European customers are beginning to ask for RoHS compliance in request for proposals, said Chris Ingle, an analyst at IDC based in London. As far as vendors being compliant, "whether that's true or not we will just have to wait and see come the date," he said.

The onus of compliance to the law "is on the producers and distributors, VARS (value added resellers)," said Darr Greenhalgh, director of supply chain solutions at Arrow Electronics Inc. in Melville, N.Y. Nonetheless, he said, "part of the issue is awareness. We always recommend that anyone who is affected by this put an internal task force together to understand the impact of this regulation."