Proving that your electronic products are compliant with the European Union’s (EU) RoHS restrictions may be more than simply sending compliant products into European distribution. Many manufacturers plan to demonstrate compliance by showing they have implemented a system that vets suppliers and maintains material content records. With that due diligence in place, manufacturers believe they can confidently ship their products to Europe.
According to Michael Topolovac, CEO of Arena Solutions, a product lifecycle management company in Foster City, Calif., the alternative to creating a system to ensure compliance is maintaining evidence that each individual part is compliant. “With the caveat that it’s early in the enforcement process, companies that sell product in Europe have to do one of two things,” says Topolovac. “They have to prove that each product is RoHS compliant and that every part in the product is compliant – and show evidence. Or, they need to prove and document that they have a compliance system with tools and procedures to prove their products are RoHS compliant.”
Topolovac notes that proving you have a compliance system is less overwhelming than maintaining individual records on every component. “If you have a product with 3,000 parts, you would have to show that each and every one is compliant. You would have to spot check that by going through the process of making sure it’s compliant, and it’s easy to make a mistake,” says Topolovac. “It’s make more sense to create a system that shows you’re taking measures to ensure your products will be compliant.”
Even large companies have struggled and ultimately faltered in their effort to become RoHS compliant. Two major producers of consumer electronics – Apple Computer Inc. and Palm Inc. – actually held back product destined for Europe because they were late in their rush to produce RoHS-compliant products. “A lot of companies didn’t really believe RoHS would take hold on July 1,” says Topolovac. “The deadline hit and companies like Apple pulled product from the market because they were out of compliance.”
Topolovac notes that Europe’s plans for screening products and punishing non-compliant manufacturers remains a mystery. “It’s still not clear how you prove compliance and what the punishment will be,” says Topolovac. “Will it be a million-dollar fine? A $5,000 fine? Jail time? We don’t know yet.” He believes the EU will initially target large producers to signal their plans for screening products and punishing non-compliant manufacturers. “The shoe will drop when a couple big companies get hit,” says Topolovac. “We’ll learn how they plan to enforce RoHS when those large companies get fined and their products get shipped back.”
A good portion of the electronic manufacturing industry is not fully knowledgeable about RoHS and its implications even as the deadline has come and gone. In survey results released in July, Arena Solutions showed that 59 percent of respondents do not have a good understanding of RoHS regulations and don’t know what was involved in demonstrating compliance. A full 60 percent admitted they are not confident they can track all parts and materials in their products. And with new regulations coming on the tail of RoHS, 63 percent of manufacturers conceded that their current compliance solution is not set up to manage multiple regulations or revisions to existing regulations.