If it were not for the Brits in 1759 though you'd all be speaking French
now and part of the EU anyway.
C
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of [log in to unmask]
Sent: 17 March 2010 14:46
To: [log in to unmask]
Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like
standards for impor
That's the spirit, Werner... the spirit of 1776 No legislation without
representation (by science) We can dump the lead-free products in Boston
Harbor at night... I take that back, the silver in the PB free solder
will not
be good for the fish larva...
Cheers,
Joe
In a message dated 3/16/2010 7:13:32 P.M. Pacific Daylight Time,
[log in to unmask] writes:
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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