The European Union's Restriction of Hazardous Substances (RoHS) law has forever changed the electronics industry. It has resulted in less hazardous substances being used and safer electronic goods.
This law has been so successful it has been mimicked by other countries. China, Japan, South Korea, Taiwan, India, and the State of California have all followed the European Union's lead and enacted their own RoHS laws.
Come January 2, 2013, the European Union will replace its original RoHS law with a new recast version known as RoHS 2. This new version will expand coverage to all electrical and electronic equipment, require special marking of finished goods and more compliance documentation, and increase penalties for non-compliance.
So what stays the same and what is different?
What's the same
Currently in-scope (covered) products are not allowed to be placed on the market if they contain a RoHS substance in an amount exceeding the established maximum allowable concentration value. Current in-scope products are product categories 1 through 7 and 10.
All electrical and electronic equipment (EEE) will be covered until July 2019 unless specifically excluded. All current RoHS exemptions will automatically expire unless renewed. A review of scope and further exclusions to category 11 will be published by July 2014.
New categories will be covered at different times over a 6.5 year period:
July 2014 -- Categories 8 (medical devices) and 9 (consumer monitoring/control instruments) will be covered.
July 2016 -- In-vitro diagnostic medical devices will be covered.
July 2017 -- Industrial monitoring/control instruments will be covered.
July 2019 -- Category 11 (all other EEE not previously covered) will be added.
All finished goods will require a CE mark and a reference to RoHS 2 in the product's declaration of compliance (DoC).
Manufacturers must submit technical documentation (of compliance status) on request, and retain such documentation for 10 years after a covered product is placed on the market.
Additional items now covered:
Components and spare parts to be inserted into (used in the manufacture, repair, or upgrade of) a covered product are considered part of that product. They must be RoHS 2 compliant but will not require a separate CE mark or DoC.
Cables must be RoHS 2 compliant. They may or not require a CE mark and DoC depending on their intended use. Cables that are considered finished goods (i.e., cables with connectors at both ends sold to end users and not OEMs) will require a CE mark and DoC. Cables that are specially designed for use in a covered product are considered part of that product and do not require a separate CE mark or DoC.
General purpose items (like semiconductor development kits) that simply plug into other equipment to make them work are considered finished goods by all EU member state enforcement authorities. They must be RoHS compliant, and will require a CE mark and DoC.
RoHS liability is increasing. Violation of CE mark and technical file requirements can result in product being withdrawn from sale and fines.
Additional RoHS hazardous substances may be added in the future. Four new priority substances will be considered in July 2014 (using the REACH methodology for substance restriction).
Nobody gets out of RoHS any longer. If an electrical or electronic product isn't currently covered, it will be. Obligations and liability for non-compliance are increasing. You can't afford to be non-compliant.
Has your business started its RoHS 2 compliance efforts? Are you comfortable with your company's efforts?
For more information on RoHS 2 and other legislation affecting the electronics industry, go here.
@Bolaji: I think the government bodies have to work closely with regulators to find out ways of fulfilling the requirements for RoHS without having any impact on the industry productivity or cost. They might look to find ways of softening the restrictions or delaying the implementation of the regulations.
Kmanchen, is just documentation is sufficient or are you going to a supervisory level to cross check how they are going to meet the RoHS 2. I think in initial level, there should be some monitory bodies to make sure they are adhere to such compliances.
Gary - Good question. I don't have any specific data but removing hazardous substances typically changes performance. An example is lead-free solder. It works but is not as effective over the same range of conditions. Same for less hazardous fire retardants. It is a tradeoff as removing hazardous substances eliminates health and waste disposal concerns, but often affects product performance.
Medical equipment will not be covered by RoHS until 2014. The effects of removing RoHS regulated substances won't be apparent until then.
I would like to see reliability data, some failure analysis. We keep our phones for 1-2 years then we replace them or the service provider replaces the broken phone. Computers get repaired or replaced after a couple years. Medical equipment could be another question, how long should Medical last?
Thanks Ken! I remember when all of this was coming up the first time and I found the amount of lead in electronics solders was minuscule. Although RoHS is the right thing to do, measuring its success via lead levels probably won't be an indicator. The lead already in the ground continues to seep, I believe. Maybe measuring other substances will be a better baseline.
Barbara - I haven't seen any figures on the sucess of RoHS or the impact of RoHS 2. The EU had an outside group conduct a ROHS 2 impact assessment. They just released their report: http://rohs.biois.com/announcements-1/finalreport. Might find something there.
Jacob - The products covered are the same but we are spending more time on compliance.
We are now providing RoHS 2 declarations of compliance to customers. We've alerted our product suppliers that we'll need technical documentation of compliance whenever requested by a customer. We are also reviewing our product line to ensure our products are compliant, especially development kits.
Happy New Year! You asked what I would like to change about the new rule. I had to think about that. Only one thing comes to mind.
The CE mark requirement for RoHS 2 impacted finished goods seems like overkill to me. There was concern over poor compliance and ineffective enforcement. Adding the CE mark requirement definitely makes it easier to enforce but will be costly for finished goods manufacturers. Other than that it seems like RoHS 2 is a natural progression. It is making electronics safer and freer (is that a word?) of hazardous substances.
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