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Using Arduino => General Electronics => Topic started by: Lawris on Nov 25, 2016, 09:33 pm

Title: Why the Arduino needs RoHS/CE ?
Post by: Lawris on Nov 25, 2016, 09:33 pm
Hello everyone,


I'm actually looking for informations on RoHS and CE norms to sell electronic material.


I've noticed that the Arduino got both CE and RoHS Compliant logos.

But, Arduino is in the "Electronic low voltage Material" category if I'm not wrong, whether the 2015/35/UE regulation.

However, in this regulation, its written that the RoHS norm apply to electrical equipment designed for
use with a voltage rating of between 50 and 1 000 V for alternating
current and between 75 and 1 500 V for direct current. (see Chapter 1 GENERAL PROVISIONS
Article 1 on http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0035&from=EN)

Arduino is never getting the voltage above, I'm wondering then why the Arduino needs the RoHS/CE certification.



Thanks in advance.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: MarkT on Nov 25, 2016, 09:50 pm
RoHS is about not polluting water tables from waste electronic equipment in rubbish dumps,
and not generating (highly) lethal smoke in a fire.

The regulations for mains equipment is probably not the only place it is mentioned.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 26, 2016, 10:22 am
As has been mentioned, there are restrictions about the sale of products containing lead based solder etc. The problem is that a lot of electronic stuff ends up in landfill and the toxic stuff (lead and cadmium for instance) leach into the waterways.

And CE is required for most things placed on the market in the EU.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 26, 2016, 10:33 am
Quote
However, in this regulation, its written that the RoHS norm apply to electrical equipment designed for
use with a voltage rating of between 50 and 1 000 V for alternating
current and between 75 and 1 500 V for direct current. (see Chapter 1 GENERAL PROVISIONS
No that is the wrong interpretation, RoHS applies to all equipment who's main purpose requires electricity. There are certain exemptions applying to some categories of equipment such as military, medical and building infrastructure. All other categories of equipment on sale in the EU need to be compliment, there is no official logo for this.

CE is required on all goods sold in the EU, it is just a self declaration that the product conforms to all the relevant regulations for that category of equipment. So a CE logo for electronic equipment serves as the RoHS logo as well.

I spent a few years of my life being in charge of regulation at one place I worked for so I have read all the documentation on this and attended training courses on it.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 26, 2016, 10:39 am
As has been mentioned, there are restrictions about the sale of products containing lead based solder etc. The problem is that a lot of electronic stuff ends up in landfill and the toxic stuff (lead and cadmium for instance) leach into the waterways.
Note there has NEVER been any documented occurrence of this happening, nore any measurements suggesting it could happen. This is a theoretical risk only dreamed up by EU technocrats.

Is it any wonder the UK voted to leave.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 26, 2016, 10:48 am
No that is the wrong interpretation, RoHS applies to all equipment who's main purpose requires electricity. There are certain exemptions applying to some categories of equipment such as military, medical and building infrastructure. All other categories of equipment on sale in the EU need to be compliment, there is no official logo for this.

CE is required on all goods sold in the EU, it is just a self declaration that the product conforms to all the relevant regulations for that category of equipment. So a CE logo for electronic equipment serves as the RoHS logo as well.

I spent a few years of my life being in charge of regulation at one place I worked for so I have read all the documentation on this and attended training courses on it.
Does not some stuff needs additional (expensive) testing by a notified body, RF devices for instance ?
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 26, 2016, 10:51 am
Note there has NEVER been any documented occurrence of this happening, nore any measurements suggesting it could happen. This is a theoretical risk only dreamed up by EU technocrats.
Maybe not.

I will ask my partner, who was (now retired) a chemist working for the Environment Agency, her job was the regulating and control of landfill sites. 
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 26, 2016, 11:49 am
Does not some stuff needs additional (expensive) testing by a notified body, RF devices for instance ?
Yes that is all part of the "relevant " regulations that is signalled by the use of the CE logo.
You do not need to actually test the equipment but you have to certify it will meet those regulations. Due diligence is to have it tested but for CE there is no need. The same goes for safety certification. Mind you some companies will insist these things are tested by an external body, these are mainly in my experience German companies.

An offensive is only committed when someone has tested the equipment and found it failing. Then how much of the "book" is thrown at you depends on your attitude to due diligence in the past. That is if you had it tested or your reasons for not having it tested.

I am aware that this is different to FCC regulations on emissions.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 26, 2016, 12:01 pm
Yes that is all part of the "relevant " regulations that is signalled by the use of the CE logo.
You do not need to actually test the equipment but you have to certify it will meet those regulations. Due diligence is to have it tested but for CE there is no need
Intereseting and I am not in disagreement.

I would sell the LoRa trackers I designed, but have always held back because of the special requirments of a RF device, I presumed it needed external notified body testing.

Even it you could self certify, that is a problem because the 'regulations' are not free, and it can be rather expensive to aquire all the ones you would need to be sure your product does comply.

Its a mess for sure, myself I think its conspiracy by 'big business' to kill off inovation and competion from small business.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 26, 2016, 02:08 pm
Quote
Even it you could self certify, that is a problem because the 'regulations' are not free,
What is not free? It costs you nothing to self certify. Or do you mean you have to pay for the documents that tell you what needs to be met?

Quote
because of the special requirments of a RF device, I presumed it needed external notified body testing.
Not in the EU, you can do it yourself. That is you can do the tests required and self certify the compliance.

For FCC you do need an approved external test house however.

Quote
myself I think its conspiracy by 'big business' to kill off inovation and competion from small business.
There is a lot of truth in that, it is called "a high barrier to entry".

In the US FCC and UL are looked at by many as a form of import control.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 26, 2016, 05:40 pm
Or do you mean you have to pay for the documents that tell you what needs to be met?
Directives are free, the actual standards are not, althoug if anyone knows of an online source .......

In the UK you would get them as the equivalent adopted British Standard, not cheap.

There can also be quite a few standards that apply.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: gpsmikey on Nov 26, 2016, 06:12 pm
Quite some years back, we were designing avionics stuff.  The processor we picked was the Motorola 68332 for a number of reasons.  One of the reasons (other than it was a really neat processor) was that it had been developed for the automotive industry and cleverly got around some requirements for EMI - there are different (stricter) regulations that apply to any digital device with a clock frequency above 32khz ... so, the 68332 was developed with an internal phase locked loop multiplier - externally, the processor ran at 32khz but internally, we ran it at 16mhz.  Well, the clock WAS 32khz  :)
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 27, 2016, 07:09 pm
Note there has NEVER been any documented occurrence of this happening, nore any measurements suggesting it could happen. This is a theoretical risk only dreamed up by EU technocrats.
I did ask and the answer was less than convincing.

So it seems likley the ban (on leaded solder etc) was based more on a general 'its a good idea' than actual hard evidence.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 07:18 pm
Note there has NEVER been any documented occurrence of this happening, nore any measurements suggesting it could happen. This is a theoretical risk only dreamed up by EU technocrats.

Is it any wonder the UK voted to leave.
Are you saying that lead cannot oxidize from the solder on a board and leach into water?  A well trained chemist (me) would like to disagree.  That is not only very possible, but I could easily set up an experiment to demonstrate it.  All I'd need is something that is known to be put together with lead solder. 
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 27, 2016, 07:46 pm
Quote
Are you saying that lead cannot oxidize from the solder on a board and leach into water?
No I am saying that there has never been any documented nor experimental evidence that this can happen in land fill with electronic equipment. Sure you can put all sorts of acid on it to make it oxidize but those acids are not found in any landfill situations.

Quote
So it seems likley the ban (on leaded solder etc) was based more on a general 'its a good idea' than actual hard evidence.
Yes, it is known as "the precautionary principle" - which a lot of EU legislation is based on. That means no evidence, but we like banning stuff so we cover our arse. That is why we now have to put up with glues that don't stick, wood preservative that doesn't preserve wood and cold treatments that don't work. This is due to

1) Stupidity
2) Lobbying by companies that seek to profit or cripple their rivals.
3) Stupidity

Same with banning lead in the paint on pencils. You would have to chew through several boxes per days for a few months to exceed minimum safety levels.

Latest one is the proposed ban on glyphosate-based herbicides because traces many thousand times lower than "safe" levels have been found elsewhere. That may be a ban too far and countries are starting to kick back. The whole EU is a farce in this respect and the quicker the UK is out of it the better so they can paint themselves into their own bureaucratic corner.

Did you know there was a ban on advertising water as capable of rehydrating you. That caused such an outrage that they rescinded it, but the stupid bureaucrats still thought it a good idea to introduce.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 27, 2016, 07:56 pm
No I am saying that there has never been any documented nor experimental evidence that this can happen in land fill with electronic equipment. Sure you can put all sorts of acid on it to make it oxidize but those acids are not found in any landfill situations.
I did find a paper which described a test on this they filled some areas of landfill, with normal waste and bits of mangled up electronics and monitored it over a couple of years.

There was more lead detected in the non electronic area, but the difference was small and easily explained by a normal experiment variance.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 08:00 pm
No I am saying that there has never been any documented nor experimental evidence that this can happen in land fill with electronic equipment. Sure you can put all sorts of acid on it to make it oxidize but those acids are not found in any landfill situations.

Acid like that is not found in a landfill?  I could pull lead with dilute carbonic acid at a pH of around 5 or 6.  If I get prolonged exposure I might could even go milder than that.  Rainwater has at least that much acid content, even more if it is "acid rain".

I get that nobody has found it, or measured it around a landfil.  But that's a far cry from saying it can't happen. 
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 27, 2016, 08:10 pm
Quote
I get that nobody has found it, or measured it around a landfil.  But that's a far cry from saying it can't happen. 
I never said that it can't happen. I said that it has never happened, not even a minimal amount. That is what NO experimental evidence means.

Did you read sernet's comments?
Quote
I will ask my partner, who was (now retired) a chemist working for the Environment Agency, her job was the regulating and control of landfill sites. 
and after asking he said:-
Quote
I did ask and the answer was less than convincing.
Show the evidence and I will be all for it, you would not get away with anything as woolly as this in Physics.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 08:16 pm
I said that it has never happened, not even a minimal amount.
You've got your logic wrong.  The fact that it hasn't been observed is NOT proof that it has never happened.  Only that it has not been observed to have happened.  It hasn't happened in a spot they've tested.  It hasn't happened to a level that is above the LOQ for the method they're using to test with.  It hasn't he appened yet.  There's lots you can say from the fact that there is a lack of evidence that something has happened, but it isn't logical to conclude that it has never happened. 
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: srnet on Nov 27, 2016, 08:29 pm
You've got your logic wrong.  The fact that it hasn't been observed is NOT proof that it has never happened.  Only that it has not been observed to have happened. 
Landfill sites the World over are tested for adverse stuff in leachate on a regular basis, they are in the UK for sure. 

So if lead (from electronic stuff) were to be a real risk, why (as far as we know) has it not yet been detected ?
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 08:33 pm
Landfill sites the World over are tested for adverse stuff in leachate on a regular basis, they are in the UK for sure. 

So if lead (from electronic stuff) were to be a real risk, why (as far as we know) has it not yet been detected ?
I can't answer that.  But I do know that it can't logically be said that it hasn't.  And I also do know for sure that if I had a piece here with solder known to contain lead I could demonstrate it.  My guess is that there just isn't enough of it and once it is diluted into the water supply it is simply below detection limits of the tests.  Landfills are also lined and they take great precautions to make sure that leachate doesn't make it to the ground water, but that doesn't mean it can't fail. 

But that doesn't make me feel any better about throwing it in the ground like that.  To me it 's like the global warming thing.   I'm not convinced that humans are the cause of global temperature rise, but to me it doesn't matter.  Surely less pollution in the air is a good thing so to me it doesn't matter if that link is proven or not.  Being cleaner is still a good thing. 
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 27, 2016, 08:50 pm
Quote
You've got your logic wrong.  The fact that it hasn't been observed is NOT proof that it has never happened.
I never said that, stop putting words into my mouth. Reply #17 said:-
Quote
I never said that it can't happen.
So why carry on like that was my position, are you taking up journalism or something? Or is it just the post truth society I keep hearing about?

Let me spell it out again because you seem to be missing the point.
It is at the moment a theoretical risk. It could be a real threat, it could not be. But until there is some evidence then my position would be to keep monitoring but hold off on the legislation. Keep all your energy in coping with real threats with real experimental science behind it, like climate change. I know your position is different.

What would have been better was if they had done more research instead of reaking havoc on the electronics industry. But not the big boys, no, the little folk who had spent decades building up small volume niche products who were wiped out by this legislation. If it is such a good idea then why is it not in the U.S.? Never mind it will come, the EU market has distorted the whole world's electronics industry

If there were any logic then the EU would ban lead acid car batteries, they actually pose a real threat to the environment, much greater than anything electronics could ever pose even in your own dystopian view of things. But then logic and the EU are strangers.

Little point in arguing further, you have made your mind up and I still can't see any evidence. But please stop misrepresenting what I said.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 08:53 pm
I said that it has never happened
Not putting words in your mouth.  Here is a direct quote of you saying that it has never happened.  It is true that it has never been observed, but that hardly means that it has never happened.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 08:58 pm
If it is such a good idea then why is it not in the U.S.?
Really?  The fact that the US does or does not do something has absolutely no correlation to the idea being good or not.  We're sort of known world-wide for our idiotic tendencies.  Not only are we OK with lead in the landfill, we are apparently OK with it flying through the air at supersonic speeds.  No, don't ever base anything on what we do in the US. 

Title: Re: Why the Arduino needs RoHS/CE ?
Post by: larryd on Nov 27, 2016, 09:04 pm
I wonder how many tons of lead has been spread around by wars and sport shooting.


.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 09:07 pm
I know they banned lead shot here for hunting waterfowl. If the game warden comes up and your shells don't stick to his magnet you're in big big trouble.  But I think that had more to do with the ducks injesting the pellets as they scoop up food than the lead breaking down.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 27, 2016, 09:12 pm
Really?  The fact that the US does or does not do something has absolutely no correlation to the idea being good or not.  We're sort of known world-wide for our idiotic tendencies.
First sensible thing you have said on this thread.   :)
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Grumpy_Mike on Nov 27, 2016, 09:14 pm
I wonder how many tons of lead has been spread around by wars and sport shooting.
Yes much more than electronics would contribute I would guess.  :)
That was very much my point, the whole RoSH thing is concentrating on the potential small effects and not looking at the larger scale.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 09:17 pm
Yes much more than electronics would contribute I would guess.  :)
That was very much my point, the whole RoSH thing is concentrating on the potential small effects and not looking at the larger scale.
I'm going to agree with you that RoSH is making a mountain out of a mole-hill and simultaneously ignoring Everest right next to you.  But at the same time I don't see the harm in making things less toxic when we can. 
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: larryd on Nov 27, 2016, 09:21 pm
In sloughs here in western Canada a cup of mud yields lead pellets from past hunting tourism.
I think the horse left the barn.

The mole hill has pellets in it too.
.
Title: Re: Why the Arduino needs RoHS/CE ?
Post by: Delta_G on Nov 27, 2016, 09:37 pm
I wonder how many tons of lead has been spread around by wars
When you bring war into it, not only has the horse left the barn but he took the dog and the chickens and the cows with him.  The lead is the least of our worries in that one.  Hell, we even verify the vintage of wine now by measuring the levels of isotopes from the atomic tests.  That stuff is ubiquitous and everywhere now.  And we wonder why the rates of cancer have gone so high.  When you stand back and look at it, it's really pretty scary.  Cause that genie can't be put back in the bottle.