RoHS substances explained

January 19, 2008 in Latest, News Leave a reply

Poison warning

While there are sometimes heated discussions about the economic impact of environmental laws, it might be helpful to summarize what the six current EU (and China) RoHS materials are, where they are commonly used, and some of their less than desirable effects on humans:


Lead is a heavy metal that occurs naturally in the environment and is produced from man-made sources. Most exposures to lead come from lead paint and emissions from industrial facilities like metal smelters. Other sources of exposure include crystal tableware, porcelain enamel and contaminated food. Lead is a suspected carcinogen, a known hormone disruptor, and can damage almost every organ and system in the human body, particularly the nervous system. Lead has been indicated as a cause of decreased mental ability, developmental delays, behavioral disorders and reproductive defects.
Lead is/was commonly used in the electrical and electronics industry in solder, lead-acid batteries, electronic components, cable sheathing, in the glass of CRTs etc. Short-term exposure to high levels of lead can cause vomiting, diarrhea, convulsions, coma or even death. Other symptoms are appetite loss, abdominal pain, constipation, fatigue, sleeplessness, irritability and headache. Continued excessive exposure, as in an industrial setting, can affect the kidneys. It is particularly dangerous for young children because it can damage nervous connections and cause blood and brain disorders.


When inorganic mercury enters the air from these human sources it is then deposited in soil and water, where micro organisms transform inorganic mercury into organic mercury compounds, such as methyl mercury. Methyl mercury can bioaccumulate in the fatty tissues of living organisms, particularly fish living in polluted waters, and the people who then eat those fish. Mercury is a recognized developmental toxin, and it is also a suspected hormone disruptor, neurotoxin, reproductive toxin and respiratory toxin.
Mercury is one of the most toxic yet widely used metals in the production of electrical and electronic applications. It is a toxic heavy metal that bioaccumulates causing brain and liver damage if ingested or inhaled. In electronics and electrical appliances, mercury is highly concentrated in batteries, some switches and thermostats, and fluorescent lamps.

Simpsons fishCadmium

Cadmium is a heavy metal that comes from both natural and man-made sources. Most exposures to cadmium come from pigments and bake ware, as well as electronic equipment, car parts, batteries, phosphate fertilizer, sludge applications in agriculture and contaminated food. This heavy metal is known to cause lung and prostate cancer, and is toxic to the gastrointestinal tract, the kidneys, and the respiratory, cardiovascular and hormonal systems. Cadmium components may have serious impacts on the kidneys. Cadmium is adsorbed through respiration but is also taken up with food.
Due to the long half-life in the body, cadmium can easily be accumulated in amounts that cause symptoms of poisoning. Cadmium shows a danger of cumulative effects in the environment due to its acute and chronic toxicity. Acute exposure to cadmium fumes causes flu-like symptoms of weakness, fever, headache, chills, sweating and muscular pain. The primary health risks of long term exposure are lung cancer and kidney damage. Cadmium also is believed to cause pulmonary emphysema and bone disease (osteomalacia and osteoporosis).


Chromium and its oxides are widely used because of their high conductivity and anti corrosive properties. While some forms of chromium are non toxic, Chromium (VI) is easily absorbed in the human body and can produce various toxic effects within cells. Most chromium (VI) compounds are irritating to eyes, skin and mucous membranes. Chronic exposure to chromium (VI) compounds can cause permanent eye injury, unless properly treated. Chromium VI may also cause DNA damage.

Brominated flame retardants (PBB, PBDE)

The 3 important types of BFRs which can / could be used in electronic and electrical appliances are Polybrominated biphenyl (PBB), Polybrominated diphenyl ether (PBDE) and Tetrabromobisphenol-A (TBBPA). Flame retardants make materials, especially plastics and textiles, more flame resistant. They have been found in indoor dust and air through migration and evaporation from plastics. Combustion of halogenated case material and printed wiring boards at lower temperatures releases toxic emissions including dioxins which can lead to severe hormonal disorders.
PBDEs are highly persistent and bioaccumulative and they are suspected hormone disruptors and can cause cancer reproductive and developmental disorders. PBDEs are suspected of having particularly damaging effects on the thyroid (which controls brain development), and as a result, PBDEs may cause neurodevelopmental disorders such as learning disabilities and behavior problems. PBDEs leach from products, and have been detected in house dust, human blood and breast milk.

(Source: Study of the RoHS Directive  N° 30-CE-0095296/00-09 December 2007)

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California RoHS bill vetoed

October 22, 2007 in Latest, News Leave a reply

California RoHSThis Monday, October 15, 2007 – California Governor Arnold Schwarzenegger vetoed Assembly Bill AB 48 that promised to greatly expand the RoHS statutes mandated by the
California Waste Recycling Act.

In killing the bill for this year, the Governator said, "Unfortunately, the
approach taken in this bill is largely unworkable and instead of the
benefits it seeks to accomplish, could ultimately result in unintended
and potentially more harmful consequences."

The vetoed bill, said
Schwarzenegger, "purports to impose restrictions similar to those
already in place in the European Union, but the deviations it takes
from the European Union approach are fatally flawed."

California politicians had sought to greatly expand the scope of the current law, which now covers a relative handful of product types, including monitors, TVs and notebook computers. 

Schwarzenegger claims
exemption language for spare parts and refurbished products, as
currently written in AB 48, would make many electronic products
prematurely obsolete and force their retirement years earlier than

The EU RoHS Directive exempts spare and refurbished products.

This was the second attempt to pass an extensive "EU RoHS" directive in California, and will probably not be the last.


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Toxic Sex Toys and iPhones

October 18, 2007 in Latest, News Leave a reply

 Can’t imagine where they will stick the RoHS label….
Yesterday’s legal action in California against Apple over its use of phthalates may be the opening shot in a nation wide battle between consumer advocates, health agencies, state and federal entities, and manufacturers of everything from teething rings to consumer electronics to sex toys.
Although the ban (which will go into effect Jan. 1, 2009) is limited to California,
“lawmakers in Texas, Illinois, Florida, Massachusetts, Maryland, Washington, Maine, Connecticut and New York are expected to introduce similar legislation in the coming months”, according to environmental and breast cancer groups that sponsored the California measure.
diapers and depends

We are getting older

Phthalate is a chemical used to soften plastics, and it’s used in a variety of industries. There have been several studies that indicate it may affect hormone levels as well as cause other lasting damage.
But the issue is fairly controversial, because there are other existing studies that show it poses no danger. The president of the American Chemistry Council says, “This law is the product of the politics of fear. It is not good science, and it is not good government.”  For now, in California at least, the health advocates have prevailed whether the science is there or not.
Some vendors of jelly rubber sex toys advise covering them in condoms
when used internally, due to the possible health risks.  Some products
containing phthalates (mostly toys and childcare articles) have been
banned in Europe.
Look for pressure to extend the ban on phthalates into EU and China RoHS.

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IP protection in China

March 6, 2007 in Latest, News Leave a reply

IP Theft"How can we do business in China and still protect our Intellectual Property?"
The short answer is:  you can’t, at least not through the American legal system.  And you will need specialized legal help to attempt to protect your IP under China’s legal system.
"China’s interests are in reducing the cost of IP, not in protecting it," according to Kenneth DeWoskin, of Pricewaterhousecoopers.
Among the reasons:
  • China’s economic growth
    is based on low-cost manufacturing, and IP licenses just add cost

  • Government R&D priorities favor derivative products for domestic
    markets, rather than true innovation that needs patent protection

  • Policy makers continue to favor the public good over property rights

UPDATE: "This over simplifies the problem; there definitely are ways to protect your Intellectual Property" says Dan Harris, a partner at Harris & Moure in Seattle.

Harris authors
as a source of China legal and business information.  He has several
compelling articles on IP protection in China.  If you are concerned
about IP protection, his site is well worth a look.


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Straight Answers: China RoHS

January 31, 2007 in Latest, News Leave a reply

China RoHS highlights
(Q:) OK, I’ve read everything I can about this new China RoHS "law".  Give me the salient points.
It is actually not that complicated. (the highlighter is your friend)
By March 1, 2007:
All products sold into China must be labeled for restricted substance content.  As almost every electronic product has at least one of the restricted substances, the labeling works like this:

  • Figure out the Environmentally Friendly Use Period (EFUP) and mark that on the product. It looks like an "e" with a number in the middle. 10, 20, 30, 50 years are common.

  • Then, analyze all the components in your product for the 6 restricted substances, aggregate them, and mark your product with a hazardous material "x/o" chart in Chinese.

  • Finally, analyze your packaging material for recycling purposes, and mark the materials. You might also have to mark your documentation and data sheets with this same information.

(Q:) That doesn’t seem so bad.
As usual, the devil is in the details. 
To do this, you need to analyze, label, and you must have supporting documents for every component in your product at the substance level.

(Q:) Wait! The Chinese RoHS spec doesn’t say that!
Very true.  All it says is that you have to indicate which of the restricted substances are in your product.  Keep reading if you want to know why you absolutely must have substance-level supporting docs…

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China RoHS Marking

January 29, 2007 in Latest, News Leave a reply


China Changes the Rules for RoHS

China RoHS (formally known as “Management Methods for Controlling Pollution by Electronic Information Products”) primarily differs from EU RoHS as follows:
EU RoHS is effectively a “self-reporting and compliance” directive, with the possibility of retroactive enforcement; China RoHS requires stringent Marking before March 1, 2007, and China-approved testing prior to product entry into China.
On November 6, 2006, China’s Ministry of Information signed three standards into law:
  • Marking: labeling and information disclosure
  • Levels: maximum concentration value
  • Testing: testing methods
Except for the Marking standard, the final official standards have not been published but are expected soon. 

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California RoHS: It's back….

January 18, 2007 in Latest, News Leave a reply

California RoHS is alive and well

The new 2007-08 California legislative session opened on December 4, 2006, and on opening day, Lori Saldana filed Assembly Bill 48, which would establish comprehensive RoHS-like legislation in California.
AB 48 would change the definition of electronic device in the California Health and Safety Code to mirror the language in the EU RoHS directive.
This is a substantial expansion of the current definition which includes video display devices only.
January 1, 2010 would be the effective date for the expanded RoHS law.

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What we do at Lead Free Design

January 8, 2007 in Latest, News Leave a reply

We document, validate and certify RoHS documentation for all of your products.  Quickly, correctly and efficiently.  At a fraction of the cost of doing it in-house.

We provide certified RoHS documentation.  Because we analyze and document your product down to the material level, we can create certification and irrefutable documentation for all countries and RoHS-like Directives affordably, consistently and quickly

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RoHS certification and compliance

January 8, 2007 in Latest, News Leave a reply

RoHS conversion process

RoHS Compliance

Restriction of Hazardous Substances (RoHS) is a group of international environmental laws requiring the re-design of many electronic devices. We at Lead Free Design are cost-effective experts at RoHS Compliance.
We analyze your electronic products, provide RoHS compliant documents, and maintain them for you, all at a fraction of the cost of doing it in-house. For Europe RoHS, China RoHS, California RoHS, Korea RoHS, Japan RoHS and all RoHS directives.

RoHS and WEEE certification and compliance – expertly, quickly and affordably.

RoHS Conversion

While many products are officially exempt from RoHS laws,  you may find your existing components are no longer available.  Get control of those weekly "end of life" and "discontinued product" notices from your suppliers.  We analyze your existing leaded products, and convert them to RoHS-compliant lead free versions.
RoHS conversion and re-design – expertly, quickly and affordably.

Medical RoHS Conversion

We are specialists in Medical RoHS conversions. 
To ensure FDA compliance, medical devices require special methods and in-depth documentation during a RoHS conversion.  We protect your existing FDA certification and 510K with full verification and validation procedures.  And we continually analyze your supply chain using predictive life cycle tools.
Medical device RoHS conversion and re-design – expertly, quickly and affordably.

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China RoHS: very different

January 3, 2007 in Latest, News Leave a reply

China RoHS is very different from EU RoHS

China RoHS is not EU RoHS
EU RoHS is effectively a "self-reporting and compliance" directive, with the possibility of retroactive enforcement.  China RoHS requires product, data sheet, and packaging marking before March 1, 2007, and China approved testing prior to product entry into China.
EU RoHS has no Marking requirements. China RoHS marking requirements are stringent.
EU RoHS requires "Certificates of Compliance", not material declaration documents for each component. China RoHS requires material declaration documents in order to survive a marking audit.
Most EU RoHS documents do not have the information needed to evaluate or support China RoHS Marking compliance.

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China RoHS – Marking

January 3, 2007 in Latest, News Leave a reply

China RoHS is very different from EU RoHS.

EU RoHS is effectively a "self-reporting and compliance" directive, with the possibility of retroactive enforcement.  China RoHS requires product, data sheet, and packaging marking before March 1, 2007, and China approved testing prior to product entry into China.

 EU RoHS has no Marking requirements. China RoHS marking requirements are stringent.

EU RoHS requires "Certificates of Compliance", not material declaration documents for each component. China RoHS requires material declaration documents in order to survive an audit.

Most EU RoHS documents do not have the information needed to evaluate or support China RoHS Marking compliance.

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Medical devices not exempt

October 19, 2006 in Latest, News Leave a reply

RoHS can affect FDA complianceWhile, technically, they may fall under exemption EU-RoHS #8, the market-based reality is that Medical Devices and Telecom are no longer exempt from effects of RoHS regulation.
And that puts your existing FDA approval at risk.
If your company is having component issues because your suppliers are switching to RoHS (lead free) compliant parts, you are definitely not alone.

What has changed?

As component suppliers are moving towards "lead free only" and discontinuing your leaded parts, you will be faced with redesign issues, regardless of your exemption status.

China RoHS and Medical devices

China RoHS requires product marking for all electronic products beginning on March 1, 2007, including medical equipment. And unless you have supporting documentation down to the material level on all sub-assemblies, you will not survive a marking audit.

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