Just when the supply chain thought it had the EU's Restriction on Hazardous Substances (RoHS) figured out, along came the RoHS recast. The update clarified a number of vagaries in the original version but also expanded the scope of the mandate to include a wider range of electronic equipment. (See: Revised RoHS Directive Adopted in EU.)
Ever-changing guidelines for environmental compliance will be standard operating procedure for the electronics industry for the foreseeable future. Not only are developing markets trying to forestall or clean up hazardous waste, but new dangers of existing chemicals are being discovered every day. This is one of the concepts behind California's Safer Consumer Products guideline, which requires manufacturers to flag harmful materials, identify a safe substitute, and then implement the replacement. (See: India Enacts RoHS & WEEE Legislation: Who's Next?)
The idea is to avoid a substitute that is as hazardous as the original, says Michael Kirschner, president of consultancy Design Chain Associates LLC (DCA) . "This will require more work on the manufacturer's part than ban/restriction regulations, but should result in fewer 'regrettable substitutions' than we've seen in the past." (See: CA Opens Consumer Product Draft for Comment and Tracking Calif. Consumer Products Proposal.)
For RoHS, at least, the electronics industry has identified its biggest problem -- lead -- and has developed lead-free alternatives. The jury is still out on the effectiveness of the substitutions, but electronics companies have accepted that lead is history. The EU has been careful about adding new substances to the RoHS list but is expanding the scope of RoHS to include a wider range of electronics products.
This is very likely to become a challenge for medical equipment manufacturers, says Ken Stanvick, a principal at DCS. Medical equipment has so far been exempt from RoHS, and the industry itself works within a tight circle of suppliers, manufacturers, and OEMs. This group has not had a wide experience with outsourcing, which helped identify a number of challenges in RoHS early on for PCs and industrial products.
In addition to updates to existing guidelines, the industry faces the challenge of inconsistencies across geographies. The US is a classic example where environmental guidelines vary from state to state. Even though "RoHS" is the term used to describe environmental efforts in China, India, Brazil. and Mexico, the specifics in each region differ considerably. (See: Continental Divides.)
There is no shortage of information, recommendations, consultancies, and even tools to help guide the electronics industry. In upcoming blogs, EBN and Velocity will take a closer look at the resources available and recommendations for manufacturers.