Help us Americans, Bjorn! (RoHS)

[Skreddy]

Please, we're so in the dark.

Could you point me to some understandable information about the EU's RoHS law, when it goes into effect, and how we need to comply?

[VacuumVoodoo]

...I'll try to give you some baisc info. I've been through the process of getting my amps RoHS compliant since January.

1. The RoHS directive will become law in EU on July 1st i.e. day after tomorrow.

This means that any product put on the market after July 1st must be RoHS compliant. Anything that is put on the market before July 1st is exempt.
"Put on the market" means that if it is already manufactured and in stock for delivery before July 1st is considered as already "put on the market". So whatever you delivered to distributors or manufactured and stocked for direct sales is considered as already "put on market". MArket is understood to be EU territory. A grey area here is when product is manufactured before July 1st outside of Eu and stocked by a non-EU distributor. I visited Leo F's scandinavian office a few days ago and they were taking truckloads of goods into stock to beat the deadline.

2. Technically RoHS means:

- leadfree. no lead in solder, components etc. Residual amounts of lead in homogenous material are allowed at very, very low levels. Homogenous material means that if a part of a components contains lead than it's that part only that is analyzed for lead content i.e. wires on a capacitor only, not the whole capacitor.
So, use only components that are declared RoHS compliant by manufacturer, don't put all your trust in distributors on this.

- certain flame retardant substances are banned: found in resistors, pcb-material and other components. Same principles as for lead apply.

- hexavalent chrome is banned. Found in steelplating i.e. transformer endbells and such.

It's fairly easy to find almost all components in RoHS compliant version, note "RoHS compliant" "Leadfree" is not enough.
Compliant PCBs - no problem here either.

Problems for us little guys:

- Manual leadfree soldering. It's a bitch. Leadfree solder doesn't flow nicely, a good leadfree joint doesn't look the same as leaded, it's surface is dull and sometimes irregular and it's really hard to see if it's good or poor. Takes time to learn. Leadfree solder requires ca 30degC higher temperature to melt and flow. You must also have a dedictaed soldering iron forleadfree soldering. If you use the old one leadresidue will diffuse into the solder enough to contaminate it.

This I think will be the main concern for us from purely technical point of view.
Those whose product rely on some obsolete component that you stocked enough to last product's lifetime are in a grey area. One example I can think of are old analogue bucket-brigade delay chips once made by Reticon.

A major administrative PITA:

As manufacturer one is expected to do the "due dilligence" in assembling a technical documentation file for each product.
In this file all materials used must be documented with datasheets and a copy of manufacturer's RoHS compliance certificate or its number.

"Producers of goods falling under RoHS" directive are required to register with national environmental agencies (this part 'm not yet sure how to handle and what it really means)

So much for RoHS itself in nutshell. A more worrying directive is WEEE - never heard of it? Here's the deal:
As producer of goods one is also responsible for their proper disposal and recycling once the products has reached maturity fr the scrap yard. Well, we shouldn't worry about that, our electronic works of art will be passed as on as family heirlooms from generation to generation, right?

A light in the tunnel: You can still use leaded solder and non RoHS-compliant components for service and repair work on products that were put on market before July 1st. There should be a sticker with date of manufacture somewhere on the box, no?

I foresee a decline in market for newly manufactured "relic'd" guitars and such following a discovery of a forgotten warehouse with a few thousands of 54 Telecasters in mint condition with certifcates of manufacture date on properly yellowed (relic'd ?) paper.

For more info from folks that make their living by consulting on these matters try THIS LINK (http://www.rohsguide.com/rohs-faq.htm)

[Skreddy]

Thank you. As tough as it is to find RoHS-compliant parts and use that lead-free solder, I suspected the administrative overhead would be the main issue.

As usual I wait for the last minute on everything.

Best regards!

[BJF]

Hi Skreddy,

It does not affect you..........yet, unless you sell to EC, though swartsifonia maybe the first US state to adopt this.

If you'd ask me I'd say it affects me and much because what I ever made never could be massproduced, while by this law I may be forced to or just make protos ;)Oh yea, I'll go RoHs

I learnt all my english from TV and msotly from Monty Python and so I'd say
" The end is nigh" " and now for something completely different.

Yes Alex layed out the text as is

I'm only one or I'd go Lord Valve on those people in Brussels, but many voices are needed.
Now if you'd excuseme I have about 200 pedals to make in two days woohoo!
Life is sometimes ridicooulous, but always there is a streak of sunshine

Take care and have fun
BJ

[Skreddy]

Thank you. I honestly don't know how you do it, building so many pedals. Here's hoping you are visited by friendly pedal-making elves while you sleep.

I do sell direct to every place on the globe, and I have a dealer in London.

I guess I'll have to research the text of the law to see if they are actually regulating me and what I can sell directly to individuals in the EU. I'm thinking that perhaps they donl't have authority, and that individuals in the EU are legally capable of making private purchases of non-RoHS products from overseas. If they're quiet about it. :eek: But, yes; I have every intention of complying nonetheless.

[cusackmusic]

My issue is that i have 1000 assembled PCBs in stock for the Screamer and Screamer Fuzz. Can I still use those as long as everything else is RoHS, or do I need to order new PCB, and use up the other ones in the US?

I am also having a problem getting the vendor for my enclosure (the Tap-A-Whirl one) to send me a RoHS certificate.

I have all the other parts in a file already, so it's a matter of deciding to start using the lead free solder. I hate the solder, and am worried about the longevity of the solder joints.

There's a reason Medical devices don't have to meet the standard yet! It's because the reliability of Lead Free solder is still unknown. What is known is that is it MORE BRITTLE! Which means more fractured solder joints, etc.

Jon

[VacuumVoodoo]

Jon,

are those PCB for EU market?
If yes:

Do you have written orders from your european distributors?
Have you previously delivered identical/same boards in pedals to EU?
Can you prove dates of manufacture?

If yes on all 3 then my personal interpretation of the directive is that these products were put on EU market before July 1st and you should be able to make your deliveries.
What I'm saying is not 100% bulletproof and would advise you to check with proper authorities.

You can still sell pedals with these boards in US and any other country that has not implemented the RoHS directive into law.

[BJF]

Hi Jon,

Aleksander put this well.( as always)

Further more RoHs and WEEE are directives dealing with garbage control.

Good questions would be if you would not use your boards are they then garbage? If you make them into pedals they would not be garbage at least not for a very long time and a timespan that we cannot see at this point.

What the directives should restrict is short term electronics such as McD toys,mobile phones, computors, kitchen appliances et.c. the list is very very long

So the refridgerator manufacturers want to make more refridgerators.....they make them so that they would be useless after a timespan.....
at the refridgerator cementary ozon leaks......environmental effects.....

Amplifiers and guitarpedals and guitars are those such that become garbage these days as once they were in the 70's?


I don't think anyone throws away art that contains lead or other substances just because they do contain this and this would not be wanted either.

What is known about the new solder is just that that it might be brittle and we may not know the effects of this in about 100 years.
In fact one of these days we might just consider concrete a stable material
( though if you put sugar in it it won't harden ;) )

Personally I can see the point of the directives though I'd say they are not not fully thought out.
Directives can be adjusted, but it takes protests

In an effort to avoid further building of garbage mountain service of equipment made prior to July the 1st is encouraged.
By this token and by the moral of this I would encourage you to build your 100 pedals for the joy of musicians.

Thoughts
BJ

[cusackmusic]

I have had several EU dealers ask for RoHS.
I have delivered the same model to SOME of those dealers.
I can prove, by invoices, that the parts were purchased a year ago. I can also prove that the raw PCBs were made two years ago. Lastly, I can prove, by invoice, that the boards were assembled several months ago.

So if I have sent them before AND I can prove the boards were already built, it's OK, but if it's a new dealer, then I have to produce brand new boards for them?

I guess I should have thought of that before I ordered 1000 boards. At least the Tap-A-Whirl and Tap-A-Phase boards are lead free. And I just found out that the switch I use IS RoHS compliant. I was worried about that since it's been built for a long time, and not a very popular switch.

[PedalworX Guy]

What a bunch of bullshit!

Are you telling me the cheap shit coming from China will all be certified?
Or is this a way to keep the slave labor build crap out of the EU countries?

Just trying to get to the bottom of this since obviously someone gains by it all but I am not exactly sure who.

Will this make gear safer than the trains and subways?
With the likes of Al Quieda, Hamas and Hezbollah I am feel so much safer knowing about the RoHS compliant gear

http://i2.tinypic.com/208h3jc.jpg



My first post I kind of felt like I had to make it a good one:D

America's last rebel,
George

[PedalworX Guy]

I have had several EU dealers ask for RoHS.
I have delivered the same model to SOME of those dealers.
I can prove, by invoices, that the parts were purchased a year ago. I can also prove that the raw PCBs were made two years ago. Lastly, I can prove, by invoice, that the boards were assembled several months ago.

So if I have sent them before AND I can prove the boards were already built, it's OK, but if it's a new dealer, then I have to produce brand new boards for them?

I guess I should have thought of that before I ordered 1000 boards. At least the Tap-A-Whirl and Tap-A-Phase boards are lead free. And I just found out that the switch I use IS RoHS compliant. I was worried about that since it's been built for a long time, and not a very popular switch.


So If I understand this John you are trying to kill us all with your non RoHS compliant Tap-A-Whirl and Tap-A-Phase pcbs?:eek:

Oh the horror!

Hey is the stuff on the Space Shuttle RoHS compliant?
I hate to think they might be putting the Astronauts in some sort of danger.

OK, second over the top and uncalled for post.
Only goofing John.


Screw authority,
George

[Skreddy]

Welcome George!

Why do you hate the earth? Treeophobe. :p

Marc

[cusackmusic]

Actually, I AM trying to kill you all with the lead content of the Tap-A-Whirl. I'm even thinking of going to a lead lined box, that way it's protected from kryptonite AND it will give everybody lead poisoning...

But seriously, anybody here know of a good resource that will tell me what documentation I need for customs, etc? I have all the RoHS documents from my parts vendors, so now I just need to figure out how to do my paperwork. (And I need to switch over to that crap lead-free solder too).

Jon

[DocRock]

Is there a reason why lead-free solder is crappy? I know very little about that sort of thing...I'm just a player. But I am curious. Does the type of solder affect the tone? Is the European Commonwealth trying to stop us from having good tone? :p

Best,

Doc :)

[DocRock]

What a bunch of bullshit!

Are you telling me the cheap shit coming from China will all be certified?
Or is this a way to keep the slave labor build crap out of the EU countries?

Just trying to get to the bottom of this since obviously someone gains by it all but I am not exactly sure who.

Will this make gear safer than the trains and subways?
With the likes of Al Quieda, Hamas and Hezbollah I am feel so much safer knowing about the RoHS compliant gear

http://i2.tinypic.com/208h3jc.jpg



My first post I kind of felt like I had to make it a good one:D

America's last rebel,
George

You're not alone, George. :D

[Skreddy]

Is there a reason why lead-free solder is crappy? I know very little about that sort of thing...I'm just a player. But I am curious. Does the type of solder affect the tone? Is the European Commonwealth trying to stop us from having good tone? :p

Best,

Doc :)
It's just that "normal," leaded solder flows at a nice moderate temperature and leaves a shiny, smooth joint. What we have been taught is that shiny solder joints are good. Grainy-looking solder joints mean potential bad contact, and possible breakage down the line. Apparently the lead-free solder melts at a hotter temperature and does not flow as neatly nor leave the shiny surface we look for in a good solder joint. This may or may not result in a lower quality product, but it nontheless seems to be a pain in the ass for those who have to use it.

[cusackmusic]

In addition to what Skreddy said, it is known to be more brittle. It also is unknown as far as long term affects such as thermal expansion, etc. All components and PCBs expand and contract as the temperature changes. This can cuase the pins to try to pull out of the solder joint. If you do not have good wetting, or if the solder itself is brittle, will this cause bad solder joints over time? We don't really know yet...

Skreddy, Get off the message boards and build my pedals, and everybody elses!

And an off topic question: Does anybody know someone who can make me a banner add for this message board? I'm supposed to have one, but I haven't had time to make a good banner add.

[Skreddy]

In addition to what Skreddy said, it is known to be more brittle. It also is unknown as far as long term affects such as thermal expansion, etc. All components and PCBs expand and contract as the temperature changes. This can cuase the pins to try to pull out of the solder joint. If you do not have good wetting, or if the solder itself is brittle, will this cause bad solder joints over time? We don't really know yet...

Skreddy, Get off the message boards and build my pedals, and everybody elses!

And an off topic question: Does anybody know someone who can make me a banner add for this message board? I'm supposed to have one, but I haven't had time to make a good banner add.
:eek:

Okay. :cool:

http://skreddypedals.com/avatars/Cusack352x161.gif
:D

[cusackmusic]

That's it! OK Dean, can you use that one?

Jon

[Skreddy]

That's it! OK Dean, can you use that one?

Jon
I can make you a proper one, Dude... :D

[cusackmusic]

What's wrong with that one? Other than copywrite issues?

[Donner]

Im wondering if the brittle lead free solder will even survive being shipped overseas.... anyone tried yet ???

[Skreddy]

What's wrong with that one? Other than copywrite issues?
It was supposed to be a joke, but I suppose if John Cusack has no problem with it...

Or you could use this less funny one. Your choice!
http://skreddypedals.com/avatars/CusackBanner.gif

[PedalworX Guy]

Although a little off the topic does anybody know where the hazzards of lead solder lay that RoHS standards are trying to address?

Is it the fact that most electronic crap (computers, cel phones and such) made today only lasts a few years and then will be filling land fills and the water supply with lead and other toxins?:confused:

Regards,
George


http://www.ted.com/tedtalks/tedtalksplayer.cfm?key=al_gore&flashEnabled=1

http://www.climatecrisis.net/

[cusackmusic]

OK, that one is pretty cool! Now I just have to get it to Dean to post!

Thanks Skreddy, you da man!

Jon

[Skreddy]

OK, that one is pretty cool! Now I just have to get it to Dean to post!

Thanks Skreddy, you da man!

Jon
Thank you! Now it's back to work for me! :)

I'm making your Dual Loops with color labels, BTW. Not that you'd care or anything. But they look sweet. I recon I'll be using color on those from now on.

[VacuumVoodoo]

http://www.edn.com/article/CA6351285.html?nid=2431&rid=533941648

Still a lot of grey areas...

[PedalworX Guy]

Thank you for the reading Voodoo.

While noticing that expensive cel phone as well as cheap cel phones last about a year I can understand the RoHS thing a bit. Computers don't seem to hit the land fills for about 5 years.

On the other hand guitar amps and pedals should not be built like these modern day wonders. I realize the Dano pedals are and perhaps RoHS makes sense there as well.

IMHO, true "Boutique" guitar gear should be made to last a life time with proper maintenance and thus the RoHS thing should not apply. I, for one, will spend a lifetime making sure my stuff doesn't end up with all the cheaply made Taiwanese crap and would only conform to the standard under protest since it's obvious, to me, why the standard is in place in the first place. After all it won't make any of my hi-tech appliances last as long as my guitar gear.

regards,
george

[BJF]

Hi,

What do you do as pedal manufacturer ?

Well, if you're small and I know there are quite a few builders out there building fine pedals much for the passion of it and if possible for a living, you might want to think about what your market is and where it is.

The EC market is hard to get into and these days, as about a year ago Maxon failed to get into the market.

The RoHs is also about building barricades and as Aleksander told me the other day China has e´ven strikter laws- this means they can sell around the globe but very few can get into the chinese market- OK so I know there's one DRD in China, and I'd not consider that a big market. I'd like to sell one pedal too the Faraoe Island just to do that and besides it's the sweetest island.
I can say though that for as many years I have had worldwide distribution, apart from Finland there are few BJF pedals within EC and that's even with something like 30 store in other countries than Finland that carry BJF.
Even in Sweden, my home country there are few pedals and few stoores carrying them, but those that do are good stores.
The average BJF owner in Sweden is a semi or professional musician and there are not too many of those.


Now, as a manufacturer you have a choice to sell to non EC countries only or go ahead with Rohs.
So anyone making fuzzpedals with old germanium transistors say in England could make all fuzzes but not sell them within EC nor to China
This may come to some consolation to some
There are ways of constructing with lead free components and lead free solder, but it has a cost and it may affect what components can be used and it may affect durability and longterm use

On the otherhand if you think about where your market is you can make the decision.

The RoHs law is still young and there may be developments and definitions.
So Skreddy if you really want to sell to EC at this point there is no other way than to go leadfree in all homogenus materials.
However you may sell a prototype disregarding RoHs- this law is about massproducts not development.
At this point RoHs does not apply in US and it is yet unknown if it will and if so to what extent.

Pending development and plans for EC I have removed the CE marking on all pedals made and thus they cannot be sold in EC..

The best of luck to you Jon and it's a good thing there won't just be Danelectroes and EH's.

I would agree with you brother George, and perhaps one has not yet seen the end of this

More to follow

BJ
'What It Is' Steven Bruton

[VacuumVoodoo]

Some interesting information in the recent RoHS exemption status report, page 9 item 4/3 and 4/9. At this time it is not known if these even will be debated and voted by EU but at least our problem/situation has been noted.

Download the RoHS exemption report (http://%3Cbr%20/%3E%0Ahttp://anacon-tech.com/IPdocs/re4view_issue28.pdf) (from my site, 350kB too big for board attachment)

[BJF]

Hi,

Impact on business and techniques to combat and stay in business in light of RoHS is a topic in the manufacturers forum- this may be of very little interest to other than manufacturers.

Any part of this that would affect let's say availability of goods or other that could be of common interest would be good to have on this thread and as we speak EC dealers are sorting out what to carry and many US made things are hard to get- this includes even Voodoo Lab, EH, Fender just to name a few.
In US this may have no to very little impact at this point.

Thanks and carry on
BJ