Hi Mike, Point well taken. However, from a CEMs perspective, I was referring to stating the corresponding exemption on the IPC material declaration sheets (listed under the RoHS Material Composition Declaration field), that will accompany the RoHS 5 (for a lack of better term) assemblies to the customer. If anyone thinks this is incorrect, I'll be glad to know the correct way. Sincerely, Amol Kane M.S (Industrial Eng.) Process Engineer Harvard Custom Manufacturing, Inc. 941 Route 38 Owego, NY 13827 Phone: (607) 687-7669 x349 [log in to unmask] www.harvardgrp.com -----Original Message----- From: Leadfree [mailto:[log in to unmask]] On Behalf Of Michael Kirschner Sent: Wednesday, July 19, 2006 1:04 AM To: [log in to unmask] Subject: Re: [LF] [TN] RoHS 5 and RoHS 6 Folks, Let me be abundantly clear: there is NO SUCH THING as "RoHS 5". I recommend that you drop it from your lexicon and never speak of it again. ;o) Your products, if they are within the scope of RoHS (EU), must comply with the maximum concentration values in homogeneous materials for all six classes of restricted substances, taking in to account applicable exemptions. One of these exemptions is for "lead in solder for servers, storage and storage array systems", and "network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunication". Read the Annex, paragraph 7, lines 2 and 3 and you will see this exemption. When people speak (sometimes lovingly ;o) of "RoHS 5", they are referring to this specific exemption. It ONLY exempts lead used in solder; for instance, on PCB-mounted components, the PCB itself, and the solder used to join them, or wires to connectors. OTHER USES OF LEAD WHICH ARE NOT EXPLICITLY EXEMPTED BY THIS OR OTHER GRANTED EXEMPTIONS ARE NOT EXEMPT! Thus your products may not, for instance, contain lead in plastics (commonly used in flat cables, etc.). And you'd better check for this if you haven't yet... So "RoHS 5" is a shorthand misnomer. It is misleading; one admittedly very significant exemption for lead does not exempt ALL uses of lead in electronics. If you cannot tell yet, I really dislike this term because it is dangerously imprecise. Also, Mr. Kane's statement below that you have to state anything is a bit misleading. To restate Chris' comments a bit differently, this is a "self declaration" process. You don't have to "state" anything; you don't have to "declare" anything; you don't need a mark of any kind anywhere including a "CE" mark in order to comply with EU RoHS. You simply have to explain, when asked by an enforcement authority or maybe a customer, why your products are the way they are (in scope/out of scope/able to take xyz exemption/etc.)... convincingly... with data... Mike Kirschner President Design Chain Associates, LLC www.DesignChainAssociates.com www.ChinaRoHS.com -----Original Message----- From: James, Chris [mailto:[log in to unmask]] Sent: Tuesday, July 18, 2006 7:02 AM Subject: Re: [TN] RoHS 5 and RoHS 6 RoHS 5 is a termed coined by industry. It is not in the legislation. RoHS 5 is understood to mean you are claiming an exemption which permits the continued use of lead. There is no provision you need to declare you have used an exemption. However you would need to declare such on any d of c you might be asked for and you are best advised to internally document your decision for claiming the exemption for when the rohs police with their xrf guns come a knocking........... Regards, Chris -----Original Message----- From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kane, Amol (349) Sent: 18 July 2006 14:34 To: [log in to unmask] Subject: Re: [LF] [TN] RoHS 5 and RoHS 6 Hi Joel, The EU legislation limits the use of 6 hazardous chemicals (Lead, Cadmium, Mercury, Hex Chromium, PBBs and PBDEs). RoHS 6 compliant means that all these 6 substances are below the permissible level in the assembly. RoHS 5 means that 5, out of the 6 substances are below the permissible level, and the 6th substance is above the permissible level, but is covered by a RoHS exemption (thereby making the assembly RoHS compliant). Usually lead is above the permissible level in RoHS 5 assemblies as there are lead solder exemptions for specific applications. If your assembly is RoHS 6, you need not declare a class, but if its RoHS 5, you must state that it is RoHS 5 and then state the exemption class that is applied to the product. Regards, Amol Kane M.S (Industrial Eng.) Process Engineer Harvard Custom Manufacturing, Inc. 941 Route 38 Owego, NY 13827 Phone: (607) 687-7669 x349 [log in to unmask] www.harvardgrp.com -----Original Message----- From: TechNet [mailto:[log in to unmask]] On Behalf Of Joel Alexander Sent: Tuesday, July 18, 2006 9:07 AM To: [log in to unmask] Subject: [TN] RoHS 5 and RoHS 6 Can anyone explain these two classes of RoHS and do you have to claim a class or just declare that you product is RoHS compliant Joel Alexander APSCO Quality Assurance Manager --------------------------------------------------- Technet Mail List provided as a service by IPC using LISTSERV 1.8e To unsubscribe, send a message to [log in to unmask] with following text in the BODY (NOT the subject field): SIGNOFF Technet To temporarily halt or (re-start) delivery of Technet send e-mail to [log in to unmask]: SET Technet NOMAIL or (MAIL) To receive ONE mailing per day of all the posts: send e-mail to [log in to unmask]: SET Technet Digest Search the archives of previous posts at: http://listserv.ipc.org/archives Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815 ----------------------------------------------------- CONFIDENTIALITY NOTICE: This e-mail, and any attachments, is for the sole use of the intended recipient(s) and may contain information that is confidential and protected from disclosure under the law. 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Thank you. --------------------------------------------------- Technet Mail List provided as a service by IPC using LISTSERV 1.8e To unsubscribe, send a message to [log in to unmask] with following text in the BODY (NOT the subject field): SIGNOFF Technet To temporarily halt or (re-start) delivery of Technet send e-mail to [log in to unmask]: SET Technet NOMAIL or (MAIL) To receive ONE mailing per day of all the posts: send e-mail to [log in to unmask]: SET Technet Digest Search the archives of previous posts at: http://listserv.ipc.org/archives Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815 -----------------------------------------------------