Source
ESB
March 09, 2006
Got
any old fashioned – leaded – spare parts?
Say
you’re in Europe and you just bought a piece of equipment that has a 20-year lifespan.
The equipment is not RoHS compliant and doesn’t need to be since the deadline
isn’t until July 1, 2006. Now suppose you need a replacement part for that
piece of equipment five years from now, will you be able to get a non-compliant
spare part?
Technically
yes. Suppliers and distributors can ship non-compliant replacement parts into
Europe as long as the part is destined for a piece of equipment that was
shipped prior to the RoHS deadline. But five years from now, can you expect
that supplier to still be producing non-compliant parts? And if a compliant
version of the part is all that’s available, will it work in your non-compliant
equipment?
As
the RoHS deadline nears, there are plenty of unanswered questions regarding
replacement parts. One of our readers recently asked this interesting question:
“I realize you can continue to ship spare parts to
help extend the life of a product already on the market after July 1, 2006, but
we’ve been advised by one firm that we can no longer ship non-compliant spares
that were not already placed on the market before July 1, 2006.
We can’t imagine that every OEM of an electrical
product is going to create new RoHS versions of old products that may be under
a support contract.”
The
answer is that you can ship non-compliant spare parts that were not on the
market before the RoHS deadline as long as they are destined to go into a
product that was on the market before the deadline. In other words, suppliers
can produce non-compliant inventory after the deadline only if the inventory is
a spare part that goes in a product that was shipped prior to the deadline.
Now
here’s the difficult part. If the spare wasn’t created until after the
deadline, but it extends the life of a non-compliant piece of equipment that
was produced before the deadline, is it exempt? After all, some devices that
can extend the life of a piece of equipment may not actually be technically
considered a spare part – say a hard drive. Yet that device may need to be
non-compliant if it is going to work successfully with the original piece of
equipment.
We
turned to Paul Tallentire, president of Newark InOne to help answer the
question. Newark InOne has a sister distributor in the U.K., Premiere InOne,
that has attorneys who study RoHS long into the night. “We’ve looked at this
question with our experts in Europe and the issue really resolves around that
fact that – and this is ridiculous – in the RoHS legislation there is no
definition of a spare,” says Tallentire. “The tricky part of the word spare, is
what happens when you’re replacing a sub-assembly that is non-compliant? That’s
still unclear.”
Certainly
for exempt industries such as defense and medical, there is no issue. Suppliers
can continue to send non-compliant parts. In those industries, compliant parts
are often not an option. “There are industries that are exempt and applications
that are exempt, so there is nothing wrong with selling non-compliant parts in
the defense or medical industries,” says Tallentire. “Those industries do not
want to repair their equipment with compliant parts because they haven’t tested
that compliant part in the system. That’s especially critical with
performance-sensitive industries like defense and medical.”
Another
uncertainty for those servicing equipment with a long operational life is
whether parts suppliers will continue to produce non-compliant inventory for
many years to come. “The strategy chosen by our suppliers is varied depending
on their production capabilities,” says Tallentire. “Some are changing over to
compliant parts and will no longer stock non-compliant parts, while some are
running compliant and non-compliant production in parallel.”
For
those suppliers that have discontinued their non-compliant line, customers may
have to turn to compliant parts to keep non-compliant equipment running. “We’ll
come to a point where a large number of non-compliant parts will no longer be
available,” says Tallentire, “People will have to repair products with
non-compliant parts. So cross referencing and substitutes will be critical for
distributors.”
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