Ask the Experts
May 29, 2006 - Updated
July 5, 2007 - Originally Posted

RoHS compliance for SMT and Through-hole equipment

Do manufacturers of SMT and Through-hole equipment need to build their machines in compliance with RoHS and what documentation do they need to provide to their customers?

Ray Whittier

Expert Panel Responses

Depends on what the equipment is and what category (as defined in the WEEE directive and referenced in the RoHS directive), if any, it falls in. Much of it can probably be considered out of scope due to being considered a "large scale industrial tool". If you choose to, or have to, comply then there is no documentation requirement for your customers.

Michael Kirschner
Design Chain Associates, LLC
Mr. Kirschner is President of Design Chain Associates, LLC, focused on helping electronics OEMs comply with RoHS/WEEE requirements, and speeding time-to-market, reducing product cost, and increasing engineering and procurement efficiency.

Yes they do. Any equipment delivered in the EU after July must be constucted of all no-lead components. The only exception would be if an exemption was granted by the authorities.

Bob Black
North America Sales Manager
Essegi Automation
Mr. Black was the President and Co-Founder of Zevatech in 1977 and introduced first Pick and Place System at Nepcon West 1980. Bob is now the President, CEO and Co-Founder of Juki Automation Systems. He is also a Co-Founder of the SMEMA Council of IPC. He serves as a member of SMTA and SEMI..

Stationary industrial equipment are exempt under the RoHS legislation. If, for some reason, your equipment fell under the auspices of RoHS, or if a customer demanded RoHS compliance, your requirements would be the same as everyone else: you must make a "reasonable effort" to ensure that all "homogenous material" within your product do not have the six banned material. This would tend to include a statement of compliance or a materials declaration from all of your suppliers and a statement of compliance from yourself regarding any of your processes or materials.

Dr. Craig D. Hillman
CEO & Managing Partner
DfR Solutions
Dr. Hillman's specialties include best practices in Design for Reliability, strategies for transitioning to Pb-free, supplier qualification, passive component technology and printed board failure mechanisms.
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