEE Wheelie 
in and some form of a RoHS symbol. Like it or not, legislation in the USA will 
ot 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 
ailure of RoHS-compliant products with their lead-free make-up and increased 
in-whisker risks. There are those who would have us support a motion to reduce 
he potential risks and allow for a better technical assessment of a 
oHS-compliant U.S. Their response would be to support a BAN on RoHS-compliant 
roducts entering the U.S.
As a member of the G8 and WTO, however, we cannot introduce a potential trade 
arrier on imported products and simultaneously protect U.S.-manufactured 
roducts. The RoHS-Directive is an emotionally charged topic in certain 
uarters, but so far no serious problems have become evident in the U.S. 
onsumer electronics market.
=============================

ob Landman
&L Instruments, LLC

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