Talk:Restriction of Hazardous Substances Directive/Archive 1

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Archive 1

RoHS - Batteries in- or excluded?

I read on Wiki that Batteries are not included in the RoHS directive. From the wiki article:

RoHS - section Details Note that batteries are not included within the scope of RoHS, therefore NiCd, Lead-acid and Mercury batteries are permitted despite the use of restricted substances.

This does not comply with the text of the Battery directive from www.defra.gov.uk:

Producer Responsibility: Batteries Directive - section Prohibitions The Directive also prohibits the placing on the market of any batteries that contain more than 0.0005% of mercury by weight; and of portable batteries that contain more than 0.002% of cadmium by weight. There are some exemptions to the prohibition for button cells containing mercury and for batteries containing cadmium, namely those that are used in emergency/alarm systems, medical equipment and cordless power tools.

My proposal is to replace the current wiki text with these lines.

- Marijn Bos, Delft, NL

Dear Marijn Bos (are you the same Marijn Bos on the Nederlands Wiki?!)

Good comments. I saw this too and added the part about the inclusion of batteries in the EU's Battery Directive. I think that's why you may not see some of these limits in the RoHS directive -- because there's a battery directive. The cadmium, lead, and mercury limits in batteries were listed in both the 1991 and the 2003 (approved 2006) battery directive versions. Since the UK limits you mentioned are the same as the EU's 1991 (and 2003 [1]) directive, the UK regulation may have drawn from the Euro battery directive. Though the quantities are the same, I'd hold off on from citing the UK directive since it does not have quite the same wording as the EU directive, and the EU directive's the one which will be homologated and harmonized to. England and other countries will ultimately comport to the EU directive, i.e., if they wants to sell products in the European Union.

The EU directives may seem toothless -- I think they're not really "laws," but serve more as guidelines for a kind of global honor system -- without much enforcement, a hope that compliance can be market-driven, accrediting the very manufacturers' test labs as capable of performing impartial self-tests and audits, allowing companies, whose may have a conflict of interest and whose neutrality may be in question, to self-certify, with final proof of compliance being their own Declarations of Conformity -- at least in the case of some of the other technical EU directives. This whole scheme may not be ambitious enough to satisfy some, in approaching a lead-free or lead-safe consumer world but, if one considers the vagaries of getting contract manufacturers to roll a highly dense, sub-micron multilayer board with good yields, in the face of problems encountered in the normal manufacturing process, lead-free solder will be quite an engineering feat, and more stringent recycling is perhaps a worthwhile parallel endeavor.

The lead-free goal difficulties and factors mentioned by others in this article, of which the EC is aware, may be why recycling is such a big part of its "solution," why the directive has such a long phase-in period (only 45% recyling in eight years), and why the commission is entertaining so many exclusions. One can say, "Let us just ban all lead in the solder!" but I don't think it's that simple. And, despite what the the directive says, I think this will be passed off to consumers. Though, this, like high gas prices, may be a good thing -- with people perhaps less inclined to waste or leave their electronic devices on street corners, once they've payed a little more dearly.

Please bear in mind I'm not an expert nor have I worked in RoHS regulation.

DonL 02:18, 22 October 2006 (UTC)

Logos/Symbols

I'd love to see some official logos. Hi-res. And a decent explanation about them declaring which is RoHS 5, which is RoHS 6, etc.

__________________________________________

Not sure what the RoHS marking/label copyright status is in publishing them here, but logos are available on the net:

This Google Images website has dozens of RoHS labels: RoHS images

Chinese ROHS logos

RoHs image with leaf

Another Google [2] search:

RoHS logo as watermark

German images? URL bar

DonL 04:52, 22 October 2006 (UTC)

References

Newark InOne provides the "RoHS Express," which provides RoHS information relative to Newark 's vendors at [3]. Newark is an electronics component distributor that highsides their RoHS-compliant vendors and distributed products. It is incorporated in Indiana, has 1300 employees, and a sister company in England.

DonL 06:55, 25 October 2006 (UTC)

How to create links to documents on EUR-Lex

At the http://eur-lex.europa.eu/en/tools/help_syntax.htm you'll find how to creat the perma link to the documents.

A lot of referred doc shall be soon not available —The preceding unsigned comment was added by 158.169.9.14 (talk) 11:52, 21 February 2007 (UTC).

Cost related closures

There are no de minimus exemptions e.g. for micro-businesses, meaning that some small businesses have closed down, citing the cost of compliance.[19][20][citation needed]

I added a citation needed tag as the reference given is one where a business has halted operations while they analyse the costs of the new EU directives. They don't appear to have come back. They may have decided they couldn't survive. Perhaps something else happened. We don't know. As such, a better reference is needed, at the very least a business which says they have decided to close down permanently because of the RoHS. Or better, a reliable source that says several small businesses have closed down because of it Nil Einne 11:44, 23 June 2007 (UTC)

Other lead regulation?

Is there any other information about lead regulation, in Europe or elsewhere, that we should know about?-69.87.200.233 18:10, 4 September 2007 (UTC)

There should be a whole article about Lead regulation. Until then, all we seem to have are Lead poisoning and Restriction of Hazardous Substances Directive. The main Lead article does not give us figures on total global production/use; we don't know how it is changing annually, over decades. We have been using this known poison for thousands of years. In the US, lead plumbing is still in use, and we are so negligent as to use it to balance the wheels on our cars. How does Europe compare? What organizations are most active against lead hazards?-69.87.200.233 18:53, 4 September 2007 (UTC)

69.87.200.233, you say that "in the US, lead plumbing is still in use." But I don't think that is correct, unless by "still in use" you mean that there are some 70 year-old pipes that still have water flowing in them (which is true in the USA as it is in most of the world). If by "still in use" you mean still being installed, then that is not correct. I don't think there has been any new lead plumbing installed in the USA since approximately WWII. More recently, even tin-lead solder for copper plumbing has been replaced by lead-free solder (which, I can tell you from personal experience, is a whole lot harder to use). NCdave 17:58, 5 September 2007 (UTC)

NPOV concern with reliability section

Without commenting on the accuracy of the tin whisker phenomenon - I'm not qualified to speak as an expert - I do take issue with the inflammatory nature of the examples used to document the risks derived from tin whiskers. I see that there is a source cited for the nuclear power plant issue. However, the list in the subsequent sentence - "satellites in orbit, aircraft in flight, and implanted medical pacemakers" - sounds like a who's who list of scary applications designed more to frighten than inform.

If there are sources for these additional failures, please add them to the article. Otherwise, I think the article's neutrality on the whole would be improved by removing this sentence entirely. (I'm not going to remove it because this isn't an article I typically maintain, and I have no interest in a neutrality fight.) Does anyone else agree that this sentence, without sources, seems needlessly inflammatory? N Norder 23:50, 12 November 2007 (UTC)

I think this sentence has now been adequately sourced. — EagleOne\^Talk 03:13, 13 November 2007 (UTC)

If there are concerns as to the accuracy of the risks statements, may I recommend following one of the links to the NASA studies on the same topic. They have been engaged in the whisker studies for safety reasons in their systems that have to continue operating for prolonged periods of time. Whiskers are a real phenomena, and wishing it to not be so will not make it go away. If you have questions about what it means, just look at the illustrative picture that's part of the section -- pure tin vs. tin-lead. Aki Korhonen 18:05, 13 November 2007 (UTC)

I agree the examples are inflammatory and out of context. The preceding sentence implies they are failures due to the new lead-free solder formulations, when in fact they are incidents predating RoHS. One is not even a solder failure, but a tin plating issue. I suggest we move this to the tin whiskers article and find better citations. Prosecreator 16:52, 14 November 2007 (UTC)

I disagree for the reasons I stated previously in my talk page. There should be a statement that the examples are of tin whisker growth in high-tin-content formulations and not in the particular lead-free solders, but it should also say that these examples can provide a good indication as to what long-term reliability can be expected from the new lead-free solders that are also high tin content products. I can't state this as an absolute as I haven't reviewed every solder out there, but as I understand it, every SAC lead-free solder exhibits whisker growth, albeit at rates that are seen as acceptably slow for consumer applications. The problem is that changes to the atmosphere or chemical contamination even in minute portions can speed the whisker growth to rates that cause premature product failure. Quicksilvers concern is well placed, in that such failures in safety critical applications can be catastrophic. Aki Korhonen 16:54, 15 November 2007 (UTC)

I added a sentence and reference that mentions that there are ways to mitigate the whisker effect. We could use more examples, e.g. slower temperature rise. I like Aki's suggestion, someone could elaborate that the citations are not of the post-RoHS formulations. —Preceding unsigned comment added by Prosecreator (talk • contribs) 17:42, 15 November 2007 (UTC)

AlphaSTAR Image

I'm adding this section here to underline the change made today by procecreator. I agree that the image is not replaceable with any other from "free" sources, or from sources that would provide a "free"-like license. The images are taken with a microscope of laboratory samples that are highly unlikely to be reproduced by an entity that would license its images on any basis other than the source from which prosecreator obtained this sample. (This is a nice way of saying, please back down, picture police, and read my user page.) Aki Korhonen (talk) 17:49, 19 November 2007 (UTC)

Swatch exemption

I dug up a related summary (http://www.orgalime.org/issues/RoHS_EU%20Overview%20Exemption_Jan07.pdf) and found that Swatch had asked for two exemptions, and got only one. They asked for the crystal and the fine pitch BGA to be exempted. The decision was to allow the exemption for fine pitch components, and is now exemption number 23. Swatch was not named in the decision, but the exemption is reflective of their request and no other request for fine pitch components was present (at least as far as I can tell). Swatch also resubmitted the crystal exemption for the next round. Aki Korhonen (talk) 20:04, 19 April 2008 (UTC)

Good find. It appears as if the fine pitch exemption originated from HP (Hewlett-Packard), not Swatch, and it was already recommended in a more specific form, here's what the German Oko-Institut Consultant to the EU says:

"The consultants already reviewed HP's whisker-related exemption request from the second stakeholder consultation to use lead-containing finishes for fine pitch components with a pitch of .65 mm or less and gave a positive recommendation to the Commision... It is therefore recommended not to grant an exemption for the general use of lead in solders of electronic modules used for quartz movements and watches."

So if I understand this right - both exemptions from *Swatch* were advised to not grant the exemption and therefore our Swatch section is probably inaccurate. Also, this quote from the consultant is also interesting:

"The applicant had produced such modules for his watches with the RoHS conform Sn96.5Ag3Cu0.5 and the Sn95.5Ag3.8Cu0.7 solder and so far has not observed any whisker problems in fine fine pitch components. The SnAgCu solders are more whisker resistant than the SnCu solders, which - in his original exemption request - the applicant had claimed to use."

I see no evidence of a recall, either. Prosecreator (talk) 03:30, 20 April 2008 (UTC)

I haven't found anything additional about the recall (yet), and based on the quick failure mode (6 months), it might be that they recalled product from distribution, not from the field.

I found some additional information, though. This link http://ec.europa.eu/environment/waste/pdf/rohs_report.pdf includes a consultants opinion and description on the Swatch topic to the EU body on RoHS exemptions (starting at page 83). His recommendation is to skip the Swatch request, because they believe the crystal stuff is not needed, and the fine pitch BGA stuff is already covered by the HP request. So the key from Swatch for fine pitch exemption, was actually bundled with HP and approved. Swatch apparently continues to use their 95% Pb solder alternative for the crystals, and as we know from the other document, they have renewed the crystal solder exemption request.

But here's a kicker: the annual use lead before RoHS by Swatch was just 20 kilograms (40 pounds or so) per year. So all this hoopla and cost is being incurred for the equivalent of 3 or 4 car batteries worth of lead! I also ran across this link http://www.gsaservice.com/impact_of_lead-free_initiatives_pax_river_11-13-07.ppt that talks about TI's entire annual contribution of lead prior to RoHS being equivalent to 10 car batteries.

This is also a cool report with many great pictures, and a reference to the Swatch issue on page 35: http://nepp.nasa.gov/whisker/reference/tech_papers/2007-brusse-metal-whiskers.pdf .. it has an interesting Swatch reference on Page 40, consistent with what I had mentioned some time ago about allowing a lesser percentage of lead in solder to help with the main reliability issue the industry is now facing.

And finally, the discussion on page 10 of the NASA report talks about how in the right setting a tin whisker will turn to plasma, and allow hundreds of amps to pass, instead of the 30mA or so that's normally noted, with a picture of a relay that shows what happened. Interestingly, I had a similar failure mode on a relay for the airconditioning control unit in my house, and now I'm beginning to regret getting rid of the part before taking it apart and looking at it under a high power microscope.

So the Swatch discussion needs to be adjusted slightly, but it seems that it's fundamentally accurate. Someone might want to add some of the other information to the RoHS article and tin whiskers article, too. Aki Korhonen (talk) 18:35, 21 April 2008 (UTC)

I have a hard time believing that GSA Service presentation - here's a good counter-example: The Sylvania lighting Manchester, NH lamp plant eliminated a major lead wave solder operation, a process that consumed several thousand pounds of lead bars and 3,500 pounds of lead waste per year: http://www.sylvania.com/AboutUs/EnergyAndEnvironment/OSIEnvironment/EnvironmentalAchievements/OSRAMSYLVANIA/ProductImprovement/MercuryReduction

Can you modify or remove the Swatch section? I guess the whole thing is really debatable based on what we've found -- Swatch didn't get a permanent exemption from anything, and there's no evidence of a $1 Billion dollar recall. It's definitely misleading. Also, we don't know what solution Swatch went with for their two requests - I can't find evidence they chose the high-lead formulation - they just said they'd be forced to use it. However, the consultants found an alternative, so perhaps they went with that... Prosecreator (talk) 15:13, 22 April 2008 (UTC)

I don't see how the Sylvania switchover disproves the GSA presentation. Sylvania doesn't say that the transition was easy or trouble-free.

You are correct re: Swatch, we don't know if they switched from a €0.05 to a >€0.70 crystal module, which is also larger. It's possible they did. It seems unlikely. The consultants found an alternative that was not very attractive, and which seems especially pointless when you consider that it's 2kg/year of lead that we're talking about. Bhimaji (talk) 17:04, 22 April 2008 (UTC)

I think you make a good point -- but as with all laws and regulations, one hopes the positive outweighs the negative. It won't be perfect. In Swatch's case the benefits might be debateable, but certainly for Sylvania, they're positive. That's why the EU has an exemption process -- but they're trying not to go overboard. Back to the Swatch section -- it doesn't appear to be accurate and needs to be modified. I can "fix" it if no one says otherwise. Prosecreator (talk) 18:23, 22 April 2008 (UTC)

[unindent for readability]

I made proposed changes to the Swatch reference, and I added the whisker plasma failure mode also. I was about to add the Sylvania discussion when I realized that the changes that produced the lead reductions for the most part (or perhaps entirely, I haven't been able to confirm) took place before the RoHS directive was instated, e.g. the 1990's. Also, the lead solder in this case is not the same as solder used for circuitboards, which is our discussion here. (I will digress and say that the Sylvania example has gone from a good example to yet another one showing how poorly thought out the leadfree solder requirement is. Prosecreator, I also disagree with your statement as to positives and negatives, if the reductions from TI are measured in 10 car batteries per year, those from Swatch in what appears to be 6, and so on, when contrasted to the millions of car batteries that are produced each year. It is plain stupid to look for reductions in the hardest place imaginable only for feel good value.)Aki Korhonen (talk) 17:43, 23 April 2008 (UTC)

[unindent for readability] Ouch - please don't get personal, I know you feel strongly about this. Unfortunately, many of the examples in the criticism section pre-date RoHS, e.g. the nuclear power plant, satellite failure, Napolean :), etc - I think their inclusion is questionable. Sylvania is subject to RoHS now, and we're talking about RoHS right? Light bulbs are included. Keep in mind car batteries generally have a high recycle rate (nearly 100%) - so you're comparing apples to oranges. I think you've added some misleading information - your consultant reference is great, I went over it carefully and here's what you added and why I think it's misleading or incorrect (italics are mine):

"For the denied part Swatch has stated to be using a replacement solder that is almost pure lead, and its application was for permission to switch to a solder with a lower lead content" -- Reference 35, page 96 says that: "The applicant [Swatch] said he would continue to use high-melting lead-tin solder alloys with more than 85% of lead... After critical inquiry concerning the technical viability of this solution, the applicant admitted that this is not a viable option. The applicant had produced such modules for his watches with the RoHS conform SN96.5Ag3Cu0.5 and the Sn95.5Ag3.8Cu0.7 solder and so far has not observed any whisker problems in fine pitch components." What you say is factual, but misleading - Swatch admitted they were bluffing.
"Swatch responded to this by applying for exemptions to RoHS compliance for two components. One of these exemptions was effectively approved, with the other still pending after an initial denial" -- Reference 35, page 93: "The second part of the request is related to the HP request from the second stakeholder consultation to exempt lead in finish of fine pitch components... By contrast, however, this exemption request focuses on the solders used to attach fine pitch components..." Both were denied, the HP request is not the same as the 2nd Swatch request and I see no evidence that anything is pending.
"Swiss Swatch watches in 2006, reportedly triggering a $1 Billion recall" -- I have a hard time with this. I know the UK Guardian says it, but your EU consultant reference suggests there was no recall and how could they have such a substantial event and not mention it to the EU? This is FUD, in my view.

Also, there's some great stuff in that reference about how the auto industry is moving to lead-free to achieve high reliability in high temperature environments as electronics are being moved to the engine bay. I'll try to add this to the Pros section. Prosecreator (talk) 20:11, 23 April 2008 (UTC)

Should there perhaps be an article specifically on the subject of lead in solder? I think that a company switching away from lead in a way that will supposedly cause problems is relevant even if it were done 30 years ago. Equally, problems with materials that are similar to those being used for RoHS compliance are relevant no matter why they were done.

If you avoid lead coating due to RoHS or you avoid it due to concern about fully hot-dipping a sensitive module in solder - the whiskers don't care what your motive is or what decade you're in.

This article gives me a sense of deja-vu back to some articles about the company I work for. We had top-quality straightforward primary sources for information, but we had people complaining they only wanted secondary sources. That is Wikipedia's policy. Unfortunately, as you can see in this article, sources that would usually be considered authoritative primary sources appear to have accuracy and reliability problems.

We need to figure out how we are going to deal with this sourcing problem now, and moving forward.

The reason I initially put the Swatch info back in to the article is because, when I looked around to see what I could find, I found many poor sources of contradictory information. I saw too many people arguing about whether this specific exemption was related or not, etc. etc. Too many non-notable people who didn't seem to understand the rules. That's when I try to focus on reputable publications. Sadly, in this case it seems like that hasn't worked. Bhimaji (talk) 23:22, 23 April 2008 (UTC)

I agree Bhimaji, an article on lead in solder would be good. The RoHS article has gotten derailed with poor sources and a focus on only one element of the directive - lead. I think the consultant to the EU commission on RoHS exemptions is a great reference on the Swatch issue and it trumps the UK Guardian or any other reference I can think of - that's why I worked hard to explain above and tried to remove the Swatch section - I'm glad you read it. I'm losing my confidence in Wikipedia and this article. We're citing anything we can Google on - e.g. corporate PowerPoint presentations and mom-and-pop company web sites just to add another item to "prove" that leaded solder is the answer. When a general newspaper article is chosen over a good, solid reference from experts in the field, we have a problem. We need to rethink the solder portions of the criticism and pros sections and stop adding poorly-referenced material that is misleading, or is just an assertion someone found in a forum somewhere to prove their point. Prosecreator (talk) 01:55, 24 April 2008 (UTC)

Prosecreator, sorry, I didn't mean it personally, and I certainly didn't want to imply that you were stupid. I intended my comments in a more general sense, and aimed them mainly at the process that allowed RoHS to approach lead in solders. I am a supporter of reducing environmental loading by industry, but it just amazes me when it happens in all the wrong places. ;) ... but to the discussion now.

the Swatch details. It seems that there's a lot of conflicting information here. There's a bit too much smoke for the Swatch issue to have been mere posturing. For example, if they find a 5% failure rate for the crystals within 3 months, and a 10% (if I recall correctly) for the BGA parts within 6 months, it seems to imply product in the field and a related cost to get it back and replace it. I also don't buy the explanation about the high-lead solder not being viable, as I believe that tuning fork crystals using that solution are out there. At first glance (which I'll repeat when I get a chance in the next few days) it also seemed to me that the effective result of the HP exemption is to allow Swatch to get a small infusion of lead into their solder during reflow. Anyway, I'll need to look into it a bit further and will eliminate the reference if it turns out to be nothing, or provide another round of references and proposed terminology.
more on Swatch: I also note that the report from the consultant is actually somewhat misleading, because it seems to mix up the discussion on the BGA exemption and the crystals. For example, the italic quote you had in bullet number 1 discusses fine pitch components (BGA) and their solders, but the crystal issue occurs inside the crystal enclosure, not in the fine pitch components as referenced. It might indicate that the consultant did not fully review this topic and didn't necessarily understand the issue. I'll read this part again later on, too.
Second Swatch request for exemption: this is in one of the references I provided earlier. I believe it was http://www.orgalime.org/issues/RoHS_EU%20Overview%20Exemption_Jan07.pdf
about Sylvania. The difference between the Sylvania example and the others is that Sylvania reduced its usage on its own. Thus the RoHS regulation -- as far as they were concerned -- had little impact. The other examples you mentioned are related to technologies that are now forced on the industry by the lead-free requirement, and are thus rightfully present as they describe relevant impact caused by RoHS. Perhaps they should be underlined as an "I told you so" if the worst (or even the middle of the road) predictions of shorter lifespan electronics bear true.
about car batteries. Yes, car batteries are recycled for the most part. But thanks to WEEE and other electric waste regulations, and also the increasing content of valuable metals and their rising market prices, so are circuitboards in ever increasing amounts, too. I would wager a guess that accidentally broken or intentionally thrown out car batteries cause multiples of the lead releases into the environment than all the SnPb solders would do if they were universally used today and simply poured on the ground. For example, with thousands of serious car accidents per year in the US alone, what happens to the batteries that are turned to mush when the impact-absorbing frontal area collapses?
please add all the material you can to the pros section. We don't want the article to look like drawn out whining about the lead-free requirement.
Bhimaji, sources of information: I agree that there's a bit of conflict in the information presented. The sources seem to be in a bunch of buckets: the politically motivated, the imperial scientific releases, and sensation hunters. We need to identify the first and last categories, but how can one do that when even the apparently scientific sources so often degenerate with a hint of political motivation for a particular outcome. The best source is likely the scientific community and those motivated by accuracy. This is why I like the NASA stuff, but it's still a bit early for someone preparing a paper on the long term impact of the lead-free solders. IPC appears to be launching a study for its members to gather information about short-term reliability issues, the results of which will likely be published early next year. NASA keeps adding cool information based on their studies.
Bhimaji, it seems that solder dipping is not really a solution for modern electronics manufacturing. Most parts are surface mount and solder is used in minute amounts. The only obvious things that are exposed are connectors, but those are mostly plated for wear-resistance. Interestingly the NASA article states that only a small percentage of lead is needed to effectively eliminate whisker growth.
any comments on the whisker ionization failure mode? Awesome pictures.
Finally, a separate article on lead-containing solder might be interesting, but I for sure wouldn't have the bandwidth to keep reviewing that on top of everything else. My personal vote would be to try to keep the discussion from sprawling too much, keeping it focused on RoHS, and if we need to talk more about whiskers, throw it over to the whiskers article. However, the lead-free solder requirement is one of the most costly aspects of RoHS to industry, well beyond the expectations of those who were drawing up the RoHS regulations, and thus definitely must be covered. Perhaps the lack of other broad negative comments to RoHS indicates that for the most part RoHS is accepted, but it took a misstep in this area.

Aki Korhonen (talk) 02:13, 24 April 2008 (UTC)

(Comments primarily directed at Proscreator)

The problem with reference quality includes references from both sides, I think. Many of the EU reports are very dense publications that require somebody with both technical and procedural experience to fully interpret. Many people seem to be very confused about the details of what exemptions were asked for, which were granted, whether the granted ones were a superset of the ones asked for, etc. etc.

You yourself earlier commented that the consultants had outlined alternatives that Swatch could use. However, those alternatives were not very good ones. They also weren't very precisely described.

Figuring out if the consultant's alternatives for Swatch were reasonable or not would require an understanding of the production costs of watch modules, as well as an understanding of how much bigger the replacement modules would be. Those two issues could be the difference between, "they could switch to ceramic with minor inconvenience," or "nobody in their right mind would make the switch. The watches would be huge and expensive."

That's why Wikipedia tries to go for secondary sources. Because many primary sources require expert analysis to properly understand.

Wikipedia does not have a good system in place for dealing with a field where there is insufficient secondary sourcing.

Aki:

I found the ionization material very cool looking.

I suspect that things aren't as bad as the worst fears suggest, since we don't seem to be seeing the expected bad results. Last week I was flying, and sat next to a gentleman who trains people to solder according to various official industry standards and certifications. He seemed extremely knowledgeable about a lot of the low level details; in his experience, he didn't consider RoHS to be a significant problem. He was dealing with a lot of aerospace and other high end contracting work, so I would've thought he would've heard lots of complaints.

Not a citeable source, I know, but I figured I'd mention it.

My suspicion as a non-materials scientist, from what I have read here and elsewhere, is that there are likely to be some areas with significant problems, but they will only be a minority. I just hope we find them before they become serious. If Nokia's cheapest phone model gets whiskers, that's going to be terrible on the environment.Bhimaji (talk) 02:26, 24 April 2008 (UTC)

Aki and Bhimaji, thank you for the thoughtful comments. Perhaps we could move some of the tin-whisker stuff to the tin-whisker article and more briefly address it here. It's amusing to me that I'm typing this text on a RoHS computer with RoHS speakers and monitor and a RoHS compliant laptop nearby. I believe my digital camera, televisions, wireless phones, and Playstation are all compliant too. Even my guitar stand has a RoHS sticker on it - although it says "RoHS exempt." ;) So, if I believe the criticism section, my computer will blow up in my face any minute, followed by my disintegrating Playstation - knock on wood. :) As Bhimaji's acquaintance mentioned, I think we'll look back at this and wonder what all the fuss was about. Please let me know what you find Aki, and Bhimaji, if you have suggestions on what we move or change please speak up. Prosecreator (talk) 02:56, 24 April 2008 (UTC)

Prosecreator, as to lead-free in my PC and everything around me, absolutely here, too. I don't expect an imminent failure of every device around me. The issue is a statistical increase in failures and a decrease in product lifespans that invalidates the reasoning for lead-free in the first place, and creates more environmental load. I'm not approaching this as someone trying to protect something that creates waste, but rather I'm trying to keep the baby from being thrown out with the bathwater. In the case of lead-free solder the jury is still out, but the questions coming out of chambers are causing a lot of concern. I'm reviewing related documents right now and will post more when/if I have something new.

Bhimaji, I tend to agree that the issue is not the end of the world at the moment. I'm very involved in the PC field and while I have some anecdotal evidence (definitely not citable) as to what appears to be an increase in issues with unknown origins (typically the field of bad solder joints and such), there is no tsunami visible, at least not yet. Given another year, I'll hope to join everyone in a sigh of relief, except those occasions when I'm forced to fly on aircraft equipped with RoHS compliant avionics and systems. ;) Aki Korhonen (talk) 05:08, 24 April 2008 (UTC)

[unindent]

Ok. Here's the scoop:

The consultant makes it very clear on pages 83, 86 and 88, that he considers the BGA request from Swatch and HP related, and that the only differences are Swatch asking for the limit to be raised to 0.8mm pitch from 0.65mm and that also solder be exempted. The consultants view is that the HP exemption on Pb finish should be sufficient to reduce whisker growth. This is also where the comments are made as to Swatch admitting that their continued use of a high Pb solder was not practical.
The discussion about the crystal exemption is for Swatch to go back to the pre-RoHS 90%Sn 10%Pb, from the current composition of 95%+Pb. The consultant doesn't disagree that Swatch can continue doing so, but believes that because he was able to find one alternative supplier on the internet who claims to make the same part in lead-free that there is no cause for an exemption. The consultant also states that Swatch should consider how environmentally friendly it wants to be, implying that Swatch not trying (and with the experiment failing -- badly) to use Pb-free is somehow not responsible.
I have found nothing specific to a recall from Swatch. The annual reports from 2005 and 2006 don't seem to reflect anything either. I still need to hunt down 2007 to see if anything is in there.

Summary: no call to change the Swatch section quite yet. Aki Korhonen (talk) 07:33, 24 April 2008 (UTC)

[unindent] I think we can leave the Swatch section in for now, after learning more. The issues left in my mind are: Did Swatch move to the high-lead version? The consultant says they admitted it wouldn't work. Was there a $1 billion recall? I think there was a recall but $1 billion seems high. I'd still like to yank most of the whisker stuff and move it to the whiskers article where it belongs.Prosecreator (talk) 21:00, 24 April 2008 (UTC)

Exemption 23 for fine pitch component finish

I'm writing this as a new section, because the previous Swatch discussion became too long.

Exemption 23 seems to be a very powerful one (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:283:0048:0049:EN:PDF), in that it allows for a Pb finish on components with a pitch of 0.65mm or less, and a lead material of either copper or NiFe. This seems to include most of the modern lead-less components, from BGA parts to QFN's and such. While it's not a permission to use Pb in the solder, during reflow the Pb in the finish will mix with the solder and will likely greatly diminish whisker growth. I don't believe it has an impact on brittleness, though.

More to follow. Aki Korhonen (talk) 05:29, 24 April 2008 (UTC)

I don't think this is criticsm. Don't you think this really shows how well RoHS is working to mitigate problems? They have an exemption process that addresses issues. My guess is industry will find a pb-free solution soon enough for fine-pitch components on copper or NiFe leadframes. We just don't understand whisker growth very well right now. Prosecreator (talk) 21:11, 24 April 2008 (UTC)

North American impact?

It would seem like this article could go into a bit more detail on the North American impact...even though RoHS isn't the law in most of the US, my limited understanding is that it has had a very very large effect on the US electronics industry (in part because of products for export), and has to some extent fundamentally changed the way that industry does business... jhawkinson 02:39, 18 August 2007 (UTC)

The North American impact will be in the form of unavailability of electronic components using eutectic tin-lead solder in their lead frames, since most component manufacturing has been moved offshore to Asia, both that of North America and Europe. A high percentage of assembly has been moved offshore as well. Asian component suppliers are rapidly converting to lead-free processes due to RoHS in Europe. Their focus is low-cost consumer goods with short useful lives, not high reliability goods for mission-critical applications. We will rapidly approach a point where the diminishing demand for proven parts with tin-lead coatings will be too small a market segment for manufacturers to bother serving, and they will drop them entirely. When that happens, military, aerospace, medical and industrial users in North America will be forced to use lead-free parts. The only way to avert this would be to maintain a manufacturing base for high reliability parts in North America for North American needs, while the rest of the world goes to hell in a handbasket. —Quicksilver^{T @} 19:05, 26 October 2007 (UTC)

Quicksilver's comments are interesting as there were some, I would say a vocal minority, who predicted doom and gloom with the implementation of RoHS. I think the Pros section addresses this and has references like "The Good news is the Bad News was Wrong." Some companies have been compliant since 2001 and the predictions of widespread failure haven't happened - when can we finally move on? Prosecreator (talk) 01:08, 25 April 2008 (UTC)

Inconsistencies in EU consultant reports

I've reviewed a few reports to find more information about the Swatch topic, and couldn't help noticing some incredible "facts" that I can't understand how they were derived at:

Document http://ec.europa.eu/enterprise/environment/reports_studies/studies/draft_rep_study_rohs_directive_dec07.pdf that is supposed to be a status report of the impact of RoHS. It provides some numbers, but they appear to be -- at least in the space of the industry that I'm familiar with -- grossly inflated:

Page 55, the document claims that a PC has between 463 and 972 grams (1-2 pounds) of lead, reduced to 447-510 grams (about 1 pound) under RoHS. I've been trying to figure out where that amount of lead could be hiding in the vast majority of PC's that I know of. There's some in a display, but those appear to be accounted for separately, and even if not, the notebook numbers -- with a change from 50-80 grams down to 5-14 grams -- indicate that the display is not a big factor.
Page 57, the document summarizes the lead savings in scenarios that do not properly compare the values. The "average" is not a comparison of the estimated pre and post ranges, but rather the estimated high's and lows' to each other. This provides for an inflated range of potential savings even if not considering the other factors above.
Page 58 claims that an average PC weighs 21 kilos, or 40+ pounds. I don't see how anything but a fully tricked out PC could get anywhere near that weight, let alone going beyond it. This here might be the root of the problem for what appear to be outlandish claims on page 55, if "they" were combining an inaccurate weight "estimate" with a mere percentage by weight for PC's.
Page 59 to 61, the document goes on to claim that PC lead content was reduced by 50%
Page 58 again: the various PC related claims, combined with the claimed 28,000,000 units allow the EU to count an estimated 14,000 tons of lead saved from PC's. There is no indication of timeframe either.
Page 63: summarizes lead avoidance for PC's to be 7000 tons at a 50% lead reduction rate. This is inconsistent with the earlier tables on page 55 that showed per unit savings to be between 12 and 500 grams, but a 50% reduction was only possible at the highest end of the scale, 500 grams per unit. That combined with the stated volume of units from page 58 means that this table should reflect 14,000 tons in reduction.
Page 73: this page shows yet another set of numbers for lead reduction from PC's. Now it's from 18.6 tons down to 9,7, i.e. 8.9 tons, with the same number of units as shown earlier on page 55 (28 million units). This implies a claimed reduction in lead from 664 grams per PC to 346 grams, well below the number published on page 55 and inconsistent with page 63. [AK Addition] I missed the fact that this table is supposed to show the amount of lead released into the environment. This means that combined with the prior table showing that 68.5% of PC weight is disposed to environment, the totals are now close to the maximum numbers from the various scenarios on page 55 to 61, though without comment as to why the maximum was chosen.
Page 76: the expectation is that the service life of a PC is 6 years. I wish I could still use my 2001 era PC and feel that it can run anything properly, let alone still function. I'm not sure how this number was derived, but it certainly doesn't appear accurate.
Page 156: now the numbers that were previously (see above) maximums are characterized as average benefits.

Summary: I'm amazed that the EU would make policy based on information that appears this shoddy. If this was the basis for the lead-free solder part in RoHS, I'm no longer surprised how the decision was made.

More to come Aki Korhonen (talk) 06:00, 24 April 2008 (UTC)

Edited the above table with more detail Aki Korhonen (talk) 06:06, 24 April 2008 (UTC)

And just a little more Aki Korhonen (talk) 06:30, 24 April 2008 (UTC)

Aki - could you fix the document link, I'm just getting a list of exemptions, I don't see any of this. Their PC lifespan should be smaller - but this only shows that the problem RoHS addresses is even worse - I believe many government agencies use a 4-6 year refresh. Their figures for lead reduction are difficult to assess, but you've got pb in displays, wiring, plastic, solder, and finishes - and pb is very dense, so I'm not as skeptical as you are. If they included lead in CRTs there would be a much bigger difference, of course. Prosecreator (talk) 20:56, 24 April 2008 (UTC)

I just fixed it. Here is again for convenience: http://ec.europa.eu/enterprise/environment/reports_studies/studies/draft_rep_study_rohs_directive_dec07.pdf Aki Korhonen (talk) 22:40, 26 April 2008 (UTC)

Failures of Leaded Solder

Just read the other day about Honda recalling 561,000 vehicles in 2006 where solder in faulty parts melted and gave minor burns to drivers. I wonder if RoHS could have prevented this as the newer formulations have better high temperature tolerances. http://www.edmunds.com/insideline/do/News/articleId=115758 Prosecreator (talk) 02:45, 25 April 2008 (UTC)

Interesting article. In that setting I wonder what are the possible causes for only the solder getting heated sufficiently to the point that it flows and drips? One explanation is a short circuit. Assuming that, it sounds like it was not triggering a fuse or perhaps it took place from the bus bar directly, which would make it quite serious. I'd say that one more way to look at it is that perhaps the only thing that kept the entire vehicle from going up in an electrical fire was the fact that the solder melted and broke contact. Aki Korhonen (talk) 23:20, 26 April 2008 (UTC)

Tin phase transformation

Can someone explain why this is in the RoHS article? I don't see its relevance. The references predate RoHS, one by nearly 30 years, the other from the 1940s. I will remove it if no one can find a justification for its inclusion. Just because tin cans failed does not mean anything. :) Prosecreator (talk) 02:31, 25 April 2008 (UTC)

I added the article with its link because it is relevant. The specific reasons and circumstances under which tin phase transformation takes place are poorly understood, as the article points out. With high tin content solders we might find combinations that appear to work well for some properties (e.g. whiskers), but not know that these might fall to the transformation problem in the long term or in certain environments (e.g. colder climates).

The effect has been known for a long time, but this doesn't change its relevancy to the RoHS legislation that might allow tin phase transformation to cause additional havoc in modern electronics. I would feel differently if we could understand and predict tin phase transformation accurately, and authoritatively state that there is no way it could take place in a RoHS impacted solder.

The uncertain nature of tin phase transformation is shown in the article that I linked to, written by an authority in electronics component manufacturing, published in a magazine focused on surface mount components and manufacturing. Aki Korhonen (talk) 23:07, 26 April 2008 (UTC)

Ahh...I don't have access to that article. This is a phonemonen in pure tin solders though, right? Your section implies it is only pure tin related, perhaps you could add a bit more detail to tie it to RoHS, otherwise we could put it in the whiskers metallurgy article. Prosecreator (talk) 05:14, 27 April 2008 (UTC)

It also takes place in some alloys of tin. The problem is predicting which alloys have it. Right now it's at the less-than-scientific "if you shake it like this, it won't" -stage. I tried to find a link to the 1981 paper, but it seems to be only available on a paid basis. The AP article is here: Tin Pest in Tin-rich Solders, Advanced Packaging, November/December 2006, Glenn A. Rinne. I'll add that link as a reference to the related paragraph. Aki Korhonen (talk) 17:32, 27 April 2008 (UTC)

I found another direct discussion of it here: http://klabs.org/richcontent/Reliability/plague_general/tin_plague_jan_2005.doc It makes the following conclusionary statement:

"Lead-free solders have a vulnerability to tin plague - the disintegration of solid tin into powder after prolonged exposure to temperatures below 13° C (56° F). Alloying tin with at least 5% lead or 0.5% or more of antimony or bismuth are effective ways to prevent tin plague. Until more is known about the performance of lead-free tin solders, they should be avoided in applications where reliability and long life are important."

Aki Korhonen (talk) 17:41, 27 April 2008 (UTC)

Effects of Pb substitution in solders

The EU document http://ec.europa.eu/enterprise/environment/reports_studies/studies/draft_rep_study_rohs_directive_dec07.pdf has an interesting admissions on page 77:

"It can be concluded that substitution of Pb in solders by other substances (lead-free solders) can also negative environmental effects, next to the positive environmental effects of Pb substitution (Kindesjö, 2002; Schoenung, 2003; US EPA, 2005; Deubzer, 2007). Only the relevant end results are mentioned in the paragraphs below."

"On the other hand, lead-free soldering increases the energy consumption for around 40 %. It requires an additionally electricity output corresponding to 4 to 10 % of the capacity of a nuclear power plant, or around 20 % of a hard coal power plant."

"The main drivers of energy consumption both for tin-lead and for lead-free soldering are the soldering processes, in particular the wave soldering processes. The higher melting points of most lead-free solders aggravate the energy consumption problem. The increased energy consumption for the metal mining and smelting, in particular of silver and of tin, add to the problem. More efficient soldering ovens and effective recycling are necessary to reduce the energy consumption (Deubzer, 2007)."

Then on page 78:

"As can be seen in the figures below, some environmental and human health impact categories are scoring negative for the Pb-free solders. The landfill space use for Pb-free solders is substantially higher then the SnPb solder."

And on page 108:

"Higher energy costs Because of the higher melting temperatures of lead-free solders, the energy use is expected to rise. Deubzer calculated energy costs would rise by € 11 million or 19%. However, the additional use of energy is judged to be only a minor factor in the total costs increase (Deubzer, 2007). More than half of the SME’s in the GreenRose project explicitly stated that their energy costs increased by 3.6%; 10%; 13%; 27% and 30%. In the framework of the GreenRose programme, 3 out of 8 SME’s indicated they suffered from a decreased throughput. One company stated production capacity decreased by 7% whereas another company believed the throughput decreased by 2.5%. The reason for this it that the heat transfer rate can only to a minor degree be increased via higher peak temperatures. The number of soldered PWB’s per unit of time thus has decreased. The lower throughput and the higher energy consumption are closely related and partly overlap (Deubzer, 2007)."

And on page 134:

"The increased use of tin solders has had its own implications for the overall tin market however, with prices of tin rising significantly in recent years to cope with the increased demand for tin solders. Stundza16 points out that the price of tin has surged in the past four years. Among other reasons (increase use of tinplated steel in China, bans on exports from unlicensed tin mines in Indonesia), his article points to the stimulation in demand for tin as a result of the ban on lead in electrical components enforced by the RoHS Directive. The marked increase in prices between 2003 and 2007 can be seen in the following graph (Source: London Metals Exchange)."

Now if someone could weave that information into the article without overwhelming the rest... Aki Korhonen (talk) 06:25, 24 April 2008 (UTC)

Aki - Please don't put any of this in the article - it's much more difficult to remove content than add it, and we already mention several lifecycle studies. I think we need to be careful about picking and choosing information from these reports. I have read the EPA and German studies and they warn against an overall conclusion which is complex to assess. Here's a quote from the EPA spokeswoman Ernesta Jones on their study:

The report contains the life cycle assessment results for tin-lead and lead-free solders, in both bar and paste form, for 16 impact categories. In some of the categories, the lead-free solders are expected to have greater [environmental] impacts than the tin-lead solders, while for other categories the opposite is true.

In the "toxicity impact" categories, all of the lead-free solder alternatives had a better life cycle analysis score than the tin/lead solders. By comparison, if "energy use" is the primary criterion, lead-free solders have more harmful environmental impact.

She warned about making conclusions either way, "because that can only be done by weighing the different impact categories.” Prosecreator (talk) 20:34, 24 April 2008 (UTC)

I fixed the link in this section as well. (It's the same study as from the previous section.) The reason I'm adding this information here is to see how this best fits in. For example, if it is shown that overall environmental impact from use of lead-free solder is worse than that of the traditional SnPb, then that should definitely go into the article. The comment you make is relevant to a point, but reduction of overall environmental impact is the goal of the RoHS legislation, hence something that creates more waste, for example in the form of emissions from power plants would definitely not be consistent with the principles that RoHS was based on.

A conclusionary statement is that it seems that the lead-free solders are only responsible for a minute amount of lead usage, yet seem to be incurring significant environmental impact from power production alone. This is not even considering the various other topics.

I'm also surprised that the landfill use for lead-free solders is worse.

Since these findings are inconsistent with the goals of RoHS they are relevant to this article. But how to add them, and how to add only the relevant portions, is the challenge. Aki Korhonen (talk) 22:57, 26 April 2008 (UTC)

[outdent] Aki - Interesting that you left out the first positive part of the summary from your reference, and kept the negative - why?, here's the preceeding section too:

"Lead-free soldering substantially reduces the worldwide potential toxicity and the risk of toxic impacts of
metal emissions into the environment from soldering wastes and from printed wiring boards at the endof- life stage. The RoHS Directive therefore achieves its intention to reduce the toxicity of the WEEE.
On the other hand, lead-free soldering increases the energy consumption for around 40 %."

So, take a look at the description as it exists now in the article on lifecycle studies and let us know what you think (I didn't write it). It mentions the EPA and Stuttgart studies and provides a good balanced summary. I can pick items out of the EPA study to counter your points, but I think that's counterproductive - I like what we have now, or you could add this portion of the summary. Prosecreator (talk) 05:25, 27 April 2008 (UTC)

Prosecreator, leaving out "positive" parts from the summary was not intentional, at least not for the sake of it being "positive". In the snippet I was trying to highlight information that is relevant to how RoHS is not meeting some of its main goals, and in fact is counterproductive. The information that goes into the article should be balanced, which is why we are having this discussion here.

I like the paragraph you highlighted, but I also believe it should go with at least a note (if not a short discussion) on higher landfill use and a characterization of what the 40% higher energy consumption means in real terms (the power plant example is particularly illustrative.) It's also helpful to mention that part of the reason for 40% higher energy consumption is the higher process temperatures required for processing the related ore.

I'll also say, to hopefully not get us going with the wrong interaction here, that I'd like to see this article be balanced. There are many positive aspects to RoHS and those should be highlighted. But it's not a uniformly rosy picture out there. And that aspect has to be highlighted too.

In the last few interactions we've had I'm getting the feeling that you see me as an advocate against RoHS, or at least lead in solders. I'm also getting the feeling that you are advocating the universal greatness of RoHS and setting aside negative details when they don't fit the overall goal. I'm not saying that this is the case, but this is the impression that I'm beginning to form.

If my impression is accurate, I suggest that we try to work past that. I hope that you recognize the contributions I have made to the positive aspects of RoHS, and I for my part will continue to do the same for your contributions.

To find common ground, I also note that the focus of our discussions on lead-free solders is probably due to the fact that it appears to be emerging as the only truly troubled aspect of the legislation. We should discuss it in a balanced manner, and because it is troubled, give it the additional space in the article that it deserves.

Aki Korhonen (talk) 17:22, 27 April 2008 (UTC)

Aki, I believe you and others are trying to "dig up" (your words) more and more criticism of pb-free solder so that it's obvious to readers the EU made a mistake in this regard - which isn't the purpose of Wikipedia. I feel the article doesn't need more negatives, it should primarily focus on a description of the directive and briefly touch on the implementation issues you feel are so important. This tends to put me in a "defensive" mode, trying to balance things. How about a new pb-free solder article we could link to, where you could go to town on all of these issues? How about moving some of the tin issues to the metallurgy article? Instead of adding more current topics like the proposed additional RoHS substances or the now in effect "China RoHS," we're derailed on issues like Tin Phase Transformation and "cherry picking" items from references that have yet to effect a RoHS compliant product in production. Just my thoughts. Prosecreator (talk) 19:02, 28 April 2008 (UTC)

Effect on sale of used equipment

Do RoHS restrictions apply only to new equipment, or to anything which is sold within the EU, including second hand equipment? In other words, do i still have right to sell or buy, for example, a vintage Macintosh SE, which is not RoHS compliant, via ebay? —Preceding unsigned comment added by 217.118.66.46 (talk) 09:12, 29 December 2008 (UTC)

RoHS applies to production of new products after July 2006. I believe all Apple products are now RoHS compliant worldwide, a vintage Mac would be exempt. Prosecreator (talk) 19:23, 5 January 2009 (UTC)

Lead-free solder health benefits

In my experience breathing in smoke from the flux in lead-free solder causes much worse respiratory problems than lead-tin solder ever did. Are there reliable sources actually saying lead-free soldering is any better? It sounds somewhat questionable to me, since real assembly / prototyping workers have proper ventilation and other protective measures so they shouldn't have gotten into contact with dangerous amounts of lead (and if they did, aren't we just replacing lead with highly active flux?) Pelzi 21:00, 5 November 2007 (UTC)

I am aware of one study of stained-glass workers with measurable quantities of airborn lead. Solder smoke is responsible for occupational asthma according to OSHA, but this is due to the flux as you've stated. I guess you're asking for a comparison of occupational asthma vs. the danger of lead inhalation. I've read lead solder MSDS's that warn of a lead-fume danger, but manufacturers often discount it as minimal. Prosecreator 16:59, 14 November 2007 (UTC)

The article contains this unsourced claim: "The use of lead-free solders and components has provided immediate health benefits to electronics industry workers in prototype and manufacturing operations. Contact with solder paste no longer represents the same health-hazard it did before." I'm no expert, but I've not seen any medical studies demonstrating such health benefits. For now, I'll add a "citation needed" flag. NCdave (talk) 11:39, 22 January 2008 (UTC)

Yes, I don't think there's been much study in this area, I assume the author of this section added it based on a simple assumption - less heavy metals, better safety. There is now a citation of manufacture MSDS's (Material Safety Data Sheets) which demonstrates an improved health rating. If you find other citations, please add them. Prosecreator (talk) 20:28, 5 February 2008 (UTC)

There should be a source for this information, as lead-free solders contain tin and/or antimony, both of which are listed in their respective wikipedia articles as having potential health hazards, which are likely exacerbated by their presence under high temperature and vapor conditions. --70.70.177.198 (talk) 06:41, 11 January 2009 (UTC)

70.70.177.198 Changes

Greetings,

You have made several changes/additions to the RoHS article, without any discussion. Let me explain -- earlier versions of the article read like an indictment of RoHS. This is not the intent of a Wikipedia article - they are meant to be non-biased. There is even some agreement that criticism/pros section should be eliminated entirely. Following Wikipedia guidelines we attempted to balance the pro and con sections with a more impartial voice. This is why you see elements in the criticism section that could conceivably be in the pros section.

I undid many of your changes until we can discuss further and I apologize for undoing the effort you've put forth.

Please feel free to discuss further on the discussion pages or here.

Prosecreator (talk) —Preceding undated comment was added at 22:01, 12 January 2009 (UTC).

I am the person who made those changes; firstly, I moved the section on benefits for the automotive industry to the pro section, because it is good, and now someone restored the old paragraph, as there are now two paragraphs that say exactly the same thing, one in 'pro' and one in 'criticisms'.

Secondly, while it is great that mercury and other metals have been restricted in batteries, the largest (industrial) impact of ROHS was on lead, and the first paragraph in the 'criticisms' section now makes no sense because it talks about lead for the first while, then suddenly shifts to talking about cadmium and mercury, I would suggest that something to the effect of "(Hg & Cd were restricted in batteries as mentioned above)" be inserted at the end of the bit about lead in batteries under the criticisms section, with the last sentence of the first paragraph of the criticisms section being deleted.

Lastly, while I agree with you that the article should be unbiased, it should not present facts in an unbalanced way in order to make it more neutral; in that, sometimes the facts may give the reader the impression that something is good or bad, but this is fine, so long as all available facts were presented in an unbiased manner.

--142.58.10.181 (talk) 17:44, 13 January 2009 (UTC)

Thanks for responding and thank you for taking the time to contribute. I agree that presenting facts and statistics are useful, but not if we leave out important information to support an argument - even the criticism section needs to have balance. I don't think readers should have to jump down to a different section to exhaust a topic. The critical section you added stated that RoHS ignored lead batteries and leaded CRTs, which I felt was misleading. I added a bit about the battery directive to show they were considered. Also, leaded CRTs were not restricted simply because newer alternatives like LCDs, are making them obsolete - this could be included too.

I think one of the problems with the article, especially the criticisms, is the emphasis on lead, with little discussion of the other substances. I think the plastics industry might emphatically tell you the BFR restrictions are huge - yet there's little discussion of it. Cadmium is huge too, the inclusion of nickel-cadmium batteries was an attempt to broaden the section - these devices only a few years ago were nearly ubiquitous in consumer electronics for rechargeable storage. Cadmium has a higher toxicity rating than lead, too.

Please let me know your thoughts. We can reword that first paragraph and/or remove the duplicate mention of automotive application.

Prosecreator (talk) 03:42, 14 January 2009 (UTC)

Thanks for responding so quickly. The reason why there is so much emphasis on lead is that, while the other heavy metals are potentially more dangerous, they have a less significant direct impact on the electronics industry, as the cost for compliance is much lower in the case of metals such as cadmium and mercury, while leaded solder is not compatible with non-leaded components and vice versa (among other issues;) another reason is that the hazard-level of a metal seems to have little to do with its ROHS status, as can be seen from the fact that bismuth is in many ROHS-compliant solders while being hazardous. Below I have included an edit of the first paragraph in the criticisms section which I would like to see your thoughts on; I would also recommend deleting the section on automobiles in the criticisms section, as it is a paragraph full of pro's. I agree with you regarding that CRT screens should be mentioned as being obsolete, and therefore not worthy of regulation, however, this obsolescence also brings with it the prospect of large quantities of these old screens being disposed of, which may cause a problem, and it might be a good idea to mention this as well.

One criticism of RoHS is that the restriction of lead and cadmium does not address some of their most prolific applications, while being very costly for the electronics industry to comply with. Specifically, the total lead used in electronics makes up only 2% of world lead consumption, while 90% of lead is used for batteries, (covered by the battery directive, as mentioned above, which requires recycling and limits the use of mercury and cadmium, but does not restrict lead;) another criticism is that less than 4% of lead in landfills is due to electronic components or circuit boards, while approximately 36% is due to leaded glass in monitors and televisions, which can contain up to 2kg per screen.[19]

-70.70.177.198 (talk) 23:56, 14 January 2009 (UTC)

OK, I have made your changes to the article - I moved it to the second paragraph instead, as the first one provides a good introduction/summary. The automotive part is now in the Pros section only, with just a brief mention remaining in criticism.

We've got a huge criticism section now, with lots of historical complaints -- some in my view are irrelevant considering nearly all consumer electronics are compliant now, the money to switch has been spent, and the sky has not fallen. :)

I'm unaware of bismuth being very toxic - it's used in cosmetics and medicines. I believe the most popular lead-free solder is SAC - tin, silver, copper. Prosecreator (talk) 16:52, 16 January 2009 (UTC)

The fallacy of lead in CRTs, regardless of their supposedly being obsolete, is that the lead in a CRT is within the glass and cannot be released unless the glass is melted. Ken (talk) 14:40, 30 June 2009 (UTC)

There is no fallacy I'm aware of. Melting is not the only risk. Try Googling on the leaching of lead from CRTs: "An experiment by Timothy G. Townsend of the Florida Center for Solid and Hazardous Waste Management found that CRTs leached enough lead in simulated landfill conditions to qualify as toxic waste" - Recycle Your Television Now—Before It's Too Late: Buzzword, Popular Mechanics 8/2008 —Preceding unsigned comment added by Prosecreator (talk • contribs) 16:57, 1 July 2009 (UTC)

Balance

Could we have some pros stated for RoHS, to balance the "criticism" section? The article carries a slight air of personal distaste for the directive, which does attempt to solve some difficult (and growing) environmental issues. Triplight 22:16, 2 September 2006 (UTC)

Dear Triplight,

I agree. The environmental directives like RoHS, WEEE, Battery and Accumulators, all cite goals of protecting the environment and human health, while providing for smooth-working "internal" European markets and standardization of technical specifications across product groups. They exist only partly to protect the public interest. Part of the early 1990s history of Euro directives is as a thrust to start a viable European union, currency, and comcomitant market, while stating lofty compliance goals. You're right -- there's no "Pro" section or rebuttal to the "Criticism" section of this article (to which I contributed, in disseminating information). I'd like to point out though that the Criticism section is simply stating widely-held beliefs and I'm not sure if it's the author's "personal distaste" for the directive. You can always create the rebuttal to Criticism section yourself.

My personal opinion is that the directive is not aggressive enough, and it relegates too much to the recycling solution. Sorting and recycling the diaspora of marketed consumer batteries takes a more concerted effort than putting bottles and paper in the blue bin. And since some of these metals are not harmful until they reach the trash, the companies can claim that only an intelligent recycling effort is necessary. Still, I'd rather the batteries in my mission-critical circuits have a little more lead or whatever -- if reliability can't be assured otherwise. But I know that there are costly technical challenges and that there have been criticism of some Directives, like the Battery Directive, based on "faulty" science, maybe impelling weakening of the specifications.

If you read anything by lovely Heather "Talking Trash" Rogers [4]], you'll see a failed part of the recyling infrastructure are the landfills and megalandfill themselves. And since the recycling effort is so underfunded and unincentivized on the individual level, Ms. Rogers notes the importance of stemming the intentional production of toxins in the first place. In one of her books, "Gone Tomorrow: The Hidden Life of Garbage[5]," she says we went from a society that saved and recycled during the Depression to one that accepted waste.

But our pro-environment stances aside, the European Union, the world's second or third largest economy, is setting the pace in this trend. China would prefer to host the Olympics as an environmentally-friendly, RoHS-compliant country so ostensibly they've beat the US to the punch. This may have had enough of an economic impact that Fujitsu said RoHS initiatives hurt their numbers this last quarter [6].

I hope to add in this RoHS article how future RoHS-compliant manufacturing processes will affect, among other things, electromagnetic compatibility. The discipline of EMC uses the physical attributes of metals, like conductivity, on, within, and around the layers of printed circuit boards for shielding and noise emissions control. The boards (and product enclosures) often use the metal layered inside insulating material to shield and dampen interference radiations from electronic products and may be affected by the use of different substances and soldering practices.

Please bear in mind I'm not an expert nor have I worked in this specific regulatory field.

DonL 05:50, 23 October 2006 (UTC)

Triplight, I totally agree. It reads to me more than just a bit of personal distaste, I would flag this article as biased. Obviously, there must be some benefits if so many governments are bothering to enact this legislation. Also, I bet there have been some hidden benefits as well. --eighthave 16:44, 16 February 2007 (UTC)

In the interest of balance, it might also be noted that if issues relating to time and usage based whisker growth are a potential source of equipment failures, it might be economically useful for an electronics supplier to embrace it on that basis alone. If the problems don't surface for a year or two, it could be an advantage to the (thus forced) replacement trade. I suggest all submissions to the main page be examined for bias in arguments either for or against the elimination of lead-based solders.

My concern - I'm in the IT industry myself (40 years in it) and I have noted server component failures from high-end name brand equipment due to whiskering that were manufactured post Feb 2003 directive implementation. I have been required to do this as part of a formal risk assessment in a very large commercial environment, in the past, in the capacity of audit of retail equipment selection.

It's probably due to cost that designs aren't adapted to effectively use lead-free soldiers (some are simply changing the solder type without considering other design parameters) but I've found it's never a good idea to assume altruism on the part of component suppliers. For whatever reasons, whiskering remains a problem in electronics as manufactured today, and should not give the appearance of being dismissed out of hand. Emotion has no place in the argument.

I must post anonymously, I'm afraid - apologies. —Preceding unsigned comment added by 202.53.35.32 (talk) 01:26, 23 November 2009 (UTC)

Could you provide more details and perhaps a reference? First, how do you know the component was compliant? The 2003 date you mention was when the directive was adopted, it was not in effect until 7/2006. Second, how do you know it failed due to tin whiskers, or is this just conjecture? I have yet to find any evidence of tin-whisker failure in the field for a mass-produced CE product. Thanks. Prosecreator (talk) 22:53, 2 December 2009 (UTC)

Exemption for Cadmium in Color-Converting LEDs

Starting February 2010 RoHS temporarily till Jule 1, 2014 exempts chromium in colour converting LEDS from the restrictions because there's no replacement material. source, EU decision (pdf). 174.6.87.98 (talk) 17:20, 28 March 2010 (UTC)

Criticism section - please clarify

My edit [7] The soldering temperature is very similar for leaded and lead free soldering, despite the difference in melting temperature. Also the NIST reference is unclear - where is the part which mentions changes in packaging etc. I can't find it.Sf5xeplus (talk) 21:58, 11 July 2010 (UTC)

If it's not in the reference, it should be removed. Thanks for the valuable contributions.Prosecreator (talk) 15:04, 15 July 2010 (UTC)

I've removed Nevertheless some changes have been made to materials for chip packages, for some printed circuit boards and components containing plastics.National Institute of Standards and Technology^{[clarification needed]}.

I simply can't find where that is stated, it may be synthesis.

A similar situation exists for the statement Care must be taken in selection of RoHS solders as some formulations are harder with less ductility, increasing the likelihood of cracks instead of plastic deformation, which is typical for lead-containing solders.

This is surely true, but it uses the same reference. I've changed that to 'reference needed'. I've also moved the NIST reference to external links since it is a good source of information.

I have removed this Restricting lead content in solder for electronics requires expensive retooling of assembly lines and different platings for the leads of the electronic parts^{[citation needed]} as far as I can tell this isn't true. Except the bit about using different platings for leads - which must be lead free - but is this not obvious? 87.102.32.76 (talk) 23:48, 16 July 2010 (UTC)

Image issues

This image

File:Pht-solder-joint.jpg

An illustration of solder joint reliability, demonstrating RoHS process reliability versus traditional joints. AlphaSTAR is a RoHS immersion silver PWB assembly process from Cookson Electronics. Copyright 2007 © Enthone Inc.

Firstly I don't see the need for the mention of the tradename - hence a previous editors advert concern.
Secondly without context there is no way this image shows that one process is more or less reliable than another. What it shows appears to be the cross-section of a solder joint - is it a broken joint or what. Additionally the image is too small to be useful sorry.
This article needs reliable references, and any images may need references to the relavent paper.

As it is the image is not suitable; it explains neither what it shows (in sufficient detail), or gives context of the image (age, operating conditions etc). A single image is unlikely to demonstrate solder reliability - possibly images+data over time may.Sf5xeplus (talk) 19:48, 4 October 2010 (UTC)

I am going to suggest speedily deleting the image.Sf5xeplus (talk) 19:53, 4 October 2010 (UTC)

I think you make several valid points. Let's keep it out, unless someone wants to explain it in detail. Prosecreator (talk) 20:19, 5 October 2010 (UTC)

RoHS II attempts

Within the category Labeling, the RoHS II attempts are shortly mentioned. Now, I've found some more information on the topic and would like to add the following:

"The European Parliament completed its first reading of the draft of RoHS II in November 2010. Items that were previously in question have now been clarified and RoHS II is on its way to becoming a CE Mark directive, which means that CE marking will be affixed to all finished products, as per Module A of Annex II of 768/2008/CE. With CE marking, the responsibility is now to be shared between manufacturers and importers and distributors. CE declaration remains the manufacturer’s obligation, while the release of compliant products onto the EU market becomes the responsibility of importers and distributors. The CE mark will now not only mean that an electrical or electronic product complies with all applicable regulations - for example, the low voltage directive or the electromagnetic compatibility requirement – the CE mark will also mean compliance with RoHS. Thus product compliance and conformity assessment will now include the obligation to comply with RoHS. No new restricted substances have been introduced and the publication of the directive is expected this year."

The reference I'd like to use comes from the free consumer information service of an international testing company (See Consumer Information on RoHS II, P. 10: http://newsletter.sgs.com/eNewsletterPro/uploadedimages/000006/SGS-Consumer-Compact-Feb2011-EN-11.pdf.

Would it be ok to use it?? Thanks. Portrino (talk) 09:06, 13 April 2011 (UTC)

Thanks for raising the point here, as well as on your talk page. Editors for whom "external links" is a specialist subject hang out at WP:ELN and they would be happy to advise you. Best. --Old Moonraker (talk) 09:25, 13 April 2011 (UTC)

Many thanks for your advice! Portrino (talk) 11:27, 13 April 2011 (UTC)

Criticisms for Glass

An excellent case is made as to why these materials should not be restricted from glass in an article from optics.org [1]. Peter Hartmann, the Director of Market and Customer Relations for the Advanced Optics division of Schott states "This is incredibly unfortunate, as the best thing you can do to take all hazardous substances out of bioavailability is melt them into glass." I suggest that this be added to the article. — Preceding unsigned comment added by 138.210.84.242 (talk) 13:43, 23 August 2011 (UTC)

Optical glass today is used in millions of portable electronic devices from smart phones to iPods. To "take it out of scope" would be a mistake. I think your article is interesting but misleading. It claims removing lead from optical glass is difficult and then surprisingly acknowledges that 90% of today's glass is lead-free thanks to RoHS. I think the author misses the point: RoHS addresses the high-tech trash problem.

Also, if you read further on this page you'll discover a study of the leaching of heavy metals from CRT glass. I would say binding metal in glass does not eliminate its bioavailability over time: "An experiment by Timothy G. Townsend of the Florida Center for Solid and Hazardous Waste Management found that CRTs leached enough lead in simulated landfill conditions to qualify as toxic waste" - Recycle Your Television Now—Before It's Too Late: Buzzword, Popular Mechanics 8/2008 Prosecreator (talk) 02:23, 2 December 2011 (UTC)

Pronunciation

In casual conversation, it is often pronounced "ROSH", or "Row Haws", except in Europe, where it is pronounced "Rose". As this is an EC directive, presumably most discussion of it is happening in Europe. Perhaps this should be rephrased to put the European pronunciation first, and the American (assuming that's where the other pronunciations are from) second? (unsigned)

I agree. Google has only 21 hits for "Row Haws", BTW. Triplight 22:16, 2 September 2006 (UTC)

"row haws" was a pronunciation guide and not something to google for. By your argument googling for "rose" returns millions of hits thus it should be listed first.... at our company it sounds more like "row hoss". justin - 5 October 2006

Perhaps someone with knowledge of the IPA could add the IPA for the various pronunciations? psu256 16:21, 2 January 2007 (UTC)

The correct pronunciation is "Rose", r-oh-s. Hence China-RoHS is pronounced "China Rose". Cinteltom (talk) 15:43, 9 January 2012 (UTC)cinteltom

Economic effects (II)

This is not in the article (if not lacking neutrality) but it is a valid thought: the positive effect of RoHS on the economy in terms of productivity and product demand. (Who knows if that wasn't another desired side-effect of the regulation in the guys' internal papers? So to say, a "21st century light bulb conspiracy"). Let's get facts straight: electronics assembled with leaded solder are reported to have a longer durability than those forcibly made with lead-free solder. So what does economy get? A lot! Product failure rate is increasing rapidly---whilst old hardware still works perfectly---and consumers have to buy new hardware more often. Simple as that! So under the cloak of being "beneficial for the environment" these lesser-durable electronic units may propel economy further! =P For (see light bulb...) when product durability is TOO high, less new products will have to be manufactured (worst case: unemployment or even close-downs of factories). So you could say the rare light bulb that lasts 50,000 hours is our classic units with good old leaded solder, whilst the new RoHS-compliant products is the 1000-hour bulb. -andy 217.50.50.231 (talk) 16:16, 11 July 2012 (UTC)

Andy, sometimes it's tough to throw out our preconceptions and anecdotal experience. There was a great deal of "this will be the end of the world as we know it," talk back in 2006 and earlier when the regulation was first proposed. Writing this today in 2012, there have literally been trillions of RoHS compliant products produced. In all of the years I've spent following RoHS, there simply hasn't been any strong evidence that compliant products are less reliable. When I hear of the few failures, they usually used pure tin or "bright tin plate" that predate or are exempt from the directive and are universally known to be avoided. Engineers and scientists have been able to develop new formulations that simply work without the environmental baggage. I won't spend time citing references, but you mentioned light bulbs. Sylvania has been making lead-free incandescent bulbs for over a decade now, and there's been no difference in reliability (See the environmental section of their web site). Virtually all of today's new LED and CFL bulbs are compliant, and they are predicted to last years if not decades longer than the traditional bulb. Hopefully the facts will eventually prevail.Prosecreator (talk) 01:18, 12 July 2012 (UTC)

Reliability Concerns Appear Unfounded

I don't have a strong technical opinion on whether RoHS is, in fact, going to cause the problems that some have predicted for reliability. However, I think that the content of this section of the article is entirely unsupported by the single citation. AMD's statements related to microprocessors and chipsets, not to printed circuit boards, the area where there seems to be the greatest concern.

Also, the statement "Contrary to the predictions" sounds a lot like a strawman. I don't think I've heard anybody say that we should expect noticable (to the mainstream press, at least) reliability problems within the first year. All the problems I've heard discussed were longer term ones. I would not expect to hear many complaints within the first year.

Also, it's worth noting that huge amounts of effort have been put in to solve this problems. It would be inaccurate to portray predictions as unfounded if the potential problems were only averted by serious R&D that wasn't guaranteed to produce the right results. Bhimaji 00:13, 11 October 2007 (UTC)

I've added a reference that hopefully addresses your concerns. My understanding is some products have been compliant for many years, e.g. Motorola cell phones since 2001. Also, I wasn't aware only PCBs were a concern - my thinking would suggest the most complex electronic components, e.g. microprocessors and supporting chipsets, would be most concerning.

You have a good point about the level of effort involved, perhaps we should add something that mentions this? Prosecreator 22:23, 11 October 2007 (UTC)

As far as only complex components being affected by RoHS, see this AP article and the accompanying photos. The variable air capacitor shown is anything but complex, but its failure due to tin whiskers will still put the equipment in which it is used out of commission. —Quicksilver^{T @} 19:12, 26 October 2007 (UTC)

You just cannot make PCB's without lead solder, especially multi-layered PCB's were the higher temperatures of lead-free solder would instantly damage the board. —Preceding unsigned comment added by Ferongr (talk • contribs) 15:35, 17 October 2007 (UTC)

This is incorrect. Most computer motherboards, e.g. Asus, are now RoHS compliant and use lead-free solder. There are numerous other examples. Are you saying that a motherboard isn't a PCB? The high temperature issues have been addressed. Please explain.Prosecreator 18:22, 17 October 2007 (UTC)

I take objection to the statement that "The high temperature issues have been addressed." Nothing could be further from the truth. In reality the ordinary margins for reliable product manufacture have simply been narrowed greatly. On one end is a cold joint from too low of a process temperature, on the other component and laminate damage due to too high a temperature. Since the board can't be brought to the process temperature for more than a very short period of time, achieving the correct range evenly at all points is a great challenge. This challenge was made even more demanding with the lead-free process, which moved the low-end up by 30 degrees C. There have been some improvements in the high-end, but it has mostly come from testing how long parts can endure the higher process temperature and documenting it as a new acceptable high end, i.e. simply evaluating and quantifying a margin that had existed in the past already. I would agree with your statement if the old range of process temperatures (albeit at a higher point) were still available. But that simply is not the case. Aki Korhonen 00:23, 19 October 2007 (UTC)

Can you quantify how narrow the "margins for reliable manufacture" are now? I would assert major manufacturers worldwide are satisfied with the numbers. Also, my understanding is there are solder formulations that don't require much of a temperature differential, which formulation are you thinking of? Prosecreator 15:14, 19 October 2007 (UTC)

<rant> Having worked in the electronics industry for over 25 years, most recently in various well-known companies that manufacture disk drive memories for consumer use, I can state emphatically that reliability is of no concern whatsoever. These companies are typically run by non-technologists, and they are entirely driven by the "bottom line" and their next bonus. If reliability is a concern at all, it is to make the product just reliable enough to survive the warranty period, typically one year or less. If it can't be made to survive the existing warranty period using junk parts, then the warranty period is appropriately adjusted downward to match the reduced quality. Most of these jokers have never worked in aerospace, military, medical, or industrial equipment companies; having electronic assemblies work reliably without maintenance for 10-20 years is a concept that eludes them. That, my dear Prosecreator, is why "major manufacturers worldwide are satisfied with the numbers". RoHS, with respect to tin-lead solder, is a purely political movement, solving a non-problem. The responsible thing to do while editing this article is to tell the truth, not dance around it with concerns about NPOV and "political correctness". RoHS is going to end up getting a lot of people killed. </rant> —Quicksilver^{T @} 16:23, 26 October 2007 (UTC)

I'm not religious, but all I can say is Amen. I agree with your view completely. Aki Korhonen 18:07, 13 November 2007 (UTC)

Unfortunately, this anti-RoHS tone is pervasive in the article. Many have tried to balance it out, but it still reads like a negative rant. I don't understand why, what I believe to be a tiny minority, is so against reducing hazardous substances. Maybe we need to eliminate the commentary sections entirely (criticism and pros) as it may not be constructive anymore. Prosecreator 17:36, 14 November 2007 (UTC)

(outdent for readability)

I believe there's a misunderstanding here. First of all, I don't believe you will find many who are against reducing hazardous substances. The question is where such reductions take place. The lead-free solder business has always been (and continues to be) a politically driven initiative, with little time given to the realities of the electronics industry. The industry can adapt to the politically imposed limitations, but they can't change materials science, as the eutectic tin-lead alloy simply has no realistic replacement. I believe RoHS has a lot of good things going for it. If it had not included lead in solders, I'd be all over it. If you were to ask me how things should be fixed, RoHS should exclude lead-free solders, as at least in theory WEEE will capture the products before they hit landfills. But that conclusionary view is not something that should be in a wikipedia article.

As to your suggestion of taking out the discussions pro and con, I believe the discussion should stay. The information presented represents scientifically valid data, and the reader is left to draw the conclusions. If the result appears to you as a rant against lead-free solders, then perhaps it's a reflection of a disconnect between the realities of the matter and your expectations of it. (And I don't mean this in a bad way.)

In summary, I believe you have contributed a lot to the discussion and the topic, and I hope you continue to do so. I also like to represent information that I have for both sides, and did add data to the "pro" side when "pro" was not much more than a paragraph. We probably have personal conclusions that aren't quite the same, but it should not keep us both from contributing. However, please, let's not take out data only because it doesn't fit our view of the world, or it seems imbalanced against our views. Aki Korhonen 20:45, 14 November 2007 (UTC)

Thanks for the thoughtful response Aki - you've made some good points. I guess the question comes down to cost vs. benefit. Does the reduction of lead in solder produce enough of a health and environmental benefit to justify the cost? Now that major corporations have made the switch, the money has been spent, so perhaps the cost is less relevant. New studies are suggesting that metals recycled from electronics and other sources (e.g. batteries) are inadvertantly showing up in the plastics and other components of children's toys. This is one hint that RoHS may be the better solution. Prosecreator 23:51, 14 November 2007 (UTC)

I don't have the answers, but I remain firmly of the belief that solder should be exempted from RoHS. The long-term reliability hit is simply too significant. I don't see that a solder-only exemption would obviate the technology investment by the industry, as much of it has been into cleaner and more efficient production equipment, and the reduction of other chemicals. All of those benefits would remain, regardless of what solder is used.

As to the children's toys, it's a prime example of where regulation should be directed. China is a glaring example of countries that use the "developing country" excuse to hide incredible waste and pollution. Some fault, obviously, falls on the companies doing the sourcing in China and not validating that they get what they "thought" they were getting, but the major issue is the blatant disregard for the environment in that country (and others, but China front and foremost.) Aki Korhonen 01:00, 15 November 2007 (UTC)

I think you should trust technological innovation to solve any reliability problems. Sony, for example, has been using unleaded solders since 2002, according to a reference in the article, and reliability apparently hasn't been a concern - the Japanese have embraced it. I bet you'll even see NASA go this route, once the beuaracratic approvals have been obtained. Prosecreator 15:57, 15 November 2007 (UTC)

I have no difficulty trusting technology, but I also know where the limits of it generally are. Sony is likely a bad example, as their long-term product quality has been lacking. I wouldn't be surprised if most electronics manufacturers like the idea of shorter lifespan for their products, as nothing beats a customer being forced to buy new. Just like "back in the day" the big three automakers loved rust that would obsolete cars within a few years.

As to NASA using lead-free, they probably are a good indicator of what works and what doesn't. If the cost of replacing a spaceborn system is in the tens or hundreds of millions of dollars, or a failure could lead to the death of astronauts, only a short-sighted fool would use anything than the best product for the job. (This doesn't mean that politically appointed short-sighted fools haven't made their way around NASA before.) Aki Korhonen 16:45, 15 November 2007 (UTC)

(outdent for readability)

Don't forget that solder isn't the only RoHS affected issue, cadmium and lead has been used in all sorts of components like cable sheathing and PVC, speaker enclosures, digital piano key weights, digital camera lenses, CRT glass, batteries, the list goes on and on. Prosecreator 20:27, 15 November 2007 (UTC)

I don't believe I have, and in fact said that RoHS has many very sensible aspects to it. Getting rid of lead and other nasties from a long list of consumer-facing products is reasonable, and can be achieved with few side effects to durability and other characteristics. The reason there is a lot of discussion on the electronics solder is for the simple reason that alternatives are far inferior in every respect. I believe a case can be made, and already has, that lead-free solders are counterproductive to the goals of RoHS and WEEE. That is why that aspect of RoHS was always on a purely politically driven agenda. Aki Korhonen 20:48, 15 November 2007 (UTC)

I can't change your mind, but I will point out the citations in the article on the advantages of the RoHS solders, e.g. smaller devices are now possible and I remember one stating connections are actually stronger. The image in the Pros section demonstrated (it was deleted due to misinterpretation of fair use, in my opinion) from Cookson Electrons that they have an unleaded formulation they claim has *superior* reliability to traditional joints. --- Prosecreator (talk) 17:15, 16 November 2007 (UTC)

I doubt I can change your mind either, though that isn't really my intention. High density small component technologies have been driven in parallel to RoHS, not as a result of RoHS. Above a certain density the rules change and manufacturing tools and processes require tradeoffs. Sometimes density is chosen over reliability. If there were no RoHS, you'd still see some companies choose to use a low surface tension solder such as SAC in some implementations because of the (lack of) flow properties, knowingly sacrificing reliability for a smaller package without paying for the next step, which is hybrid technology and very expensive.

I tried to find some product from Cookson Electronics that claims to outperform eutectic leaded solder, but didn't see anything. Did you mean the immersion silver finish that they offer, which is a board coating, and not a solder?

By the way, I agree that the wiki picture-police (I'd use a stronger word, but will not digress this time) is not applying their own stated principles accurately. It's frustrating to see very instructive images go unused because of some artificial demand that pictures be "set free" instead of made available where needed. I wish the picture-police would be required to provide 1 replacement image for every 10 they "police" away. I would bet that the number of "policed" images would whittle very quickly.Aki Korhonen (talk) 08:24, 17 November 2007 (UTC)

Right, the Cookson Electronics product is silver immersion. However, it appears they are claiming it gives lead-free solder joints improved reliability over traditional joints. I was able to add the image back, if you'd like to take a look. Prosecreator (talk) 16:57, 19 November 2007 (UTC)

Reliability Concerns Appear Unfounded? Oh, yes, and the EU that mandated it is doing really well for themselves! I agree with Aki Korhonen and Quicksilver. The reliability of consumer electronics has PLUMMETED since RoHS came into force. Let's talk about failures of aluminum electrolytic capacitors before RoHS and since RoHS started barbecuing PCBAs, through the roof. It is very, very typical for digital TV converter boxes to fail in 30-180 days, and in many cases, several aluminum electrolytic capacitors inside have already died. Here's the most telling proof: The medical field and every military in the world have told lead-free products to take a flying fucking leap.--99.24.216.254 (talk) 09:28, 11 August 2012 (UTC)

Correction: The Chinese have adopted a very similar version and the military and medical exclusions were in the directive from the start - PLUS many of the exclusions are being removed as we've discovered ways to reliably make products compliant. There is no evidence I'm aware of in the literally billions of units in the field today showing significant issues in reliability. The examples critics use include incidents that occurred prior to implementation or poor designs of products that ignore the current science, e.g. pure tin plating. Correlation is not causation and IF consumer electronics are less reliable today than a decade ago, one could argue they are subject to increased failure due to increasing complexity and tight cost constraints. Prosecreator (talk) 22:40, 11 August 2012 (UTC)

AgCdO switch contacts?

Following the apparent mismatch on a power relay between its RoHS mark and the contacts being AgCdO, I found http://www.checon.com/contact-materials/silver-cadmium-oxide-sko-materials/ where they state that Cd is exempt in contacts, in some countries. It seems relevant, does it warrant a section under Exemptions? -- Silicosaur'us 22:59, 10 February 2013 (UTC)

Good question. I'd avoid getting into the weeds with specific exemptions, especially if they only apply to some countries. I don't think this article needs to detail the specification, people can read it directly for that information. If anything, I'd like to eliminate the solar panel mention, as it's too specific. Plus, historically many exemptions have expired or been removed, so it's tough to maintain them.

Prosecreator (talk) 15:33, 12 February 2013 (UTC)

4% LEAD CONSIDERED ACCEPTABLE. WTF?

SSDs with a tiny component that is ~3% lead passed RoHS compliance testing. this Certificate says (Note on page 12) "Copper alloy containing up to 4 % lead by weight" is exempt, per directive 2011/65/EU Annex EC Annex 6(c)! The exemptions Prosecreator dismisses seem to be inadequately covered and far too important to exclude entirely from the article. The reasons for the exemptions reportedly 'are granted to narrowly-defined applications for which the elimination of the prohibited substance is technically or scientifically impracticable or when the only available substitution produces more negative than positive benefits to the environment, health, or consumer safety." And yet some of the ~82 exemptions are loopholes big enough to, erm, pilot a supertanker through. 7a and b exempt ANY solder that is over 85% LEAD, and essentially exempt some of the world's biggest companies - from the lead restrictions - i.e. the bulk of the infrastructure of Google (#6), AT&T (#15), Verizon (#27), Vodaphone(#29) and Amazon (#37), and pretty much Cisco and Qualcomm's entire product lines (#40 & #41) are exempt from lead content restrictions. --Elvey (talk) 16:43, 17 April 2013 (UTC)

Good points, perhaps expanding the exemption section with attention to any changes with RoHS II would help. RoHS II may eliminate some of these exemptions, I haven't done enough research yet.Prosecreator (talk) 00:22, 18 April 2013 (UTC)

Such boasting may be appropriate to reference. :-) I was referring to loophole 7b. Also, RoHS II is relevant, ~~but WP:CRYSTAL...~~-it went into effect on 2 January 2013; 'full compliance' (meaning unclear) deadline is 22 July 2019 (per [Kingston info]. --Elvey (talk) 01:12, 18 April 2013 (UTC)

I also think a couple words added to the lede and the sentence starting "The maximum permitted concentrations are 0.1%" that link (using an intra-page link) to the exemption section would be appropriate, otherwise, they're misleading. e.g. "(with exceptions)" or something similar. --Elvey (talk) 01:12, 18 April 2013 (UTC)

Sounds reasonable, I like your intra-page link idea.

First I thought we should beef up the exemptions section, but I question whether the purpose of this article is to detail all of the exemptions. There are too many to list and some are subject to expiration. I don't really like the section now, with its arbitrary selection. Instead, an overview should be sufficient.

I have removed my comment on 7b, as further research suggests it may be unfounded. Prosecreator (talk) 02:43, 18 April 2013 (UTC)

Yes, I don't want to make it too big either! Certainly doesn't need to list all or most of the exemptions. I knew almost nothing about RoHS 'till I happened to see that 3 & 4% lead stuff, which led me to notice some of the ginormous exemptions. So I still know very little. Likewise, I have updated my comment re. RoHS 2, etc. One would hope that the exemptions have been set and are modified based on a fair cost-benefit analysis. That, is, by prioritizing low-hanging fruit- restricting where the environmental benefits are the highest and the financial costs are lowest on a QUALY basis, for example. The 'shoddy' report Aki Korhonen pointed out makes me think that may well not be what actually has been done. :-(. I'm going to make the exceptions change; I leave it to you and others to tweak the exemptions section. Ciao! --Elvey (talk) 07:42, 18 April 2013 (UTC)

RoHS 2 as holy as the original!

I was reviewing your last edit and noticed these huge loopholes in RoHS 2:

Most vehicles are exempt. Active implantable medical devices (and large fixed photovoltaic solar panels) are exempt.

AND the same incredibly broad exemptions I identified (above) in RoHS are in RoHS 2! 7a and b! See http://register.consilium.europa.eu/pdf/en/10/pe00/pe00062.en10.pdf, which your first link links to! Pge 51! I skimmed for context and those exemptions are part and parcel of RoHS 2. (Am I misreading it? At first when I found it, I guessed I probably was looking at since-sunset exemptions, but they seem to be current.)

Holy moly loopholes, Robin! :-) It's clearly inaccurate to say that RoHS 2 only has a 'few' exemptions.

Your second link seems to be quite the convincing whitewash. Non-RS? --Elvey (talk) 20:28, 18 April 2013 (UTC)

Yeah, you may be over reacting. RoHS is meant for consumer electronics so many of these are expected, like vehicles and medical devices. I will try to do some clean up at some point. Prosecreator (talk) 20:46, 18 April 2013 (UTC)

Well, I might be, but if I'm not mistaken, a typical car could be sold and marked as RoHS 2 compliant even though it contained lots of hazardous, toxic metals and plastics, and none of the electronics, such as the radio were themselves RoHS 2 compliant... If so, then your addition, "Apart from a few exemptions, RoHS2 covers all types of Electrical and Electronic Equipment (EEE)" is misinforming readers. Allowing implantable medical devices containing lots of toxic metals and plastics to be marketed as RoHS 2 compliant is dishonest, IMO, given how RoHS is commonly described. Cleaning up. --Elvey (talk) 19:52, 24 April 2013 (UTC)

As I'm editing, I'm noticing additional problems. Please verify the accuracy of your contributions and the reliability of your sources more carefully. A few things failed verification.

Apropos "Previous exemptions to product from categories 8 and 9 will be gradually phased out" - See WP:CRYSTAL; where specific sunset expiration years have been set, we can mention them, but not otherwise. Only a few categories have a future sunset expiration date. --Elvey (talk) 21:21, 24 April 2013 (UTC)

Elvey - I think we're going a little overboard with the exemptions thing. I took out the exemptions mention in one spot on component percentages and you added it back, it was repetitive, IMHO. Also, the compliance section is nearly empty and the reference provided is broken. Let's try to keep the flow and coherence of the article as a whole in mind. Can we always discuss before you make further exemptions changes? I do like the other RoHS2 additions you made - if you read further in the Kingston reference you'll find the verification you need in their RoHS2 sections. Thanks.Prosecreator (talk) 15:27, 25 April 2013 (UTC)

Overboard? How is "Apart from a few exemptions, RoHS2 covers all types of Electrical and Electronic Equipment (EEE)" NOT misinforming readers, when there are really many exemptions, and the article mentions only two of the smaller ones. Can we always discuss before you make further changes? After all, which of us put information into the article that failed verification/was false?

You removed two fv tags diff. The sentence "The CE logo now indicates compliance and declaration of conformity is detailed" it is not even English. If we drop the "is detailed", it's still bad English. So it still fails verification. We could remove "and declaration of conformity is detailed". The other sentence did fail verification as well, but you later accepted my proposed change, which fixes the problem sentence.

Nobody's perfect - if something's misleading, I will remove or correct it. Admittedly some of the info you said was not cited was buried towards the end of the Kingston reference. My point on article flow, was that when you mention the same thing over and over, it disrupts the article's coherence. I think things are in good shape now. Please consider reading the HP reference for a good, more in-depth understanding of the exemptions now with RoHS 2. Prosecreator (talk) 22:06, 29 April 2013 (UTC)

Another example:

The sentence "Exemptions expire after these time periods unless renewal applications are approved" is not accurate, so I've reverted it. Again. You say I'm not reading the source fully. Well, please quote a sentence from the source that includes the word "approved", or equivalent language. You won't be able to, because the source says something quite different.

And what about vehicles? Why have you left them out? --Elvey (talk) 21:47, 10 May 2013 (UTC)

We can add vehicles, the section just gives examples, I don't think it was intended to be all inclusive.

Conflict Resolution and RoHS Article

Note: I moved the following comment from my talk page, and reply to it here. -Elvey
Somehow we've got to find common ground on this article. You just undid a sizeable contribution that I made to the exemptions section without prior discussion. You've argued my contributions aren't verifiable yet you fail to read the references fully to discover their accuracy. When I have found inaccuracies, I have corrected them in a timely fashion and in good faith.

After undoing your latest retraction dated today (4/30/2013), the exemptions section again closely follows the Hewlett-Packard reference and is entirely verifiable.

Twice you have left the article with a broken link and missing reference. The new exemptions section you created originally had no verifiable information. Wikipedia articles should never knowingly be left this way - this is why there is a preview button. New sections should not be sparse - adding more exemption detail and "additions" I feel is a great way to better inform the reader, and it matches the reference, although I feel you haven't read it yet.

I have been a contributor to this article for several years now and would appreciate you respect my contributions and the article itself, despite any agenda(s) you have to the contrary.

Prosecreator (talk) 22:15, 30 April 2013 (UTC)

My edits, and explanations on the talk page and in edit summaries speak for themselves, and your comments are both way out of line, and non-responsive.

I do not enjoy repeating myself.

*Please point out the *specific* inaccuracies in the article and I'll address them. It feels as if you're attributing the entire article to me -- I am not the only editor. FWIW, the article was a mess when I found it, basically a RoHS hack job. Several others helped improve it with me.

I HAVE pointed out what I see as several inaccuracies in things you've added to the article. I'm not attributing the entire article to you. --Elvey (talk) 22:17, 10 May 2013 (UTC)

What part of "Can we always discuss before you make further changes? After all, which of us put information into the article that failed verification/was false?" do you not understand? Accuracy alters the amount of deference I'm willing to give to a long-time contributor, whether your claim that "When I have found inaccuracies, I have corrected them..." is true or not. What has happened is that you added inaccuracies (things that failed verification/were false) to the article. Do you deny that? Please be clear.

*I'm willing to wait to make further exemption section changes pending discussion, but I'm not convinced your availability or knowledge will sustain this approach. I believe you haven't been reading the references thoroughly and you seem to have a biased agenda and no experience in this area. Example: Asserting something as inaccurate when the citation mentions it towards the end, e.g. Kingston document and CE mark section or redundantly defining what exemptions are in various ways.

I can't make sense of that last "sentence".

The discussion can proceed appropriately once you answer. I've said, "It's clearly inaccurate to say that RoHS 2 only has a 'few' exemptions." Disagreeing about emphasis and relevancy is one thing. Disagreeing about what is verifiable is another.

*The word "few" isn't in the current article. If you think something's inaccurate, provide a reference or at least a sound argument and I'll change it.

Please don't screw up the indentation when you reply inline. (Fixed.)

AGAIN, you have NOT answered my question: What has happened is that you added inaccuracies (things that failed verification/were false) to the article. Do you deny that? Please be clear. I have pointed out what I see as several inaccuracies in things you've added to the article. I have asked you to respond to those points. You have not. Further editing while not doing so amounts to edit warring. But you think you're special.

I'm glad to hear that you're "willing to wait to make further exemption section changes pending discussion". You did just edit that section, however.

What part of "This adds more inaccuracies than it removes. As noted earlier, I think it needs to be reworked. Shorten 'Future Possible Additions' ?" do you not understand? Your comment on my talk page (which I've moved here) makes it seem like you hadn't read or simply chose to ignore these comments of mine. You revertd my edit without responding to my discussion points. Such editing may cross the line into edit warring. I did discuss the edit, though you say I haven't. It's you who haven't discussed your last edit, unless you count merely making an argument from authority (as above and in your edit summary) as discussion.

*I objected to you removing an entire section and leaving the article with a broken link while you worked on a replacement that never came. This is poor editing. Don't remove something and promise a replacement unless you can do it right away.

Please directly respond to my question:

"How is "Apart from a few exemptions, RoHS2 covers all types of Electrical and Electronic Equipment (EEE)" NOT misinforming readers, when there are really many exemptions, and the article mentions only two of the smaller ones."

*The article now mentions just about every exemption, and the "few exemptions" is gone. I'm confused.

It's not complicated. You added that quote to the article, thereby misinforming readers, not some other editor. You implicitly excuse your doing so by saying that the article doesn't say that now. It doesn't say that now because I fixed it.--Elvey (talk) 22:17, 10 May 2013 (UTC)

If you want a more collegial discussion, then when I say "This adds more inaccuracies than it removes," and identify them, it behooves you to make an effort to address the inaccuracies identified, rather than simply revert and argue from authority.

*I'm arguing you didn't identify them, but deleted my work and left the article broken. Then disappeared for days.

Do you think you are entitled to edit this article more boldly, or that your contributions deserve more deference than other editors, who should run their edits by you for approval before making them?

*Because of my experience and expertise with this subject and article, yes. ;)

Responses marked with *: Prosecreator (talk) 20:59, 10 May 2013 (UTC) --Elvey (talk) 19:27, 10 May 2013 (UTC)

I don't find this productive. Let's try to agree on changes in the future and leave it at that. Prosecreator (talk) 22:54, 10 May 2013 (UTC)

Reference Quality

References to RoHS exemptions such as those that that contain lots of "Text to follow" sections do not qualify as reliable sources for that purpose (example), when the actual text of RoHS is as available and clearly superior. So I'm reverting this. They could be used as sources of commentary. --Elvey (talk) 21:26, 10 May 2013 (UTC)

Instead of removing, why not find a better reference?

What? We already have one to the actual text of RoHS. I've removed the commentary as it's misrepresented as part of the directive, but you put it back just the same, again! --Elvey (talk) 23:37, 10 May 2013 (UTC)

Implantables

You said, "If you think something's inaccurate, provide a reference or at least a sound argument and I'll change it." Long ago (see above) I pointed out that "Allowing implantable medical devices containing lots of toxic metals and plastics to be marketed as RoHS 2 compliant is dishonest, IMO, given how RoHS is commonly described." but you didn't make any changes in response. Instead, you've reverted many of the changes I've made to address inaccuracies that I've identifed and evidenced.--Elvey (talk) 23:37, 10 May 2013 (UTC)

I haven't intentionally left anything out. I have tried to keep from adding too much detail to improve readability. It's tough because the audience for this article can be so varied, from students or recent grads like you to engineers, bureaucrats, material scientists, etc. Prosecreator (talk) 00:46, 11 May 2013 (UTC)

Incessant removal of cited content

Prosecreator, Apropos http://en.wikipedia.org/w/index.php?title=Restriction_of_Hazardous_Substances_Directive&diff=554648399&oldid=554639703: Once again, the reference, http://register.consilium.europa.eu/pdf/en/10/pe00/pe00062.en10.pdf, clearly supports the information you've removed. Are Category 4f and Category 4h figments of my imagination? No. Vehicles are both covered and exempt. "Automotive vehicles are outside the scope of the directive. " is nonsense. If you continue to assert otherwise, despite the obvious, unambiguous meaning of Category 4f and Category 4h, I will report you for disruptive editing. The med EEE noted is also covered and exempt. Simply read the category noted within the reference document noted. FFS! "Active implantable medical devices containing lots of toxic metals and plastics may be marketed as RoHS 2 compliant." is simple, accurate, and verifiable using the provided, detailed reference. But you've removed it. Umpteen times. --Elvey (talk) 07:54, 12 May 2013 (UTC)

Direct quotes from the source:

Subject matter: This Directive lays down rules on the restriction of the use of hazardous substances in electrical and electronic equipment (EEE) with a view to contributing to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE.

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 and designed for use with a voltage rating not exceeding 1 000 volts for alternating current and 1 500 volts for direct current;

(2) for the purposes of point 1, ‘dependent ‘ means, with regard to EEE, needing electric currents or electromagnetic fields to fulfil at least one intended function; (3) ‘

Categories of EEE covered by this Directive:...

3. IT and telecommunications equipment....

Category 4f and Category 4h:

(f) means of transport for persons or goods, excluding electric two wheel vehicles which are not type approved;

(h) active implantable medical devices

8. Medical devices...

11. Other EEE not covered by any of the categories above

Commentary notes: RoHS II was expanded. “Electrical and electronic equipment” (EEE) now includes equipment which is dependent on electric current or electromagnetic fields for at least one intended function.--Elvey (talk) 07:54, 12 May 2013 (UTC)

Additions

I will remove the additions portion of the Exemptions section and make it a new section.Prosecreator (talk) 23:01, 10 May 2013 (UTC)

Future possible additions, again? Again, see WP:CRYSTAL. You said "There are too many to list", PC! And then you include this level of mind-numbing detail - why? --Elvey (talk) 23:37, 10 May 2013 (UTC)

No, I was talking about the exemptions. If we're going to have lots of "mind numbing" exemptions, let's mention the possible additions too for balance. Also, you took out the exemption detail and replaced it with statements that appear to support a possible agenda you hold: to emphasize "loopholes", as you say it.

Seriously? See WP:POINT. I've listed a handful of the over 80 exemptions. --Elvey (talk) 20:06, 11 May 2013 (UTC)

See my comment below, Prosecreator (talk) 21:41, 11 May 2013 (UTC)

Current issues with the article:

Your statement: "ANY solder that is over 85% lead is permitted. (Category 7a)" I believe is wrong and/or misleading. Here's how it reads: "7a Lead in high melting temperature type solders (lead-based alloys containing 85 % by weight or more lead)". How about the original?

Can you give an example of a solder that is over 85% lead that is not permitted?--Elvey (talk) 20:06, 11 May 2013 (UTC)

Nope you're right. I wanted to add to the article that solders >= 85 have very limited application, generally high temp applications. Prosecreator (talk) 21:41, 11 May 2013 (UTC)

Your statement: "All the servers, switches, routers, cells and other telecommunication equipment that constitute the global Internet and phone systems are exempt from lead content restrictions. (Category 7b)" is not NPOV. Here's what the reference says and what it used to say in the article:

"Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunication. Allows lead based solders to be used in IT and telecommunications network infrastructure equipment. (Category 7b)". Again, why not the full text?

Why not the full text? Because quoting the main exemptions verbatim is a copyright violation!--Elvey (talk) 20:06, 11 May 2013 (UTC)

If it's cited and quoted, shouldn't that be fine? And do you think the directive text is copyrighted? I think it's public domain. Prosecreator (talk) 21:41, 11 May 2013 (UTC)

Actually, yeah, it's PD. And it's awful legalese. --Elvey (talk) 08:11, 12 May 2013 (UTC)

"There are over 80 exemptions, some of which are quite broad". I think this is my statement, but I can't find verification of over 80, which would be hard to quantify, so it should probably be removed.

You could count the number of exemptions. You're not seriously denying that it's true, or are you?--Elvey (talk) 20:06, 11 May 2013 (UTC)

Nope, you're right -- actually I'm thinking there are more! Prosecreator (talk) 21:41, 11 May 2013 (UTC)

It's silly and bad form to have a one-line section for additions. I'd like to add back the additions and exemption details and move the additions section above or below exemptions or combine them again. What shall we do? Prosecreator (talk) 21:41, 11 May 2013 (UTC)

I've said thrice now: "Shorten 'Future Possible Additions' ?"--Elvey (talk) 23:42, 10 May 2013 (UTC)

As I alluded to above, I thought exemptions were too long. By adding the comparable additions we achieve balance.Prosecreator (talk) 00:41, 11 May 2013 (UTC)

And I ask again, Seriously? No; see WP:POINT. --Elvey (talk) 08:11, 12 May 2013 (UTC)

Prosecreator Responses to Elvey and his Exemption Contributions

Please stop the cursing. Inappropriate language is against the Wikipedia philosophy.Prosecreator (talk) 23:43, 12 May 2013 (UTC)

You are one touchy guy. Believe me I'm not out to get you at every turn, why the vitriol? Anyhow, we have a disagreement in sources it sounds like - did you read them? As you've mentioned the legalese is hard to parse and I believe your interpretation may be incorrect. Prosecreator (talk) 23:43, 12 May 2013 (UTC)

"lots of toxic metals and plastics may be..." - Elvey.

This is imprecise interpretation and borderline commentary, lacks detail or direct citation, and curiously skips over the broader number of categories that are included. We don't need to dumb it down. Which plastics? What toxic metals? Do you have evidence? How about the medical devices that are included! We have a disagreement in sources, see below. Prosecreator (talk) 23:43, 12 May 2013 (UTC)

Here's what the source says about medical devices that I cited in the article ("recast" is referring to RoHS II) Medical Devices under Recast RoHS Regime (my emphasis in italics): Prosecreator (talk) 23:43, 12 May 2013 (UTC)

The RoHS directive did not cover medical devices (and monitoring and control instruments) because of concerns over the reliability and availability of certain substitute materials. Medical devices as EEE are—and have been—dealt with separately because of their relative complexity and the very serious consequences of product failure. RoHS-related restrictions on the use of certain substances combined with requirements for medical devices to meet high levels of performance and safety under other directives have also delayed their inclusion.

Despite this, medical devices and monitoring and control instruments had always been targeted for inclusion within the scope of RoHS. After a European Commission proposal in 2008, various meetings and the consideration of numerous compromise legal texts, the European Parliament and Council adopted a new RoHS Directive in May 2011 (the recast), which finally brought medical devices and monitoring and control instruments within its scope. The recast entered into force on 21 July 2011 and member states have until 2 January 2013 to implement it. The result for manufacturers of medical devices is that new substance restrictions will apply to their products and they will have to comply with EU rules on the CE marking of products caught by the new regime.

Here's the source for vehicles: Prosecreator (talk) 23:43, 12 May 2013 (UTC)

While the Automotive industry does fall outside the scope of the RoHS-Directive, the ELV (End of Life Vehicle) 2000/53/EC Directive does cover automotive industry and its products. And yes, much of the ELV has been carried over to the RoHS-Directive.

Prosecreator (talk) 23:43, 12 May 2013 (UTC)

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B-class assessment

Suitably referenced: there are 65 references throughout the article, of which only 13 are dead (and therefore require alternatives or archived copies). Addressing these and the few "citation needed" tags interspersed would readily clear this criterion. N
Reasonably covers the topic: while I am not a subject expert, its coverage of first the details of the directive, as well as exemptions and labelling, then also comparisons to other regions' equivalents and an appraisal of the value of the directive, provides more than sufficient detail for the average reader looking to find out about the directive. Y
Defined structure: the article is appropriately and logically sectioned and sub-sectioned. Y
Reasonably well-written: the article reads well, with no major grammatical issues or barriers to smooth reading. Y
Contains supporting materials: both a summarising infobox and illustrations of labelling are provided. Y
Presents content in an appropriately understandable way: the article is written in an informative but straightforward way. Y

Based on the above, a relatively small amount of work would not only pass it as B-class, but I believe would also nearly pass it for Good Article classification on the existing article alone. This would require a subject-matter expert to work on it with a respective GA reviewer, but I believe that it shouldn't require a great deal of work at all to get to GA-class (and potentially even FA-class). — Sasuke Sarutobi (talk) 18:15, 4 November 2015 (UTC)

Automotive exemptions?

I believe I've gone over the document in detail, and I can't find where the automotive electronics are exempt. Can anyone verify first that I have the correct document here? And second point to where the exemption is? I don't think automotive is actually exempt and the main page needs to update to reflect this. — Preceding unsigned comment added by 198.135.124.92 (talk) 18:01, 23 October 2014 (UTC)

Good catch, I can't find mention of automotive electronics in the reference you site. The RoHS article mistakenly references a section "4f", but this is incorrect. I believe, however that the directive does not address this and hence it is exempt... We should probably just remove the two sentences. Prosecreator (talk) 20:40, 23 October 2014 (UTC)

The exemption is in the document you have linked to, look at page 4 of the PDF,

"Article 2 Scope subsection 4(f) means of transport for persons or goods, excluding electric two-wheeled vehicles which are not type-approved;"

The statement in the article that Vehicles are instead addressed in the End of Life Vehicles Directive (Directive 2000/53/EC).[22], is not completely true - the scope of the ELV directive is limited, by the definition of a vehicle in Article 2 Definitions subsection 1.

″"vehicle" means any vehicle designated as category M1 or N1 defined in Annex IIA to Directive 70/156/EEC, and three wheel motor vehicles as defined in Directive 92/61/EEC, but excluding motor tricycles;"

From this buses, coaches and heavy goods vehicles are excluded along with some other classes from the scope of both the RoHS/RoHS2 and End of Life Vehicles Regulations. I have recently contacted the UK government department responsible for the enforcement of these regulations ( National Measurement & Regulation Office ) asking what regulation is relevant to class M2 & M3 - the response indicated that they where unaware of legislation that would bring class M2 and M3 in to its scope.

Sorry if this information is not presented in the best way - my first edit - involved in supplying electronics used on buses. Dave bex (talk) 18:55, 1 December 2015 (UTC)

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RoHS = Directive 2011/65/EU (RoHS 2)

This is the main page for RoHS. It should then have Directive 2011/65/EU (RoHS 2) as the main subject, and RoHS 1 should be described as history. — Preceding unsigned comment added by Petermadler (talk • contribs) 20:49, 6 September 2020 (UTC)