Scott,

I see two issues with your idea - one technical and one more public-relations.

The intent of the limit is to allow for impurities in the production of the
materials. I suppose you can intentionally add the restricted substances as
long as you don't exceed the limits but I can't imagine that a 1000ppm (0.1%)
maximum concentration will be either beneficial or easy to control. (Note Cd =
100ppm or 0.01%)

Caveat Emptor: Intentionally adding the restricted substances within the limit
will, IMO, be perfectly legal however your company may get some unwanted
publicity since you may be perceived as using a loophole to introduce
restricted substances into the EU. Your competition will be well within their
rights to highlight that to your customers.

...Marko


From: Scott Xe [mailto:[email protected]] 
Sent: Tuesday, April 28, 2009 8:55 AM
To: [email protected]
Subject: [PSES] Limit for RoHS Directive

As far as I remember, the original RoHS Directive did not have any limit for
each restricted substance and the limited was introduced by the amending
directive thereafter.  Did anyone remind me where I can find out the reasons
for adding the limit?  I am unsure if the added limit does not mean you can
use small amount of restricted substance but due to impurity in mass
production of consumer products.

Thanks,

Scott

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