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From:
SALA GABRIELE <[log in to unmask]>
Reply To:
TechNet E-Mail Forum <[log in to unmask]>, SALA GABRIELE <[log in to unmask]>
Date:
Mon, 24 Sep 2018 18:38:45 +0200
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Hi Blair,

start taking a look to EU Directive 2011/65/EU RoHS II.
https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX:32011L0065

See Annex  III and Annex IV
For instance take a look to item  6 (a), 6 (b), 6 (C) "  Pb in Steel, in Aluminum and in Copper Allows % limits by homogenous part).....

And also look at 7 (a)  " Lead in high melting temperature type solders (i.e. lead- based alloys containing 85 % by weight or more lead " this is the case where the Pb is used to attach the Die to Lead Frame of a D2-Pack or an IC generally speaking

All those information have to be provide by Component Suppliers, several of them have those info available on their web site, other on request, other nothing or very generic declaration like RoHS compliant (not acceptable) , etc...

The do not forget other EU Regolatory 1907/2006/EC REACH and , for instance substances SVHC ( total 191 entries up today in the list) in article, where for instance, ef you part (article) contains Pb, don't care about RoHS II Categories and limitations (Annex II), here you can use Pb but you must communicate to your DU (Downstream User) the presence of Pb (since June 2018 is classified SVHC by ECHA) in the article (part) if greater then  > 0,1% w/w. Just Communicate (no labeling required ) according to Art.33 of REACH. Etc.

Not so easy  to explain (REACH > 850 pages) , plus CLP, plus......
About SVHC, go to ECHA site you'll find many  useful infos...

Have a good luck....

Gabriele

-----Messaggio originale-----
Da: TechNet [mailto:[log in to unmask]] Per conto di Blair Hogg
Inviato: lunedì 24 settembre 2018 17:42
A: [log in to unmask]
Oggetto: [TN] Prop 65 and RoHS compliance

Hello Technetters,

Since now anybody and everybody can be sued in Cali if you don't put a label of some kind on your products, We've been labeling just about everything. I'm sure you all are doing the same, and maybe have been for some time. 

From what I understand, the label has to state the bad stuff that the product contains - lead, chromium, BPA etc. 

I've been told that even an RoHS compliant product should be labeled for lead as there is enough lead in the copper used to make the board that it will need the label. Any thoughts on this? I'm aware that there can be lead internal to the components in the assembly and still be RoHS compliant, which would require a label, but without researching every component, there is no way to determine this. If the copper in the PCB does contain lead, I don't need to check the components. 

Thanks all,
Blair


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