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

[Larry Phipps]

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
>
> _..._
>
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