News

Beware of Counterfeit Parts

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Counterfeit parts
Gray Market parts are going to need a lot more scrutiny
because of RoHS.Typically, the flow of gray market parts – some of them counterfeit – balances industry gaps in supply and demand.
Much of the gray market consists of legitimate brokers, but during the transition to lead-free products, even reputable brokers may come under suspicion.

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The Cost of Compliance

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Ouch!

From Electronic News:
“We knew it was going to cost more to become RoHS compliant. Just how much more is debatable, but the established guess is 8% – 15% of product production costs.”
And the costs are not just internal. Suppliers like Newark and Digi-Key have seen their costs increase, so expect to see it reflected in your component and raw material costs.
In its case, most distributors have added additional employees — at additional cost
— for the bin checks, as well as additional employees in the receiving
area to double check warehouse supply.

Newark InOne also noted additional time and money spent by Newark InOne’s legal staff, for undertakings such as ensuring the verbiage is correct on packaging and sorting out new contracts.

 

“…we are keeping two inventories,” said Jeff Shafer, Newark InOne’s senior VP of product management, noting that on top of that the company does bin checks to be absolutely certain customer orders for lead-free are lead-free.
But the cost of non-compliance is higher, especially with China RoHS and EU REACH now required.  For a proposal to ensure your products are compliant. Protect your market share.

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RoHS in other countries

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RoHS is not just for the European Union.

Here are some of the “Lead Free” initiatives currently planned or in place:

EU RoHS - July 1, 2006

 

 

European Union
EU RoHS, which went into effect on July 1, 2006 mandates a phase-out of heavy metals such as cadmium, mercury, lead, and hexavalent chromium as well as brominated flame retardants in future electronic products.

China RoHS - March 1, 2007

 

 

China
China RoHS was issued on Feb. 28, 2006 and takes effect March 1, 2007. The directive mandates for a phase out of heavy metals such as cadmium, mercury, lead, and hexavalent chromium as well as brominated flame retardants in future electronic products.  Phase 1 is extensive labeling and reporting.  Phase 2 requires removal of banned substances.

Sony Green, Mitsubishi Sumitomo - 2006

 

Japan
Although Japan does not have a regulation that mandates elimination of lead, Ministry of Trade and Industry (MITI) requested the decrease of lead in electronics by 75 percent by year 2005. Implementation of this request was voluntarily because the largest market for Japanese electronics is Europe. In order to comply with European RoHS, Japan had to adjust its manufacturing process by decreasing heavy metals in production.

Korea RoHS - July 1, 2007

 

 

South Korea
Korea issued similar to RoHS legislation called “The Act for Resource Recycling of Electrical/Electronic Products and Automobiles” to the World Trade Organization (WTO) on March 30, 2006. This legislation is planned to be enforced on July 1, 2007.

Pending legislation for 2007

 

 

New Zealand
In July 2005, Environment Minister released Product Stewardship and Water Efficiency Labelling, a discussion document outlining the government’s options for encouraging businesses and consumers to accept responsibility for the environmental effects of products.

 

Pending legislation for 2007

 

 

Canada
In October 2004, Alberta launched Canada´s first provincial electronics recycling program with advance recycling fee of up to $45 on electronics sold in the province.

 

Want to cover all of these RoHS Directives at once?….

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Getting the Lead Out

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So what does all this mean for consumers? Most companies say their toxin-free products will look and act the same as their lead-laden counterparts.”

Popular Science has a great article in their latest issue titled “Getting the Lead Out” by Billy Baker. It is a well written layman’s explanation of what the RoHS directive and conversion process is all about.

Use it to show your kids what you do for 14 hours a day… (we did)

Want to stop spending 14 hours a day on RoHS?…

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How to use an XRF gun

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Incoming inspection shows due diligence

Thermo Electron Corporation, the manufacturer of NITON Analyzers (XRF guns) sponsors free webinar about the technology and proper use of an XRF gun on a regular basis.
 
Because of anticipated supply chain problems, vendor compliance issues and counterfeit part probabilities, Lead Free Design highly recommends that you have an incoming inspection plan in place for the next 12 months.
 
We also highly recommend the Niton XRF gun – we use one ourselves.  About $40k to buy, but you can lease one for about $1800 a month.  Considering the costs of getting caught with non-compliant parts, it is cheap insurance.
Click here to sign up on their website

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California RoHS bill vetoed

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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
necessary.

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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California RoHS: It's back….

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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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California's RoHS date is 1 Jan 2007

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Starting January 1, 2007 California is banning any product that can’t be sold in the EU.

Here’s California’s SB 50 (1 b. below):

The department shall adopt regulations, in accordance with this section, that prohibit an electronic device from being sold or offered for sale in this state if the electronic device is prohibited from being sold or offered for sale in the European Union on and after its date of manufacture, to the extent that Directive 2002/95/EC, adopted by the European Parliament and the Council of the European Union on January 27, 2003, and as amended thereafter by the Commission of European Communities, prohibits that sale due to the presence of certain heavy metals.

You only have until Jan 1, 2007 to comply !

RoHS California’s definition of the "covered electronic device" is not completely known at this time, and may not be as all encompassing as the RoHS EU. The lack of clarity and details in California’s RoHS are as frustrating as the EU RoHS directive. More and more countries and states will be taking direction from EU RoHS.

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Which products must comply?

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How do I know if my products must comply?

There are two major RoHS directives in place:  EU RoHS and China RoHS

While 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.

China RoHS and EU RoHS are very different…

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Stationary Industrial Tools

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Are large scale stationary industrial tools exempt from EU RoHS or China RoHS requirements?

For China RoHS, all categories of Electronic Information products require Marking.  The final specifications for Testing and inclusion in the catalog have not been released.

For EU RoHS, large scale stationary industrial tools are specifically exempt under category 6, but there is currently no clear guidance on the scope of electrical and electronic (EEE) devices covered by this exemption and it is therefore difficult for us to give advice with certainty.

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"Placed on the Market"

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What does "Placed on the Market" mean?

China RoHS and EU RoHS have very different definitions for "placed on the market".

For EU RoHS, "placed on the market" is defined for the purposes of RoHS in the European Commission’s ‘Guide to the implementation of directives based on the New Approach and the Global Approach’ (commonly referred to as the ‘blue book’).

China RoHS is very different… 

The general principles of "placing on the market" for EU RoHS are:

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Where does RoHS apply?

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Where (Geographically) does EU RoHS and China RoHS apply?

 

For China RoHS, it is mainland China, Hong Kong and all Chinese territories.

China RoHS is very different 

For EU RoHS, RoHS only applies to products placed on the market in the European Economic Area (EEA).

Note: the EEA is a superset of the EU, and includes the 25 EU member states (below) plus Iceland, Norway, Liechtenstein, Sweden and Switzerland.

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