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IPC RoHS Directive Webcast Guides Attendees
July 26, 2005 |Estimated reading time: 2 minutes
By Michelle M. Boisvert, SMT Managing Editor
NASHUA, N.H. — "Only 246 working days to 1, July 2006!" a slide informed attendees during the IPC – Association Connecting Electronics Industries' Webcast, The RoHS Directive on the Restriction of Hazardous Substances, presented by Steve Andrews of the UK Department of Trade and Industry. Andrews gave attendees an overview of the RoHS Directive and an update on RoHS maximum concentration values. But what seemed to really bring attendees to the edge of their seats, and brought about the most attention during the Q&A session was the compliance and enforcement section.
The RoHS Directive is an 'Article 95' Directive, which means that it is meant to protect the single market, seeking to reduce the environmental impact of a particular product. The Directive restricts the use of six substances, but does not specify how manufacturers/producers can comply or the requirements for market surveillance. Compliance will be enforced by market surveillance, said Andrews. If the enforcement body challenges a declaration, the company must prove that it took reasonable steps (due diligence) to meet the regulations. While materials declaration and parts marking standards exist and continue to be developed, Andrews explained that the EU supports an adoption of standards, but the government would not mandate that manufacturers use a particular one.If a product is suspected of non-compliance, the enforcement body will check to see if the manufacturer took reasonable steps to comply. A testing phase will occur if there are on-going concerns. Lastly, Andrews said, products will not be removed from the market until proven to be non-compliant. "Companies are presumed to comply. They are innocent until proven guilty," added Andrews. There was some question about need for consignment materials, those products or parts "on hold" in a warehouse somewhere prior to July 1, 2006, to be RoHS-compliant. Andrews advised that manufacturers must use the Blue Book for guidance, following the "Put on Market" definition. This states that a product is placed on the European market once it is available for orders or transfer to a final order. If the items are made available for distribution of use prior to July 1, 2006, they do not need to be compliant.Another topic of discussion was how partnerships using proprietary technologies should deal with the materials declarations. There is concern that a company will lose intellectual property if it must declare all materials to its partners, possibly divulging their "secrets." Because there is no formal materials declaration statement or standard, Andrews suggested that companies create (among themselves and their partners) a blanket statement that does not name specific technologies used, but states compliance of a particular part. It seems that is one for the lawyers to hash out. What can a company do if they're completely RoHS-compliant and ready to let the EU know? Well, not too much. Under RoHS, there is no product registration. Those companies may have to wait until they have WEEE-compliant parts to tell the EU about them. For additional information on lead-free regulations, IPC is hosting RoHS Summer School, a series of Webcasts on lead-free legislation. The next Webcast, Standards Activity – 1752 is scheduled for Thursday, July 28, 2005. For a full schedule and to register, please visit www.ipc.org/RoHSedu, or call (847) 597-2861.