Ask the Experts
February 5, 2019 - Updated
July 5, 2007 - Originally Posted

RoHS existing products vs. new products

Regarding RoHS; if we have been building product XYZ for 2 years now and will continue building it for sometime, will it have to be converted to lead free after July 1, 2006? It is my understanding that only NEW products, not product currently in production, will need to be RoHS compliant after July 1, 2006, am I correct?


Expert Panel Responses

To my knowledge, all products not specifically given and exemption by the EU must be lead free.

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..

Nope. New in the RoHS Directive as in "from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)," means newly manufactured, not newly designed. Another way to view it is that Dell can not sell a lead-containing computer in Europe after July 1, but a private transaction of a used Dell computer containing lead is still allowable. Reference:

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.

You have misunderstood the word "new". All products sold into the EU must be lead free with certain exceptions. Just because it is not a "newly" developed product does not make it exempt. In this document "new" means not "used".

Edward Zamborsky
Regional Sales Manager
OK International Inc.
Ed Zamborsky is a Regional Sales & Technical Support Manager for Thermaltronics, located in New York. His position requires frequent customer visits throughout North America and the Caribbean and his position encompasses not only sales but the role of trainer and master applications engineer for all of Thermaltronics products. His expertise includes such specialties as hand soldering, convection and conduction reflow techniques, array rework, fluid dispensing equipment, and fume extraction. Ed has authored many articles and has presented many papers on topics such as; Low Volume SMT Assembly, Solder Fume Extraction, SMT Rework, BGA Rework, Lead-Free Hand Soldering, High Thermal Demand Hand Soldering, Lead Free Visual Inspection and Lead Free Array Rework.

There are folks far more knowledgeable than I on the RoHS Regulations, however I think you are incorrect. The way I understand the regulations is that ANY product offered for sale in EEU nations that is not clearly exempt from the regulation must comply by July 1, 2006. This means the product that you are offering for sale on July 1, 2006 must comply not that you start producing products that comply on July 1, 2006. I also find that for some reason many customers I visit think they are exempt from the RoHS Regulations. There are only a few exemptions so if you think you are exempt you should verify if you are by working with an industry expert/consultant.

Joe Belmonte
Principal Consultant
ITM Consulting
Mr. Belmonte has been a process engineer and process engineering manager in the electronic manufacturing industry for over 25 years, with experience in all aspects of electronic product assembly operations. He is well-known throughout Asia and SE Asia for both his process work and teaching engagements.

Products that will be sold in the EU as of July 1, 2006 need to be compliant with the RoHS legislation. For example, if you are building product XYZ and sell it in the EU in June it can contain lead, antimony, poly-bominated biphenyls, etc. That same product sold a month later must meet the criteria set forth in the EU legislation. Therefore it is not defined by if the design is new, but when the physical device is sold in the region under the jurisdiction. In addition, China has legislation that is being finalized that is a copy of the EU RoHS legislation. Furthermore, it should be recognized that California may be enacting similar legislation (an exact copy of the EU RoHS legislation).

Dr. Brian Toleno
Application Engineering
Henkel Electronics
Dr. Brian Toleno is the Application Engineering Team leader for Henkel Technologies. He is responsible for the technical service and application engineering for Henkel's electronics assembly materials, including solder paste, underfills, PCB protection materials, and underfills.
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