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Questions about ROHS — Parallax Forums

Questions about ROHS

william chanwilliam chan Posts: 1,326
edited 2009-11-16 00:22 in General Discussion
I know this has been discussed before, but I can't seem to find the answers to my questions.

1. If I send a sample electronics product to Europe, do I need a ROHS certificate?
2. Can I make my own ROHS certificate for my own products?
3. Does every part and component of the product need to be certified?
4. If a shipment to Europe lacks a ROHS certificate, will it be returned or confiscated?

Thanks.

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Comments

  • LeonLeon Posts: 7,620
    edited 2009-11-13 23:41
    Here is a UK guidance document:

    www.rohs.gov.uk/Docs/Links/RoHS%20Regs%20Guidance%20-%2021%20June%202006.pdf

    You should also check the actual regulations.

    Other EU countries will have similar requirements.

    Certification will be required in a few months, I don't think that the details have been worked out yet. At present, you have to be able to show conformity only if it is required.

    I was recently sent a non-RoHS ARM board made in India for review and there weren't any problems with it getting into the country. In theory, it could have been confiscated or returned. The supplier is redesigning the board to make it compliant.

    You might also need to demonstrate CE conformity. That involves testing and could cost as much as $5,000.

    Leon

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    Post Edited (Leon) : 11/14/2009 12:10:40 AM GMT
  • LoopyBytelooseLoopyByteloose Posts: 12,537
    edited 2009-11-14 09:56
    Mostly, the ROHS has evolved into an economic barrier so that only well capitalized companies can compete on a global level. Verification always costs money.

    Parallax had a rocky change over to ROHS because all the 'experts' were pushing carrying two manufacturing lines - one compliant and one non-complaint. But in the end, double inventories and double production lines create untold certification hassles and the possibility that your staff sends the wrong product to a ROHS client. So Parallax, like just about the whole industry, has chosen to make everything ROHS compliant and no longer carry Pb inventory if at all possible. It is just the cheaper, easier way to manage your venture.

    Still, if you are using jobbers out of China, many are not ROHS compliant and cannot qualify. You may have to shift to a jobber in the EU that can prove their manufacturing is 100% compliant in order to avoid certification hassles.

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    aka G. Herzog [noparse][[/noparse] 黃鶴 ] in Taiwan
  • william chanwilliam chan Posts: 1,326
    edited 2009-11-14 11:32
    So does that mean that before I stuff a PCB with components, I should ask the assembly factory whether they are ROHS certified or not.
    If they say yes, then everything is no problem?

    Does this also mean that I must let them procure all parts and components?

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  • LeonLeon Posts: 7,620
    edited 2009-11-14 13:57
    Yes, provided that the components you specify are RoHS. You need to check that for yourself, to make sure. You could choose an ISO9000-registered company and check their procedures, to make sure that they are using lead-free solder. You can buy lead testing kits, if you want to check the solder yourself.

    Leon

    ▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔
    Amateur radio callsign: G1HSM

    Post Edited (Leon) : 11/14/2009 2:08:05 PM GMT
  • LoopyBytelooseLoopyByteloose Posts: 12,537
    edited 2009-11-14 15:07
    My guess is that they provide certificates as well.

    So if a company says that they can do ROHS, but cannot supply certification - they may not really know how to do it.

    ▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔
    Ain't gadetry a wonderful thing?

    aka G. Herzog [noparse][[/noparse] 黃鶴 ] in Taiwan
  • mctriviamctrivia Posts: 3,772
    edited 2009-11-14 15:16
    Things to look for:

    1) PCB Is Silver, or Gold Plated. If not silver or gold then leaded tin is usually used. Also ask if they are ROHS Complian.
    2) All parts you buy are ROHS Compliant. This is pretty easy these days since very few products contain lead anymore. Some things like lithium batteries are ROHS Excempt because there just is no alternative.
    3) All solder you use is lead free. I through out all my 63/37 solder a year ago so I would not accidentally use it on any products.

    By doing these 3 things I have made sure that all products I make are ROHS compliant. The life expectancy of ROHS compliant circuits is not as long as non ROHS compliant but lead is really not something you want to be working with and compliance is a must for world wide trade.

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  • LeonLeon Posts: 7,620
    edited 2009-11-14 16:57
    Loopy Byteloose said...
    My guess is that they provide certificates as well.

    So if a company says that they can do ROHS, but cannot supply certification - they may not really know how to do it.

    There is no official certification process for RoHS conformity, at present. It should be specified, of course, when dealing with a board supplier/assembler.

    www.rohs.gov.uk/FAQs.aspx#25

    Leon

    ▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔
    Amateur radio callsign: G1HSM

    Post Edited (Leon) : 11/14/2009 5:07:07 PM GMT
  • william chanwilliam chan Posts: 1,326
    edited 2009-11-14 22:45
    What if my product has a vga display card which we buy from retail stores.
    How do we get a ROHS certificate for these cards?

    Does this mean that any prototype boards we make cannot be sent to europe for testing before volume production?

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  • Tracy AllenTracy Allen Posts: 6,666
    edited 2009-11-14 22:52
    For small shipments or of prototypes, Big Brother is most probably not going to ask. There is no form to fill out at present to hand to customs officials, and I doubt that is going to happen anytime soon.

    Where it will come to a head is if you want to sell your product regularly to an institution and in particular to a government agency in the EU, or if you sell thru a distributor. They will demand compliance with RoHS. Even at that level it depends mostly on voluntary compliance and it suffices for your company to state that it complies . And to do that honestly, you have to go down your bill of materials and check them off one by one. Every mainline distributor like Digikey, Mouser, Arrow, Avnet etc. and of course Parallax, list the RoHS status of the components they sell. Major PC board manufacturers give the option for lead free plating, and that is mostly the default option now. Same thing with assemblers. It is wise to keep a paper trail of all this stuff so that you can make a good case if someone asks for it, but that may never happen. CE is harder, and it is the EMC (Electromagnetic Compatibility) sections that are usually most problematic, although there are lots of special requirements for toys, medical devices etc. etc.. If your product contains a microprocessor, or high frequency or sensitive circuits, it will take special equipment to verify EMC compliance. It is an issue too if your product is a sub-assembly or component that will be used as a component in something else. The regulations in that area are tightening up.

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    Tracy Allen
    www.emesystems.com
  • LeonLeon Posts: 7,620
    edited 2009-11-15 00:09
    william chan said...
    What if my product has a vga display card which we buy from retail stores.
    How do we get a ROHS certificate for these cards?

    Does this mean that any prototype boards we make cannot be sent to europe for testing before volume production?

    As I said previously, there is no such thing as RoHS certification! If the card is marked RoHS you might be OK, but it would be safer to buy it from a company like Digi-Key.

    Prototype boards sent to the EU should be RoHS, of course.

    Leon

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    Amateur radio callsign: G1HSM
  • william chanwilliam chan Posts: 1,326
    edited 2009-11-15 02:38
    Can I confirm that to sell a product in the EU like in the UK, you need CE and EMC certification which costs a lot of money?
    Otherwise, no electronics product can be sold?

    Should the CE and EMC certification be done by the UK distributor?

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  • LeonLeon Posts: 7,620
    edited 2009-11-15 15:41
    Yes, CE is a requirement for any equipment sold in the EU. It could be done by the importer, of course, and might be lot cheaper here than where you are. It's not necessarily all that expensive if the facility is hired for a half-day and one does the preliminary testing oneself. Any problems can then be fixed and the final testing by the test house will just be a formality. We used that approach where I used to work.

    Leon

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  • Erik FriesenErik Friesen Posts: 1,071
    edited 2009-11-15 17:24
    Is all equipment, even industrial equipment, required to pass CE testing? Or does it have higher acceptable emmissions?
  • LeonLeon Posts: 7,620
    edited 2009-11-15 18:14
    It applies to nearly everything. You need to read the regulations to see what is exempt. CE EMC requirements are more stringent than those for FCC, in that immunity to external fields is required, as well as low emissions.

    Leon

    ▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔▔
    Amateur radio callsign: G1HSM

    Post Edited (Leon) : 11/15/2009 6:19:14 PM GMT
  • william chanwilliam chan Posts: 1,326
    edited 2009-11-15 23:45
    Oh no, my product has a mini-itx board with an Atom dual core processor inside.
    But my enclosure is plastic.

    Will it pass CE?
    Do I need to line the inside of the enclosure with metal foils?

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  • LeonLeon Posts: 7,620
    edited 2009-11-16 00:22
    You might be OK, it depends on how well the Atom board was designed. Where I used to work they have a 500 MHz Blackfin system in a plastic enclosure, but the PCB was very carefully designed. Nickel spray screening is often used inside plastic enclosures, and can be very effective. You will probably need to add filters to the cables, we had to do that on the RS-232 connector on the earlier system I designed with a much slower DSP. That was the only problem we had.

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    Amateur radio callsign: G1HSM

    Post Edited (Leon) : 11/16/2009 12:27:40 AM GMT
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