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Subject:
From:
Werner Engelmaier <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Wed, 17 Mar 2010 06:43:00 -0400
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text/plain (390 lines)
 Hi James,
Did the EU think in those terms—NO. And while a lot of products get imported, they are imported because they were outsourced by American companies.A doubt that the 'logistics' is much different than when RoHs first got started.
And if we do not play ball, with this 'Sn-risk' mandate, it would collapse once the USA points out that the 'Pb-free' king does not wear any clothes.
Werner

 


 

 

-----Original Message-----
From: James, Chris <[log in to unmask]>
To: [log in to unmask]
Sent: Wed, Mar 17, 2010 5:37 am
Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like standards for imported products?


Werner - as Bob pointed out in his last paragraph, the US could not do
that and I'm sure the US public would not care to be denied the range of
products the US imports. Think about the logistics before you
reply..........

C


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Werner Engelmaier
Sent: 17 March 2010 02:02
To: [log in to unmask]
Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like
standards for imported products?

 Hi Bob,
While not all of RoHS is bad, your points are well taken.
So lets concentrate on the real bad part-the Pb ban.
We should actually turn the argument around. Since it now is clear, that
all the substitutes for SnPb are environmentally more damaging-less
sustainability, more energy use, worse in land fills, more scrap to go
into land fills, lower reliability, tin whiskers, ravaging tin mining,
etc. etc., the USA should ban electronic imports that contain Pb-free
solders [unless their use can be explicitly justified] on those grounds.
That would put USA products on a higher plane than those problematic
Pb-free electronic products with the arguments of more environmentally
products that are also more reliable.
Werner

 


 

 

-----Original Message-----
From: Bob Landman <[log in to unmask]>
To: [log in to unmask]
Sent: Tue, Mar 16, 2010 11:48 am
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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