RoHS in Eu - Hobbyist Builders exempt; Also lead based solder and Lead free solder OK.

[Eric Swartz - WA6HHQ]

There has been a lot of discussion and confusion on the Elecraft list
regarding the European RoHS (Reduction of Hazardous Substances)
regulations, if hobbyist builders were allowed to use regular lead based
solder and if they were regulated at all by these rules. I'd like to
clarify these points and set your minds at ease. :-)

The RoHS regs clearly state that they -only- apply to commercial
'producers' of electronic products. They do not regulate individual
'non-commercial use' buyers. The regulations and their enforcement only
apply to 'producers' who have a physical presence (Office) in Europe.

 From the Official RoHS regulations:
http://www.rohs.gov.uk/Docs/Links/RoHS%20directive.pdf

---
‘Producer’ means any person who:

(i) manufactures and sells electrical and electronic equipment
under his own brand,

(ii) resells under his own brand equipment produced by
other suppliers, a reseller not being regarded as the
‘producer’ if the brand of the producer appears on the
equipment, as provided for in subpoint (i), or

(iii) imports or exports electrical and electronic equipment
on a professional basis into a Member State.
---

Since our customers are neither manufacturing nor importing our products
on a 'professional basis' they are exempt from the regulations. There is
no regulation of individuals building for their own use. This is where
the hobbyist exemption comes from. They are free both to import parts,
solder and products of any type for personal use and they certainly can
continue to use regular lead based solder for construction.

A large number of commercial producers in Eu and the U.S. agree that the
RoHS regulations exclude those purchasing products and parts for "own
use built equipment (hobbyist)".


 From the Kontron Eu RoHS compliance web page:
http://emea.kontron.com/index.php?id=1148 (They are a large Eu company.)

---
Also there are some exceptions to the RoHS Directive:

* military systems
* avionics systems
* equipment for national security
* own use built equipment (hobbyist)
* spares for products on the market before July 1st, 2006

---

Other companies with identical statements:

http://www.arcom.com/RoHS_and_WEEE/default.htm
http://www.rave.com/COMPANY/RoHSWEEE.html
http://www.maloca.com/print/rohs.htm
http://www.chassis-plans.com/rohs.htm


Clearly our customers are not at risk for RoHS enforcement as a
'producer' and thus they can import kits and build for their own use
using lead based solder. Also supporting this is the continued
availability of regular led based solder in Eu from local distributors.

Here are some direct links to lead based solder distributors who ship to
Europe and the U.S. You can order directly from these suppliers on-line.

http://tinyurl.com/o2zgf www.rapidonline.com - U.K. Company
http://www.digikey.com - U.S. and Eu
http://snipurl.com/vgt6 www.mouser.com - U.S. and Eu


Important Note - Lead-Free Solder is also OK to use:
I'd also like to correct an incorrect statement I made in an earlier
email regarding use of lead free solders to build our kits:

It does -not- void the Elecraft warranty to use lead-free solder to
build a kit. (I was incorrectly confusing this with the use of water
soluble flux solders, which we do prohibit.)

We -do- ask that you have prior experience using lead-free solder for
construction before using it on our kits. It does require much more
care, higher soldering temperatures and much more expertise than lead
free solder. To be honest I see no reason to stop using regular lead
based solder. It is a superior product and much easier to use and
remove. But if you can't find lead based solder, lead-free solder will
work too, just please be careful in its use.

So please feel comfortable to continue to import and build our kits and
to build with regular lead based solder, or if you have sufficient
experience with it, lead-free solder. :-)

73, Eric WA6HHQ
http://www.elecraft.com

_..._

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[N8LP]

Thanks for the clarification on the warranty comment, Eric.

Larry N8LP



Eric Swartz - WA6HHQ Elecraft wrote:

> There has been a lot of discussion and confusion on the Elecraft list
> regarding the European RoHS (Reduction of Hazardous Substances)
> regulations, if hobbyist builders were allowed to use regular lead
> based solder and if they were regulated at all by these rules. I'd
> like to clarify these points and set your minds at ease. :-)
>
> The RoHS regs clearly state that they -only- apply to commercial
> 'producers' of electronic products. They do not regulate individual
> 'non-commercial use' buyers. The regulations and their enforcement
> only apply to 'producers' who have a physical presence (Office) in
> Europe.
>
> From the Official RoHS regulations:
> http://www.rohs.gov.uk/Docs/Links/RoHS%20directive.pdf
>
> ---
> ‘Producer’ means any person who:
>
> (i) manufactures and sells electrical and electronic equipment
> under his own brand,
>
> (ii) resells under his own brand equipment produced by
> other suppliers, a reseller not being regarded as the
> ‘producer’ if the brand of the producer appears on the
> equipment, as provided for in subpoint (i), or
>
> (iii) imports or exports electrical and electronic equipment
> on a professional basis into a Member State.
> ---
>
> Since our customers are neither manufacturing nor importing our
> products on a 'professional basis' they are exempt from the
> regulations. There is no regulation of individuals building for their
> own use. This is where the hobbyist exemption comes from. They are
> free both to import parts, solder and products of any type for
> personal use and they certainly can continue to use regular lead based
> solder for construction.
>
> A large number of commercial producers in Eu and the U.S. agree that
> the RoHS regulations exclude those purchasing products and parts for
> "own use built equipment (hobbyist)".
>
>
> From the Kontron Eu RoHS compliance web page:
> http://emea.kontron.com/index.php?id=1148 (They are a large Eu company.)
>
> ---
> Also there are some exceptions to the RoHS Directive:
>
> * military systems
> * avionics systems
> * equipment for national security
> * own use built equipment (hobbyist)
> * spares for products on the market before July 1st, 2006
>
> ---
>
> Other companies with identical statements:
>
> http://www.arcom.com/RoHS_and_WEEE/default.htm
> http://www.rave.com/COMPANY/RoHSWEEE.html
> http://www.maloca.com/print/rohs.htm
> http://www.chassis-plans.com/rohs.htm
>
>
> Clearly our customers are not at risk for RoHS enforcement as a
> 'producer' and thus they can import kits and build for their own use
> using lead based solder. Also supporting this is the continued
> availability of regular led based solder in Eu from local distributors.
>
> Here are some direct links to lead based solder distributors who ship
> to Europe and the U.S. You can order directly from these suppliers
> on-line.
>
> http://tinyurl.com/o2zgf www.rapidonline.com - U.K. Company
> http://www.digikey.com - U.S. and Eu
> http://snipurl.com/vgt6 www.mouser.com - U.S. and Eu
>
>
> Important Note - Lead-Free Solder is also OK to use:
> I'd also like to correct an incorrect statement I made in an earlier
> email regarding use of lead free solders to build our kits:
>
> It does -not- void the Elecraft warranty to use lead-free solder to
> build a kit. (I was incorrectly confusing this with the use of water
> soluble flux solders, which we do prohibit.)
>
> We -do- ask that you have prior experience using lead-free solder for
> construction before using it on our kits. It does require much more
> care, higher soldering temperatures and much more expertise than lead
> free solder. To be honest I see no reason to stop using regular lead
> based solder. It is a superior product and much easier to use and
> remove. But if you can't find lead based solder, lead-free solder will
> work too, just please be careful in its use.
>
> So please feel comfortable to continue to import and build our kits
> and to build with regular lead based solder, or if you have sufficient
> experience with it, lead-free solder. :-)
>
> 73, Eric WA6HHQ
> http://www.elecraft.com
>
> _..._
>
> _______________________________________________
> Elecraft mailing list
> Post to: [hidden email]
> You must be a subscriber to post to the list.
> Subscriber Info (Addr. Change, sub, unsub etc.):
> http://mailman.qth.net/mailman/listinfo/elecraft
> Help: http://mailman.qth.net/subscribers.htm
> Elecraft web page: http://www.elecraft.com
>
>
>

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[Brendan Minish]

On Thu, 2006-09-07 at 09:47 -0700, Eric Swartz - WA6HHQ Elecraft wrote:

> Here are some direct links to lead based solder distributors who ship to
> Europe and the U.S. You can order directly from these suppliers on-line.
>
> http://tinyurl.com/o2zgf www.rapidonline.com - U.K. Company
> http://www.digikey.com - U.S. and Eu
> http://snipurl.com/vgt6 www.mouser.com - U.S. and Eu


You can also order Lead based solder in the EU from EU based
distributors such as
RS-components Here part number 551-671 is an ideal choice for the
hobbyist
http://rswww.com
or in ireland
http://www.radionics.ie

Farnell also sell tin/lead solders from a number of manufacturers
http://www.farnell.com/

Lead based solders will remain available for the foreseeable future  

Recently I have been doing some work with lead free solders, It's not
very nice to work with and my advice is to avoid lead free solder except
for situations where it's absolutely necessary

73
Brendan EI6IZ

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