Olander Corporation RoHS Position Statement 11/10/05
This is a living document.
Because the EC RoHS regulations are not finalized
and the legislation and understanding of the legislation keep
This is our current position.
Anyone who knows us knows we do not give "lip
service" to any issue.
We are working to service a diverse customer base.
While this issue affects many of our customers,
Others are not impacted at all.
The Olander Corporation is well aware of the pending EC RoHS
regulations due to take effect on July 1st of 2006. We have been
polling our suppliers since January 2005 to determine which are
in compliance and when those who are not might be.
The issues are:
- Base material
from our suppliers
The vast majority of commercial threaded fasteners sold in
the United States are imported from other parts of the world and
then sold through distributors to the end user. Also, more and
more US fastener "manufacturers" are outsourcing their
Plated Steel Fasteners
The importers purchase parts many months in advance and have
vast inventories on hand to carry them through the manufacturing
and shipping lead time. What this means is there is a lot (hundreds
of millions) of threaded steel fasteners at importers in the United
States with Hexavalent chrome plating that cannot be used in Europe
after June of 2006. We know of only one importer at this time
that has taken it upon themselves to start stripping and re-plating
some of their inventory for distributors that are requesting
them to do so. This one importer is also ordering steel fasteners
with trivalent chrome plating on their incoming shipments.
Other importers will send parts to platers after selling them
to a distributor and the distributor pays to have the part re-plated
and then delivered. Fasteners are relatively inexpensive. To have
a fastener stripped of hexavalent chrome and re-plated with trivalent
chrome can double the cost of the fastener. (A note here; just
because one re-plates a steel part with a compliant plating, that
does not make the part compliant. What about the base steel? No
one has certified that the base steel is compliant. We can't.
We did not manufacture it or purchase it from the manufacturer
and the importers did not ask for certification because they
may have purchased the part over a year ago, prior to any knowledge
about EC RoHS regulations). Until EC RoHS, importers may not
have specified the type of steel from which the fasteners were
to be manufactured. Threaded fasteners are a commodity, not usually
manufactured by the best, most controlled manufacturing facilities.
Another issue is: What platers are qualified to apply trivalent
zinc? Are their lines set up in a way that prevents the trivalent
parts from contamination? The platers that appear to be qualified
are charging twice what we used pay for hexavalent zinc plating.
(Supply and demand)
Trivalent chromate passivation does not provide the same level
of protection from corrosion that hexavalent chromate does. That
is why the industry has been utilizing hexavalent chromate.
For our customers that have been requesting that we certify
that RoHS certified parts will be at least as good, we can't do
The high density, heavy weight, of fasteners leads to high
freight costs as well. A fastener that went to a distributor from
an importer now goes from an importer to a plater to the distributor,
adding freight cost. It is not uncommon to purchase $100.00 of
fasteners and have the freight cost be $25.00. Now it is
going to cost $25.00 to the plater, then $25.00 to the distributor
and $75.00 to strip and re-plate the fastener.
The box of fasteners that used to cost $125.00 now costs $225.00.
This is reality until the importers can get trivalent chromate
zinc coming into the US in volume.
Stainless Steel Fasteners
As far as we have been able to discern, stainless steel threaded
fasteners have nothing in them that would make them non-compliant
with EC RoHS regulations. However, the stainless steel importers
will not issue a statement of compliance on anything purchased
from them prior to that statement date. If we have a statement
of compliance dated 7/1/05, all parts sent to us 7/1/05 or later
would be compliant, but the same part from the same lot at the
importer sent on 6/30/05 would not be. Sounds uncomfortably like
a way to increase sales by obsolescing your customer's (our) inventory
to me. By the way, there are only two large stainless steel importers
in the US. All of us have to play by their rules. (Sounds kind
of like the oil companies.)
US manufacturers from whom we purchase stainless steel threaded
fasteners have had no problem with a back dated statement, we
find it curious that the importers are reluctant to do likewise.
Also at issue are the hundreds of millions of fasteners already
at the distributor level. What to do with them?
Military part numbers
Again, the stainless steel military parts are compliant and
we have certifications from our suppliers.
Steel military parts are not going to be compliant. They have
cadmium plating with a dichromate supplemental treatment that
is non-compliant and they are not going to change. This will
be an issue for any electronics original equipment manufacturer
that has designed in a military part number in their non-military,
non-flight, non-medical application.
This will also be an issue with some non-military manufacturers
like PEM and Captive. While 99% of their manufacturing is for
commercial applications, one or two of their part numbers are
qualified as military part numbers and have non-compliant plating
that the military applications require.
What we have been doing
While we have had requests (less than 30) about our compliance
to the EC RoHS regulations. We have over 1,500 accounts. Many
are medical instrument manufacturers and aircraft subcontractors
that are not impacted by this regulation. We had a medical
instrument subcontractor recently tell us that they did not
want any RoHS compliant parts and were going to ship back
the compliant parts we shipped them because the drawing they manufacture
and assemble to does not specify RoHS compliant plating.
So here we are, a fastener distributor with:
What are we going to do?
- Compliant parts
parts that will always be non-compliant
parts that some of our customers want left that way
- Parts that probably are compliant, but because our supplier will not issue
a compliance statement to us, we have to call non-compliant.
We will quote and ship our customers what they request. If
they want RoHS compliant parts, then they will have to tell
us at the time they ask us to quote, because many of our
customers don't need and in some cases do not want compliant
We are and always have been a stocking distributor, stocking
what our customers purchase.
Since January of 2005, we have been diligently working to ascertain
which of our over 40,000 part numbers are compliant, which are
not, and working to replace the non-compliant with compliant.
We will continue to do so.
On advice from our attorney, we will only certify as compliant
each part for which we have certification in hand from our suppliers,
no more. Initially, we were going to call all the parts
that we are sure are compliant, compliant. (Stainless steel, 6/6
nylon, trivalent zinc plated steel, etc) But, our attorney has
advised against this because we would be making a statement for
which we have no documentation. Some of our suppliers were
going to call all the "seemingly compliant" parts compliant
as well, but changed their minds about the same time we did. I
think that they had a talk with their attorneys too.
We have had some of our customers making the determination
of compliancy based on the information we are giving them. So,
even though we can not call the part compliant, they have.
I envision having to carry inventory in compliant and non-compliant
parts as long as regulations allow some industries to be non-compliant.
As previously stated, this is an evolving situation. There
has not been a day go by in recent memory when we haven't had
a meeting or four on EC RoHS.