Remove Red Tape

Products and Equipment

These regulations result from the implementation of European directives on the free movement of goods, e.g. electrical equipment, household appliances, toys, radio and telecommunications equipment; supply of machinery; lifts etc. They also include regulations relating to the previously nationalised industries, such as iron, steel, aircraft and shipbuilding.

You can find all 83 regulations that relate to products and equipment below to the left.

Tell us what you think should happen to these regulations and why, being specific where possible:

• Should we scrap them altogether?
• Could their purpose be achieved in a non-regulatory way (eg through a voluntary code?) How?
• Could they be reformed, simplified or merged? How?
• Can we reduce their bureaucracy through better implementation? How?
• Can we make their enforcement less burdensome? How?
• Should they be left as they are?

14 comments on “Products and Equipment”

1. Bob Worsley on September 1, 2011 at 9:19 am said:

   Many of the comments about WEEE, RoHS and tin lead solder have been very ably described above.

   I would like to add that I used to manufacture small position measuring units for machine tools. These were sold all over the world until the WEEE directive put me out of business. The costs of complying are foolish, last time I looked, when I contacted my MP, there was an annual charge to the EA of about £4,500 pa.

   When WEEE came in I added up all that I had sold in the then 15 years I had been trading. It came to about 800kg in total weight. Being that the WEEE directive wants the weight of items sold to an accuracy of +/- 2 tonnes, per annum, rather makes by 100kg or so irrelevant. Does this make me exempt? Of course not.

   As to lead free solder, I entirely agree with other comments that it is impossible to RELIABLY hand solder with this stuff. It is now very difficult to buy pin in hole components, and I would love to see one of these ‘experts’ hand solder a quad flat pack, TSSOP or similar package, I use SOIC and PLCC and they are hard enough with lead solder.

   Perhaps lead free is fine if you have a million £ flow solder set up, I don’t. All mine is hand soldered, and yes, I did try reflow soldering but the paste goes off so quickly you have to keep buying it.

   What seems to be lost is just how little lead is used. I simply can’t believe the 1% pa figure. Just look how many car batteries are sold each year. In any case I would happily pay, say, £50 per kg for tin lead solder. A solder joint uses miniscule amounts, a 500g reel used to last me for more than a year spread over several hundred items.

   As a side issue, lead is banned because it is hazardous in the environment. We own a small wood, the sporting rights of which are reserved to another. So, about eight times per year a dozen or so people walk through blasting off at anything with their shotguns. Each cartridge has 30g of lead in it, They fire 100+ cartridges each on each shoot. As the gun is fired some of the lead shot is abraded into dust along the bore. All this is spread liberally over an ancient woodland site. So why isn’t it bad for the environment?Comment Tags: cost, lead, RoHS, solder, weee
2. John Chubb on August 14, 2011 at 10:10 am said:

   I ran a small company manufacturing electrostatic measuring instruments up till February 2009. While never a large company about 60% of the business was exports across the world. The WEEE regulations required us to analyse and report the quantities of the materials used in our instruments and to have arrangements to dispose of our products at the end of their life. It was quite impractical for us to know where our instruments might end up or to expect customers to return them at the end of their life. We therefore put a comment in the user manuals requesting that instruments be disposed on with regard to recycling, etc. The quantities of metals used in our instruments were in the range of a few kg a year. It would also be very expensive for us to consider dismantling any instruments that we had that were returned or were with us at the end of their life.

   The restriction on the use of lead free solder raised serious problems for a small company where quite a bit of work involved hand soldering.

   My recommendation, which I had communicated to the Dept Business, was that WEEE regulations should not be applied to companies making less than a defined quantity of product in a year.Comment Tags: weee
3. Paul Mardon on August 11, 2011 at 1:43 pm said:

   RED TAPE CHALLENGE -
   REQUEST FOR THE EXCLUSION OF SME’s AND
   COMPANIES PRODUCING PROFESSIONAL, LONG LIFE EQUIPMENT
   FROM THE BURDEN OF THE WEEE REGULATIONS

   Exclusion of SME’s:
   Disproportionately for SME’s, the WEEE regulations are a bureaucratic and administrative burden, financial burden and extra worry, making it more difficult for UK electronic and electrical manufacturers to compete in the global market and survive to provide UK employment.

   These regulations are another complexity, obstacle and discouragement to the start up of the new innovative companies that the country needs.

   Exclusion of Low WEEE Manufacturers:
   The WEEE regulations and their charges for disposal of equipment should be for companies who actually produce electronic and electrical waste. I.E. companies who produce equipment with limited life like light bulbs, strip lights and general ephemeral “throw away” consumer equipment.

   The majority of UK companies have been forced out of such markets by low cost Far Eastern manufacturing and most of those remaining now concentrate on producing Professional Equipment, built for reliability, durability, maintainability and repairability.

   I maintain that companies who already care about the planet, the environment, sustainability, and who endeavour to produce robust, durable, indefinite life, repairable equipment should be acknowledged for doing so by being excluded from the WEEE regulations and requirements.

   We should NOT be treated in the same way as companies producing limited life equipment, ephemeral equipment and products with built in obsolescence.

   Submitted by:
   Paul F. Mardon
   (MA Cambridge University, Engineering)
   Founder (1970), Technical Director & Managing Director
   Pulsar Light of Cambridge Ltd.
   3 Coldhams Business Park
   Norman Way
   Cambridge
   CB1 3LH
   UK
   www.pulsarlight.comComment Tags: weee
4. Ian Benton on August 8, 2011 at 7:52 am said:

   I refer to The Restriction of the Use of Certain Hazardous Substances
   in Electrical and Electronic Equipment Regulations 2008

   Cadmium Suplhide
   See:
   www.silonex.com/announcements/Marshall_support_letter_01_08_07A.pdf

   The report from OKO-Institut on alternative circuitry for audio use is just plain WRONG.Comment Tags: ian@electrovision.co.uk
5. Paul Mardon on August 4, 2011 at 9:44 pm said:

   REQUEST FOR THE EXCLUSION OF SOLDER
   FROM REDUCTION OF HAZARDOUS SUBSTANCES (RoHS)

   Solder is the metallic, electrically conductive “glue” that mechanically and electrically connects virtually all electrical components together. Good solder is the crucially important corner stone required to produce reliable, robust, durable electronic products.

   The research to find the most suitable metallic alloy for solder was done in the 1950’s and before. It consists of a eutectic alloy of Tin 63% and Lead 37% (sometimes 60%:40%). Metallurgy is a relatively mature science – the number of metal combinations is limited by the number of metals in the Periodic Table, which won’t change! The Tin-Lead 63:37 solder works perfectly on all fronts and nothing better has been found.

   The EU had concerns that Lead would leach out from waste electrical and electronic products in landfill. It had been shown that the Lead in Cathode Ray Tube (TV set) Glass could be made to leach out using acetic acid (vinegar) so the EU included Lead as one of the six substances in RoHS.

   Subsequent research found that:
   1. Lead does not in fact leach out from electronics in real land fill sites.
   (Ref: Is this Ban Really Necessary? A Critical Investigation of the CRT Ban by Clark Akatiff Landfill Supervisor City of Palo Alto May 2002)

   2. And scientific research by the USA Environmental Protection Agency – “Solders in Electronics – a Life Cycle Assessment” www.epa.gov/dfe/pubs/solder/lca/index.htm found that:
   The replacement Lead-Free solder is worse than the traditional Tin-Lead solder for:
   a) Ozone depletion
   b) Global warming
   c) Energy use
   d) Water quality
   e) Non Renewable Resource Use – It takes 453Kg more Non-Renewable Resource from the Planet to use 1000cc of Lead-Free solder than it does traditional Tin-Lead solder. (Translated to petrol equivalent 453Kg of NRR = 162 gallons of petrol.)

   In spite of the American scientific research from the USA showing:
   1. That there was no need for the ban on Tin-Lead solder and
   2. That Lead-Free solder is worse for the planet and the environment and
   3. Protests from industry about damage to reliability and durability of products,
   the EU ploughed on with the legislation.

   The USA Environmental Protection Agency’s assessment assumes products will be equally reliable using Lead-Free solder. They are not – it’s far worse than that. If a product using Tin-Lead solder works reliably for say 20 years, the version of that product built using Lead-Free solder may only last 5 years before it fails and is scrapped. Thus four times as much solder is used and four times as much Electronic and Electrical Equipment goes to waste! The complete product is built four times over instead of once, creating a massively higher burden on natural resources from the planet and cost to the environment!
   (You may have noticed that you have to pay dearly to get a longer guarantee than one year on today’s Lead-Free consumer electronics.)

   Why? Because Lead-Free solder is technically worse than Tin-Lead solder in every aspect.
   Compared with the ideal characteristics of Tin-Lead solder, these are some of the defects of the replacement Lead-Free solder:
   1. Tin-Lead solder melts at the optimum temperature of 183oC – hotter than the maximum working temperature of electronic components so it won’t melt in use but not so hot it overheats and stresses components, plastics and circuit boards during soldering. The SAC Lead-Free solder however melts at 217oC and the SC Lead-Free solder at 227oC, wasting energy and stressing components.

   2. Lead-Free solders make poor quality and unreliable connections. The Lead-Free solders’ lack of surface tension in the liquid form and poor ability to alloy with the metals they are supposed to be joining mean they do not wet the surfaces well or wick up through circuit board via-holes and onto top pads for example, making less reliable connections.

   3. Lead-Free solders grow Tin Whiskers, causing short circuits in electronics. Notable examples are the loss of satellites, the shutting down of a nuclear power station, short circuits in watches, recall of heart pace-makers. This NASA web site:
   http://nepp.nasa.gov/whisker/reference/tech_papers/2006-Leidecker-Tin-Whisker-Failures.pdf
   gives an idea of the scale of the problem. It is estimated that the damaged due to Tin Whiskers amounts to $10-40 billion. Tin-Lead solder does not grow Tin Whiskers.

   4. At all temperatures below 13.2oC Tin and the Lead-Free solders gradually change from the silvery metallic state to their preferred low temperature allotropic state – a grey, non-conductive powder, breaking connections and causing product failure. This is known as Tin Pest. The tin powder can fall onto other parts. If the temperature rises the tin powder changes back into its metallic state causing short circuits and product failure.
   (E.g. http://www.periodictable.ru/050Sn/Sn_en.html ).
   Tin-Lead solder does not suffer from Tin Pest.

   5. Lead-Free solders are more brittle and less ductile. A Boeing study estimated that Lead-Free solder would be 20x as likely to fracture due to vibration. Keep Lead-Free solder out of aircraft please!

   6. Lead-Free solders are more brittle and less ductile. They therefore fracture under conditions of thermal expansion and contraction. E.g. www.playbackups.com/Playstation3-xbox-360-repair-repairs-manchester-bga-solder.html

   Using the Lead-Free solder mandated by RoHS means that besides its greater life cycle costs to the Planet and the Environment of the solder itself, listed at the top:
   Products are less reliable and fail sooner.
   More products are therefore scrapped and go to waste.
   Customers suffer.
   Manufacturers are hit and could be bankrupted by loss of reputation and hence sales, or the cost of guarantee claims.
   Including solder in the RoHS directive therefore actually encourages short life electronics and the “Throw Away Society”, puts greater demands upon the Planet’s resources, increases damage to the Environment and has a Huge Cost to Society.

   Requests:
   1. I hereby ask that solder is no longer included in the EU RoHS Directive.
   2. The choice of solder should be left to manufacturers to decide.
   3. At the very least the UK should set an example and send a signal to the EU by refusing to condone this folly by refusing to enforce the use of Lead-Free solder in electronics.

   Further information and the injustice and absurdity of the situation:

   Lead is used for:
   The flashings on the roofs of 90% of our buildings – all out in the acid rain,
   Leaded lights, Stained glass windows, Church roofs, Organ pipes,
   Water pipes to older houses,
   Tankards,
   Etc.

   325,000 tons of lead is used annually in the UK by ALL industries.
   Only 1% of this lead is used, however, in the Electronic and Electrical Industries.
   Our small amount of lead is not out in the rain, or where it can be touched, or drunk from, but is encased inside a product – so why pick on us?

   There is no health issue to solve:
   Since red and white lead oxides were removed from paint and since lead was removed from petrol in the 1970’s, the level of lead intake in the UK has fallen to around 1/20th of the World Health Organisation’s Provisional Tolerable Weekly Intake of 1.5mg per person per week. It probably won’t go much lower because lead is an element that occurs naturally in soil and is therefore in our food as a trace element.

   In the past we could all breathe in lead particles and compounds from exhaust fumes and from our streets, and babies could chew on toys painted with lead paint, so stopping these uses was wise.
   There’s no need, however, to throw the baby out with the bath water.
   No one chews on the circuits inside an electronic product.
   And no-one comes to any harm because the Palace of Westminster’s roof is covered in acres of lead or because the Queen Elizabeth II Conference Centre – a very elegant Government building just across the road from the House of Parliament is completely clad in lead!

   Because Lead-Free solder is unreliable, the Military, Aerospace, Railways, Automotive and Medical Equipment are exempt and may use Tin-Lead solder. Smaller companies like ours do not have the clout to win exemptions. (I did apply but heard nothing.)

   I asked the RoHS Enforcement Officers three time if there was any reason why Lead-Free solder was better than Tin-Lead solder for the planet, the environment, for products or for society, in case I’d missed something, and three times they were unable to give me a single reason in favour of Lead-Free solder.

   Every time the Enforcement Officers “persuade” a company to comply, they increase use of the planet’s non-renewable resources, increase damage to the environment, damage product reliability, increase waste, disadvantage customers, damage manufacturers and generally cost society. How can they do this with a clear conscience???

   About Pulsar:
   I started the business in 1970 from one corner of my bedsitter. In the 41 years since then we have created 3,200 man-years of UK employment and brought in over £100 million of export earnings to the UK. We invent, design and manufacture electronic lighting equipment for professional entertainment and architectural use. The determination to produce robust, reliable, durable, maintainable, eco-friendly products is coded into every strand of our corporate DNA. We make products in the tradition of great British Engineering. Our customers proudly tell us that products we built in the 1970′s are still working perfectly (as well as those from the 80′s, 90′s and 00′s).

   During our 41 years we have built a worldwide reputation for the reliability of our products. We are now, however, being asked to throw that all away and use a solder which is worse for the planet and environment to make our products unreliable – this is madness!

   I am blowing the whistle on this devastatingly costly and damaging EU legislative mistake.

   The reliability of our products is sacrosanct. Unreliable products do not give us a sustainable business model where we can continue to provide employment and make our contribution to UK Plc – we refuse to comply.

   [text deleted]Comment Tags: lead free solder, RoHS, Tin-Lead Solder
   • Elliot Mackenzie on August 5, 2011 at 1:12 pm said:

     This is unfortunately EU law, stemming from RoHS legislation. Nonetheless the poster is right: the rule should be scrapped as it is ineffective, counterproductive, and in many cases flouted openly.

     There is plenty of research into this. Possibly one of the more notable reports was conducted by the US government Environmental Protection Agency which concluded that excluding the significant additional costs of manufacturing and wastage, the life cycle benefits of switching to lead-free solder are mixed (EPA Website/”Solders in Electronics”).

     Though I have seen varying figures, lead used in solder represents less than 1-2% of overall lead consumed in industry, so at best the leaded-solder rules are a solution looking for a problem.

     Even within the EU supply chain, the rule is so widely ignored that it can be hard to find suppliers and manufacturers who reliably adhere to it even when it is insisted upon. It isn’t exactly a scientific survey, but I just took a quick look on the [Text deleted] website ([Text deleted] is a major supply of electronic components) and as of today they listed 118 leaded-solder products but only 43 lead-free solder products. Either automotive/aerospace are buying up all the leaded-solder products from Farnell or that’s pretty good going for a banned product.

     Lead-free solder is painful stuff to work with and you end up with increased wastage as the higher temperatures end up frying more boards during manufacturing which all end up as e-waste before they are even sold. You needn’t go far to find evidence of that – PCB manufacturing companies hate the stuff for that reason. Even after the product is sold, it’s more likely to break due to vibration which leads to even more broken bits of e-waste (and annoyed customers). All in all, the ban on leaded solder ends up producing a bigger, rather than a smaller, problem.

     This is also a case where industry has managed to reduce and largely solve its own problems: modern designs make extensive use of SMT (surface mount) components which require a tiny fraction of the solder that older through-hole designs required in years gone by. There are so many layers on modern PCBs that any lead content is typically sandwiched between many layers of inert silicon and copper, and they only way any lead could leech out in measureably quantity would be if they were melted/burnt at extreme temperature (in which case the far bigger health risk is burning plastic).

     It’s very difficult to diagnose the lead content of an electrical board by looking at it, so manufacturers have to trust their supply chain (which can extend 10-20 hops if you look at it closely enough). I would not be surprised to find more than 25% of low-to-mid brand electrical goods and a lesser but still significant proportion of high-end goods you’ll find in any high street store will have lead content even though they aren’t suppose to. Seriously the [Text deleted]a on that one – they wouldn’t have to go far to find it: I have even pulled apart USB sticks purchased from a big brand high street electronics dealer to find solder joints inside which I’m pretty sure are lead.
6. Sam Lawes on August 4, 2011 at 11:54 am said:

   Health and Safety legislation has become tied very closely to fear of litigation, and has resulted in constraints upon the industry, the individual businesses and the individual employees. This is not expert or rare knowledge: every other factory worker and every other employer in the sector will have something to say about such regulations, along much the same lines. I would request, then, not the change of an individual law or regulation so much as an attempt through any legislation which comes about as a result of this consultation to induce a culture change from the cowardice and paternalism of modern ”Health & Safety” themed laws towards the responsibility and ”be sensible and don’t get hurt” attitude that has defined much of our modern history and contributed to many of our greatest successes as a nation.Comment Tags: culture, Health and Safety, litigation
   • Terry Scuoler on August 4, 2011 at 3:07 pm said:

     Hi Sam,

     I am interested in the issue you raise.

     Do you have any examples of how the culture you refer you is negatively affecting the design and implementation of product and equipment regulations?

     Terry
7. Andrew Ellems on July 28, 2011 at 9:09 am said:

   We could improve the job Market by increasing import duty on complete items ie washing machines etc, being imported and reduce to almost nothing the parts required to build these items. Then companies can then assemble the items here in the UK. You will also create jobs by making a dept responsible to ensure that companies that do import such items are then used for assembly and not just a replacement part.
8. Ian Benton on July 21, 2011 at 9:02 pm said:

   RoHS regulations:
   Allow an exemption for Cadmium Sulphide photocells. The reasons given for rejecting the request for an exemption are flawed. There is no simple alternative circuitry. The amount of cadmium in a photocell is less than the amount of arsenic in an LED, but arsenic is not banned but is considerably more toxicComment Tags: cadmium sulphide photocell
9. Ian Benton on July 21, 2011 at 8:53 pm said:

   Allow an exemption for Cadmium Sulphide photocells. The reasons given for rejecting the request for an exemption are flawed. There is no simple alternative circuitry. The amount of cadmium in a photocell is less than the amount of arsenic in an LED, but arsenic is not banned but is considerably more toxicComment Tags: cadmium sulphide photocell
10. Ian Benton on July 21, 2011 at 8:51 pm said:

    Repeal the legislation concerning lead in solder. The research on which it is based has subsequently proven to be flawed. Lead does not leach out of landfill into the water supply. The water supply is more likely to be contaminated by lead from church roofs (and those of the houses of parliament)
    The mandatory use of lead free solder reduces reliability (if it didn’t why would there be an exemption for aerospace), is bad for the environment (increased CO2 generation due to the hotter process, increased requirement for silver) and due to the reduction in reliability results in more EEE in landfill.Comment Tags: lead free solder
    • Terry Scuoler on July 28, 2011 at 10:13 am said:

      Hello Ian,

      I am very interested in your views on the regulation of the use of cadmium sulphide and lead in solder.

      To help me understand what scope there might be for reform in this area. Do you know if these regulations stem from EU legislation or are UK-specific?

      Whatever the origin of these regulations, it sounds you are saying that the evidence base behind them is questionable. Are you aware of any published evidence or studies of the environmental impact of these substances that would support a review of these regulations?Comment Tags: lead free solder; cadmium sulphide photocell
    • Ian Benton on August 8, 2011 at 8:14 am said:

      I refer to The Restriction of the Use of Certain Hazardous Substances
      in Electrical and Electronic Equipment Regulations 2008

      Cadmium Suplhide
      See:
      www.silonex.com/announcements/Marshall_support_letter_01_08_07A.pdf

      The report from OKO-Institut on alternative circuitry for audio use is just plain WRONG. The examples given do not work as well, and require many more components.

      For lead in solder, most points are covered very well by Paul Mardon.
      Also worth noting is that equipment made with lead-free solder is much more difficult to service and therefore is much more likely to be put in landfill instead of being repaired.
      The amount of lead used in solder is insignificant to that used in batteries.Comment Tags: ian@electrovision.co.uk