RoHS

June 18, 2014


Several days ago I published a blog concerning “Conflict Minerals”.  This is a very real attempt issued by legislatures to lessen or eliminate minerals and substances mined to support destructive political actions taken to subjugate populations.  Necessary actions must be taken by engineers and management to evaluate products received insuring none contain conflict minerals.  Companion legislation has been issues by the European Community (EU )to insure environmental issues are also addressed.  RoHS is the abbreviated name for this directive. Any company doing business in the European Community must adhere to RoHS requirements.  This is mandated policy affecting all manufacturers supplying domestic consumer products or commercial products.  The purpose of RoHS  is to require companies to quantify six (6) materials used in the manufacturer and assembly of products.  Let’s take a look. The European Union set forth RoHS (Restriction of Hazardous Substances) Directive to establish environmental guidelines and legislation to reduce the presence of six (6) materials deemed hazardous to the environment.  To comply, products entering the EU must not have a homogeneous presence of these materials above the following levels by weight percentage:

  • Lead (Pb) < 0.1%
  • Mercury (Hg) < 0.1%
  • Cadmium (Cd) < 0.01%
  • Hexavalent Chromium (CrVI) < 0.1%
  • Polybrominated Biphenyls (PBB) < 0.1%
  • Polybrominated Diphenyl Esters (PBDE) < 0.1%

RoHS Compliance is determined by a combination of supplier certification and engineering design verification.    The directive applies to equipment as defined by a section of the WEEE directive.  The Waste Electrical and Electronic Equipment Directive (WEEE Directive) is the European Community directive 2002/96/EC on waste electrical and electronic equipment(WEEE) which, together with the RoHS Directive 2002/95/EC, became European Law in February 2003. The WEEE Directive set collection, recycling and recovery targets for all types of electrical goods, with a minimum rate of 4 kilograms per head of population per annum recovered for recycling by 2009. The RoHS Directive set restrictions upon European manufacturers as to the material content of new electronic equipment placed on the market. The symbol adopted by the European Council to represent waste electrical and electronic equipment comprised a crossed out wheelie bin with or without a single black line underneath the symbol. The black line indicates that goods have been placed on the market after 2005, when the Directive came into force. Goods without the black line were manufactured between 2002 and 2005. In such instances, these are treated as “historic weee” and falls outside re-imbursement via producer compliance schemes. The following numeric categories apply:

  1. Large household appliances.
  2. Small household appliances.
  3. IT & Telecommunications equipment (although infrastructure equipment is exempt in some countries)
  4. Consumer equipment.
  5. Lighting equipment—including light bulbs.
  6. Electronic and electrical tools.
  7. Toys, leisure, and sports equipment.
  8. Medical devices (exemption removed in July 2011)
  9. Monitoring and control instruments (exemption removed in July 2011)
  10. Automatic dispensers.
  11. Semiconductor device

Batteries are not included within the scope of RoHS. However, in Europe, batteries are under the European Commission’s 1991 Battery Directive (91/157/EEC), which was recently increased in scope and approved in the form of the new battery directive, version 2003/0282 COD, which will be official when submitted to and published in the EU’s Official Journal. While the first Battery Directive addressed possible trade barrier issues brought about by disparate European member states’ implementation, the new directive more explicitly highlights improving and protecting the environment from the negative effects of the waste contained in batteries. It also contains a program for more ambitious recycling of industrial, automotive, and consumer batteries, gradually increasing the rate of manufacturer-provided collection sites to 45% by 2016. It also sets limits of 5 ppm mercury and 20 ppm cadmium to batteries except those used in medical, emergency, or portable power-tool devices. Though not setting quantitative limits on quantities of lead, lead-acid, nickel, and nickel-cadmium in batteries, it cites a need to restrict these substances and provide for recycling up to 75% of batteries with these substances. There are also provisions for marking the batteries with symbols in regard to metal content and recycling collection information. It also does not apply to fixed industrial plant and tools.  Compliance is the responsibility of the company that puts the product on the market, as defined in the Directive; components and sub-assemblies are not responsible for product compliance. Of course, given the fact that the regulation is applied at the homogeneous material level, data on substance concentrations needs to be transferred through the supply chain to the final producer.  An IPC standard has recently been developed and published to facilitate this data exchange, IPC-1752.It is enabled through two PDF forms that are free to use. RoHS applies to these products in the EU whether made within the EU or imported. Certain exemptions apply, and these are updated on occasion by the EU. The RoHS 2 directive (2011/65/EU) is an evolution of the original directive and became law on 21 July 2011 and took effect 2 January 2013. It addresses the same substances as the original directive while improving regulatory conditions and legal clarity. It requires periodic reevaluations that facilitate gradual broadening of its requirements to cover additional electronic and electrical equipment, cables and spare parts. The CE logo now indicates compliance and RoHS 2 declaration of conformity is now detailed (see below). In 2012, a final report from the European Commission revealed that some EU Member States considered all toys under the scope of the primary RoHS Directive 2002/95/EC, irrespective of whether their primary or secondary functions were using electric currents or electromagnetic fields. From the implementation of RoHS 2 or RoHS Recast Directive 2011/65/EU on, all the concerned Member States will have to comply with the new regulation. The bottom line—it remains a complex world and global issues abound.  These issues affect companies trying to market and sell their products to countries far and wide.  We will not be successful unless we “play their game”.  Maybe that’s as it should be.  I welcome your comments.

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