SV: [sdiy] ROHS sales questions/people selling in europe

[John Alex Hvidlykke]

Hi Dan

> since the vactrol thread has veered off in a different direction,
> I thought I would ask this in a new thread.
>
> I am wondering if
>

...

> 3. Someone told me that you CAN sell a product in EUROPE with ONE
> VACTROL IF the total weight of the CADIUM IN THE TOTAL BOX is
> under .01 or .001% BY WEIGHT
>
> which would make it impossible to sell VACTROLS Directly to the
> EU BUT possible to sell A compressor with ONE LDR or maybe a
> tremelo with ONE vactrol if you used a HEAVY enough  box and
> other ROHS components

I would hope so, but I doubt it. I have pasted the relevant part of the
directive below. As far as I understand the text, the limits apply to the
smallest part of the product, that cannot be separated from the rest (for
instance the copper part of a wire, but excluding insulation). In that case
"the smallest part" would probably be the vactrol itself or the LDR part of
the vactrol.

\John


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Maximum Concentration Values
26. For the purposes of the RoHS Regulations, a maximum concentration value
of
up to 0.1% by weight in homogeneous materials for lead, mercury, hexavalent
chromium, PBB and PBDE and of up to 0.01% by weight in homogenous materials
for cadmium will be permitted in the manufacture of new EEE. These values
were
established through the adoption of a Commission Decision on 18 August
2005.13

27. "Homogeneous material" means a material that cannot be mechanically
disjointed into different materials.

28. The term "homogeneous" is understood as "of uniform composition
throughout",
so examples of "homogeneous materials" would be individual types of
plastics,
ceramics, glass, metals, alloys, paper, board, resins and coatings.

29. The term "mechanically disjointed" means that the materials can, in
principle,
be separated by mechanical actions such as unscrewing, cutting, crushing,
grinding
and abrasive processes.

30. Using these interpretations, a plastic cover (for example) would be a
homogeneous material if it consisted exclusively of one type of plastic that
was not
coated with or had attached to it (or inside it) any other kinds of
materials. In this
case, the maximum concentration values of the RoHS Regulations would apply
to the
plastic.

31. On the other hand, an electric cable that consisted of metal wires
surrounded by
non-metallic insulation materials would be an example of something that is
not
homogeneous material because mechanical processes could separate the
different
materials. In this case the maximum concentration values of the RoHS
Regulations
would apply to each of the separated materials individually.

32. A semi-conductor package (as a final example) would contain many
homogeneous materials, which include the plastic moulding material, the
tinelectroplating
coatings on the lead frame, the lead frame alloy and the gold-bonding
wires.