MEL PICBASIC Forum - RoHS Statement


  • RoHS Statement

    Crownhill Associates operates a quality system compliant with ISO9001:2000 covering all aspects of its operations. Crownhill are also able to manufacture products with full component level traceability where required by its clients. Our quality system and documentation are open to review by our clients at our discretion. The provision of high quality, consistent, safe and reliable products is of paramount importance to Crownhill Associates.
    Complete products are CE marked where applicable. We also provide advice to clients as well as professional engineering services to aid their compliance and approval programmes where our assembly-level products are being incorporated into overall systems or third-party products.
    We recognise the significance of ROHS regulations, it is our objective to ensure that all products supplied by Crownhill will comply with the requirements of 2002/95/EC (ROHS) on or before the due date, or will qualify for exemption.
    Some products may not be totally free of hazardous materials.
    Some products will contain components that are exempt or are exempt due to them being brought to market before 1st July 2006.

    Compliance

    To be compliant means to 'follow the rules'. In the case of material and substance restrictions such as RoHS, our product(s) do not exceed any of the thresholds or limits established in the market place. If our products were ground up and analysed by a chemical laboratory, the results would all be below the limits specified in the laws and directives of the countries or states of concern.
    To achieve compliance we:
    "Make certain that each and every component within all of our products is 100% compliant with the laws and regulations, as they are currently written and enforced, in all the markets we enter into". Our goal includes becoming and remaining aware of the global situation as restrictions change and evolve.

    What is RoHS?

    The Restriction of Hazardous Substances (RoHS)
    RoHS is legislation enacted by the EU parliament to control the distribution of certain hazardous substances. It is frequently pronounced so as to rhyme with 'toss'. While RoHS specifically refers to directive 2002/95/EC (see below) it is sometimes used to refer to more general cases of restrictions of materials and substances in various markets. Thus, to be 'RoHS compliant' may mean compliance with a larger set of rules
    The RoHS (and other legislation limiting hazardous substances) is critically important to the Electronics and Electrical Equipment (EEE) supply chain because of the severe penalties that can be directed at the OEM, reseller or importer who violate these rules and regulations. These penalties may be as extreme as a complete product recall from the EU markets. Not only would the recall itself be expensive, but the additional scrutiny of the violator's other product lines would be of concern, as well as the negative public opinion (a 'green' violation is frequently more serious in many European countries that it is in the US).

    RoHS, From the directive:

    DIRECTIVE 2002/95/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment….
    RoHS is a law (directive) that seeks to remove or greatly reduce a group of hazardous substances from electrical and electronic equipment and products. It specifically addresses the results of these hazardous substances in landfills and in the recycling process. A short list of substances is currently addressed, but one should not assume this is the end of legislation of this type.

    From the directive:

    1. Member States shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). National measures restricting or prohibiting the use of these substances in electrical and electronic equipment which were adopted in line with Community legislation before the adoption of this Directive may be maintained until 1 July 2006.
    Most Electrical and Electronic Equipment (EEE) is covered by this directive. There are few exceptions. Exclusions may include some military equipment, implanted medical devices, large factory floor equipment and some classes of computer storage devices. These are fully defined in an appendix of the directive, which you can find using the links to the directive itself provided on this page.

    Again, from the directive:

    Article 3
    Definitions
    For the purposes of this Directive, the following definitions shall apply:
    1. 'electrical and electronic equipment' or 'EEE' means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1,000 volts alternating current and 1,500 volts for direct current;

    The last concept we cover here is the idea of the 'producer' or responsible party. In general, the brand owner is the responsible party. Responsibility for unbranded products generally falls to most recent 'seller'. The actual text is reproduced below:
    2. 'producer' means any person who, irrespective of the selling technique used, including by means of distance communication according to Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997 on protection of consumers in respect of distance contracts
    1. manufactures and sells electrical and electronic equipment under his own brand;
    2. resells under his own brand equipment produced other suppliers, a reseller not being regarded as 'producer' if the brand of the producer appears on equipment, as provided for in subpoint (i); or
    3. imports or exports electrical and electronic equipment on a professional basis into a Member State. Whoever exclusively provides financing under or pursuant any finance agreement shall not be deemed a 'producer' unless he also acts as a producer within the meaning of subpoints to (iii).
    (3) OJ L 144, 4.6.1997, p. 19. Directive as amended by Directive
    2002/65/EC (L 271, 9.10.2002, p. 16).

    In summary, RoHS and similar legislation is changing the way EEE is designed, manufactured and distributed. The risks are high, and the cost of compliance is not insignificant.