Here comes RoHS on steroids. The recast version throws a wider net and offers fewer exemptions. The infamous exempt talking teddy bear now has to go lead-free.
The revised RoHS Directive now applies to all electrical and electronic equipment (EEE), not just a few select categories. Category 8 for medical devices and Category 9 for monitoring and control instruments will come under its purview by 2014. Category 11, all other EEE not covered by any other category, will come by 2019.
The exemptions policy will also change. Industry, instead of the EU government, will now have to prove the necessity of an exemption. Exemptions will also have expiration dates, and companies will need to submit renewal applications at least 18 months before the exemptions expire in order for the EU to consider renewing the exemptions.
The revised RoHS Directive will be a CE Marking Directive, which requires manufacturers, distributors, and importers to accurately label EEE manufactured or sold in the EU. Products that are not primarily electronic -- but include electronic parts -- will also lose their exemptions. The talking teddy bear was given as an example of a toy whose function was not primarily electronic, since the bear still functions as a toy if the electronics are not working.
A big industry pat on the back to IPV - Association Connecting Electronics Industries in Bannockburn, Ill. The electronics industry trade group argued successfully that any new materials considered for inclusion in RoHS be considered hazardous based only on scientific analysis. “IPC has advocated over the past two years that any changes to the RoHS Directive be underpinned by a solid scientific examination,” says Fern Abrams, IPC director of government relations and environmental policy. Due to IPC's aggressive lobbying efforts, the revised RoHS Directive does not restrict any additional substances.
Abrams notes that the methodology for evaluating substances for priority assessment is now congruent with the EU Registration, Evaluation, and Authorization of Chemicals (REACH) Regulation. According to IPC, REACH has a robust, scientific evaluation process for evaluating and restricting chemicals.
While the RoHS revision did not add new materials to its list, four substances have been identified for priority assessment in a nonbinding recital: hexabromocyclododecane (HBCDD), bis (2-ethylhexly) phthalate (DEHP), butyl benzyl phthalate (BBP), and dibutyl phthalate (DBP).
Seems like we've been hearing a lot about new RoHS guidelines as of late--I believe Rob, you wrote something recently about new regulations in India. My question is what does all this mean for engineering and manufacturing groups in the States given that Europe is obviously a key market for them and will these new stronger rules finally pave the way for similar and subsequent regulations here?
If your markets are only in the United States RoHS has no affect. There are medical equipment manufacturers and many defense manufacturers who are not affected by RoHS. Global manufacturers, however, have adopted the RoHS restrictions since they don't know which of the products might end up on the European market.
The biggest change in the RoHS Recast is that some portions of the electronics market are no longer exempt from RoHS restrictions. That includes medical electronics. So, if you're a medical electronics producer with a global market, the RoHS restrictions may be newly applicable.
So far, there is no credible movement in the United States to create a domestic RoHS.
This is the only positive news in this whole ROHS issue. We still produce for ourselves withoiut ROHS. I still see too mane peoduction issue which in my opinion dod not justify this ROHS mess. Just last week some connectors melted while in automatic assembly due to high temperature. They all were ROHS, however with a very borderline thermal chanracteristics. Now we need to look for an even more expensive part. We were producing this product to over 10 years without any problem. Now we have burnt connectors and overheated ICs. Also during rework, the ROHS solder smells terrible. I really fail to see any serious benefits. Am I the only one with negative views?
Good points, sensor pro. One of the reasons IPC fought so hard to make sure RoHS changes were based on proven science going forward is because many in the electronics industry criticized the banning of lead in solder, insisting that the EU didn't base the decision on proven science. Many materials experts insist the lead in solder won't leach out in a landfill and they have challenged the EU to prove otherwise, to no avail.
The fact that IPC won on this point during the RoHS Recast is significant.
I thought the whole point of RoHS was that it considers the product from cradle to grave. The fact that lead may not leach out of a soldered joint in a landfill doesn't mean that the use of leaded solders is environmentally benign. In this case, the risks are at the cradle, rather than the grave. The same goes for chromate conversion coatings. I don't think a chromated die casting presents much of a threat to the environment - but a a chromate line obviously does.
In my field (marine engines), we still use a lot of RoHS restricted substances, including cadmium, hexavalent chromium, etc. We are actively looking for good alternatives, and already have a few in place. The U.S. Department of Defense has actually a lot of helpful work in this regard.
There has been a lot of confusion in the U.S. about exactly what RoHS is, what it applies to, etc. I'm sure that these changes will only increase the confusion.
That's an excellent point, Dave. Those who oppose RoHS on scientific grounds do indeed discuss its danger (or lack of) in the product's useful life and after disposal. You're correct about the "birth" part where there would be plenty of exposure.
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