RoHS Frequently Asked Questions
The
European Commission has recently clarified various issues on
the interpretation of the RoHS Directive and the definition of
some of its terms. This has provided answers to a number of frequently
asked questions.
Q1. What is covered?
A1. Equipment which is dependent on electric current or electromagnetic
fields in order to work properly excluding
military, medical
and some other control products. Products made specifically
for the
automotive trade are allowed to contain lead but not the other
5 substances.
Q2. Does the Directive apply to professional equipment?
A2. The
RoHS Directive does not differentiate between household or professional
electronic and electrical equipment,
so products for professional use are covered by the RoHS Directive.
Q3. Does
the RoHS Directive apply to batteries?
A3. The RoHS Directive restricts the use of heavy metals in electronic
and electrical
equipment, but does not apply
to
batteries.
Q4.
Does the RoHS Directive apply to spare parts installed in new
equipment?
A4. The
Directive does not apply to spare parts for the repair, or reuse,
of electronic and electrical
equipment put on the
market before 1st July 2006.
Q5. What does 'put on the market' mean?
A5. The
words 'put on the market' refer to the initial action of making
a product available for the first
time on the community
market. This takes place when the product is
transferred from the
producer to a distributor or final consumer or
user on the Community Market.
'Making a product available for the first time'
refers to each individual piece of equipment
put on the
market after the date
for the restrictions (1st July 2006) and not
to the launch of a new product or product line.
Therefore, say for instance producer A is manufacturing
item ABC, and has done for years, which uses
a non-compliant process,
he
can not stock pile and put it on the market after
1st July 2006 and hide behind the fact they were
WIP made
before the
deadline.
Q6. Does the substance ban under the RoHS Directive apply to the
production process?
A6. It
is understood that the substance restriction refers to the final
product and not the production
process. But, if
say
for instance
lead or cadmium is used as a catalyst within
a production process and as a result of this is found
in the final
product above
the prescribed limit, then that product is
not compliant.
Q7. Does the substance restriction under the RoHS Directive apply
to products built for own
use?
A7. The
RoHS applies only to products that are put on the market. Products
manufactured
for
own use
such as prototypes and development
samples are excluded from the scope of the
Directive. If subsequently put on the market,
they have
to comply with the Directive.
Q8.
Are maximum concentration values set in the RoHS Directive?
A8. Yes
there are and these limits refer to homogeneous materials such
as plastics, ceramics,
glass,
metals, alloys, paper, board,
resins and coatings. For instance, a semiconductor
package contains many homogeneous materials
which include: plastic
moulding material,
tin-electroplating coatings on the lead
frame, the lead frame alloy and gold bonding wires.
Contrary to general opinion,
the materials
can be easily identified down to the composition
of plating using X-ray techniques on equipment
specifically
designed for
this
purpose. It will easily identify levels
of lead in plating material down
to a few PPM in a matter of minutes. After
1st July 2006 there will be no hiding place
for those
manufacturers
who think they
will not be detected.
|