September 18th, 2006
Folks,
July 1, 2006 has come and gone. Most of us expected many problems at the borders of the EU countries Re customs after this date. All appears quiet. I have heard few stories of customs disasters. Since it appeared that < 50% of companies were RoHS compliant, I am wondering what happened. My guess is that the EU is not ready to perform consistent inspections and since there is no paperwork requirement (i.e. the act of placing a product on the market declares its compliance) product is simply flowing in with only spotty checks or testing.
Readers, what are you hearing?
Cheers,
Dr. Ron
Don Ballard:
Be careful in the Netherlands. They are checking many things at customs using XRF. They even check non EEE items for excess cadmium. We learned the hard way. We were told that the Netherlands, Norway, Iceland and Liechtenstein were all checking for excess cadmium in just about everything imported into their countries.
Got this from them:
The aim of the Cadmium regulation law environment dangerous substances are among others keeping out Cadmium Keeping products on the territory of the Netherlands independent of the European Economic Area (HONOUR). THE HONOUR exists from the territories of the EU-member states, the kingdom Norway, the republic Iceland and frost kingdom Liechtenstein. This means that goods which have not been brought nevertheless on for this the mean territory in consumption environment can be brought. The ministry of VROM sees to this end on. This supervision was exercised on the basis of decision indication
supervisory civil servants VROM-regulation (Stcrt of 20 December 2001,no. 247/ page. 27).
V.w.b. the product Cadmium refers I you to the ministry of V.R.O.M. On the Internet site of V.R.O.M., www.vrom.nl/pagina.html?id=9186, more
information is consult concerning cadmium.
The address of the ministry of V.R.O.M.: PO Box 16191, 2500 BD Den Haag.
YOU can conjugate visibility for further questions also at the aforementioned ministry of V.R.O.M. or with the VROM inspection, LMIP of V.R.O.M.
Slovenia:
Slovenia started checking only manufacturers DoC for RoHS.
Testing is expected to begin in 2007 by National Chemicals Bureau http://www2.gov.si/mz/mz-splet.nsf/f1?OpenFrameSet&Frame=main&Src=/mz/mz-splet.nsf/0/5D32C6BA00FB6338C1256B1E004D85EA?OpenDocument
Don Ballard:
We have also gotten letters from our distributors abroad asking us to swear that our products are RoHS compliant.
An interesting item, we got a certificate from one of our manuafcturing facilities showing they were approved via a facilities audit showing they used RoHS approved methods and procedures in the assembly process of their finished goods. I think this is a great idea.
Based on what I have seen thus far, the majority of folks are just compiling CoC's and getting documentation to show the products are RoHS compliant. From what I have read and heard, this will not be enough to show due diligence. I believe that once some enforcement and punishment has been dished out, more folks will do more things to show compliance. Right now, there is no bite behind the EU's bark when it comes to RoHS....or very little. People will only do what they have to do until they see otherwise.
Personally, I was thinking people were going to do BOM scrubs at a minimum as well. I even considered buying an application and offerinfg the service after I saw what other places were charging for scrubs (minimum $2500 or $10 per line-item). I sent out notices and feelers with little, almost no response. If it were my name on the product, I sure as heck wouldn't trust a certificate on everything. All it would take is once to get burned.
Don Ballard:
Unfortunately, what I am hearing from some is, "since there are no fines, merely the refusal of the shipment at customs, we will just take our chances." That is the attitude I have been hearing and you can't really blame them. RoHS and WEEE need to be more strictly enforced at all levels- manufacturing, importing, sales and end of life. Once folks see that they mean business, more attention will be given to this area.
Another interesting item. Many I have spoken with are now just counting China out of their sales plans due to more strict RoHS rules. From what I am being told, it is not economically feasable to sell into China given the method in which China will test all products.
aaron:
I hear that some of the NGOs may start testing for Xmas time.
Best, Aaron
Mike:
I was thinking about what a RoHS "justification" package might have to contain if we were challenged at the EU border. Although there is no supporting documentation rule; is there any guidance out there? We produce a large 'fixed base" complex assembly which is exempt except some parts. As a start I was thinking about the following:
1- Explanation as to how the directive applies to our product - what is to be compliant & what is exempt.
2- List of compliant parts from our BOM.
3- Our internal RoHS control process; yes we created one which includes (controls, audits, & part validation methods which includes inspections and a x-ray gun we purchased).
4- we have supplier evidence (declarations, etc) but this would start to make the package much bigger & complicated.
Any thoughts? Thanks
John:
Is RoHS Compliance not Being Aggressively Enforced?
Simple answer, yes.
I am competing against product that is non RoHS compliant every day, especially from the American imports.
It appears to not be worth the paper it's written on.
There appears to be a misconception within our industry that it only applies to "newly designed" product, so existing designs are exempt.