Rob, at face value, the recast seems to place some pretty onerous demands on manufacturers. In reality, though, how do you think these tougher and more defined restrictions will impact US companies producing products that utilize electronics? Will it call for major changes to engineering and manufacturing practices?
More restrictions and jobs for regulators. How do they want us to jump start the economy if producing products becomes more and more expensive.I still battle with the ISO9000. Even theough on the surface it is a very good idea, in reality is the company make garbage, the ISO9000 will make sure that they make garbage consistently.
My organizations products offered in europe come with the notice that " because our products are worth cecycling, you may return our product to us and we will pay for the shipping". The result is that our products will never enter the waste stream, and the fact is that they are worth both recycling as new and repairing and selling as "repaired, with full warranty".
I do agree that it is quite clear that these regulations have been created by a group of people driven primarily by fear. I would comment that satifying the fears is far more important to them than any concern for the conomic damage they are inflicting. The pity is that when they sink they will drag others along.
I think the answer is designing products that customers want with reasonable and limited regulations. To go overboard is not a solution. Also to just create jobs that do not produce anything, is not smart either.
If your products were added as a result of the inclusion of Category 8 Medical and Category 9 Monitoring I can understand the need for additional activities, resources, and the added cost of doing business to sell into Europe.If your products were already in scope and you put in place the processes and procedures to insure ongoing compliance, the impact to your company and products will be minimal.Many electronic products have required CE marking and compliance.The generation of a “Declaration of Conformity” and a “technical document” should not be new activities to any company producing a product that requires compliance to the Low Voltage Directive.
Bottom line, if your company took the time and effort to do it right the first time versus taking every short cut possible you should be well positioned to respond to the changes brought about by the recast with minimal effort required.
As a side note, a greater concern for small and mid sized manufactures will continue to be the need to respond to the ever increasing and evolving environmental compliance specifications being issued by their major customers.These specifications impose requirements, which in many cases go far beyond those of the RoHS Recast.Environmental compliance specifications issued by major product manufacturers and their impacts will be far greater than those resulting from the RoHS Recast.
Thanks for your concise comments, Ken. It looks like the RoHS recast expands the universe of those subject to RoHS rather than deepening the requirements of those already in compliance.
You final paragraph is intriguing. By "compliance specifications being issued by their major customers," do you man customers such as Wal-Mart? I'm aware they are demanding environmentally friendly packaging from their suppliers.
I think Ken's point here is telling: "If your products were already in scope and you put in place the processes and procedures to insure ongoing compliance, the impact to your company and products will be minimal."
At this stage of the game, the ideas and goals of compliance directives like RoHS aren't necessarily new or any kind of big surprise. Environmental issues are at the fore of all kinds of global political discussions and as Ken also noted, they are rapidly becoming a "requirement of interest" among key customers like the Walmarts and Dells of the world. With all of that going on, isn't the better strategy to see the writing on the wall and make the hard and potentially costly changes that will help companies adapt and move forward? Why fight it?
One one side I agree with you that we need to look into the future and try to initiate complience with a long term vision.
However if we do not start fighting this madness is scare tactics by people with limitted industrial experience, this will never stop. At some point it has to stop. Insted of spending money on development and new products we spend hard earned money on worthless regulations. It is the big guys that should start demanding some type of limit on these regulations. If a firm with 20 engineers make some noise, nobody will hear, but is a company like IBM, DELL, TI, etc.. voice their opinion, I think it will be much more significant.
In the economy of today we need to be very carefull. For example about 7 years ago we were running lots of small PCB with about 1.2% structural falure during vibration. After going to ROHS, same board has about 4% rework due to failures.
Not counting the extra cost for the ROHS complience.
Wal-Mart is an example of a major retailer imposing corporate requirements, which will impact the supply chain.My comments were primarily directed towards the activities of the major electronic product OEMs such as Apple, Dell, and HP who are struggling to comply with today’s requirements while anticipating future requirements that can have an adverse effect on the products and materials they design, manufacture and purchase.This has resulted in the development of“Super Specifications” that go beyond today’s legislated requirements.Keeping up with these“Super Specifications” will be a greater struggle than achieving and maintaining RoHS Compliance.
Sometimes these “Super Specifications” require data that is not currently available within the supply chain and as a DCA partner is often quoted as saying “when asked for data sometimes the best answer is I don’t know but we will develop a plan to get the data”.Bridging the gap between what is specified and the ability to deliver what is specified has and will continue to be an ongoing struggle.
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