Now that the dust has settled on the revamp of the European Union’s Restriction of Hazardous Substances (RoHS) Directive, let’s look at how the changes will affect the electronics industry. First, EU member states have 18 months to transpose the directive into national law. The regulations are expected to take effect no later than Jan. 2, 2013.
The revised RoHS Directive now applies to all electrical and electronic equipment (EEE). “They have changed the definition for electric and electronic equipment,” Kenneth Stanvick, senior vice president of Design Chain Associates, tells Design News. “Before, the primary function of the product had to involve electronics. Two classic examples include a Teddy bear and a greeting card. Both were still functional if the battery were dead. They’ve made the directive more broad so now if only one of its functions is electronic, it’s still in the scope.”
Medical and monitoring equipment come into scope. Category 8, medical devices; and Category 9, monitoring and control instruments, will come into scope by 2014.
A new Category 11 is added. The additional Category 11 now covers all EEE not covered by any other category. It will come into scope by 2019. “While they haven’t added any new materials to RoHS, they did change the scope substantially with Category 11,” says Stanvick. “This catch-all will bring devices such as electromechanical into scope.”
Industry has to prove exemptions. In the past, the EU government had to prove particular products should not have exemption status. That has been reversed with the recast. Now, industry has to prove it needs an exemption (such as the device cannot be produced effectively without RoHS-banned substances). Plus, all exemptions will have expiration dates.
To avoid the expiration date, companies will need to submit renewal applications at least 18 months before the exemption expires. “Design engineers will need to know what is in the product and when any exempted materials will expire. There are 32 exemptions, and some have multiple parts, a, b, or c. They have different dates when the exemptions will expire.” Stanvick says design engineers may want to reuse a part only to find it is no longer exempted.
CE Mark becomes part of RoHS. The CE Marking Directive that requires manufacturers, distributors, and importers to accurately label EEE products sold into the EU is now part of RoHS. “The CE Mark is new for some people,” says Stanvick. “It also includes technical documentation. In the past there was no documentation requirement.” He says that for companies that are already providing documentation, there will be no major changes. “There are also questions about where to put the CE Mark.”
A copy of the final revised RoHS Directive is available here.