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March 2010

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Subject:
From:
"James, Chris" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Thu, 18 Mar 2010 15:43:28 +0000
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text/plain (2871 lines)
The agreement between the EU and the US on Champagne basically says that
if you used the word "Champagne" as a generic term before the law was
approved (2006), you are permitted to continue using it. 

Basically, you are permitted to say something like "American Champagne"
or "Rocky Mountain Champagne" , but not just "Champagne" as the term
"Champagne" without a modifier (true place of origin) could be confused
as describing origin, not product. 

 

 

________________________________

From: Werner Engelmaier [mailto:[log in to unmask]] 
Sent: 18 March 2010 15:30
To: [log in to unmask]; James, Chris
Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like
standards for impor

 

Not true....France forgot to protect 'champagne' in the USA.
Werner

 

 

 

-----Original Message-----
From: James, Chris <[log in to unmask]>
To: [log in to unmask]
Sent: Thu, Mar 18, 2010 9:51 am
Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like
standards for impor

No you wouldn't - only sparkling wine produced from grapes grown in the




region of Champagne in France can be called Champagne.........



















-----Original Message-----




From: Leadfree [mailto:[log in to unmask] <mailto:[log in to unmask]> ] On
Behalf Of Bob Landman




Sent: 18 March 2010 13:34




To: [log in to unmask]




Subject: Re: [LF] The Brainstorm: Should the U.S. employ RoHS-like




standards for impor









Yes, but as a former (and native) Californian, we'd then be able to  




call our sparkling wine champaigne. If only we had known...









Bob









Sent from my iPhone









On Mar 17, 2010, at 11:01 AM, "James, Chris" <[log in to unmask]> wrote:









> 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] <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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