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 European Union Restriction of Hazardous Substances (RoHS) Directive was published on July 1. It will go into effect on July 21.
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).