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.
The cost won't be very high and the impact is very likely to be limiited. These rules aren't supposed to hurt enterprises and regulators working with business bodies to ensure the negative impacts are limited or spread out over some time.
@Ken: What do you think will be the economic impact of RoHS 2? Is it likely to hurt the manufacturing companies? Considering the time when many countries are looking to bring manufacturing back to their own countries to give a boost to their economies, is it a good time to have this law enacted and revised?
" Also the mechanical parts manufacturers, screws, bolts or anything needed to finish your end product must be made to undergo ROHS compliance."
@SP: That's what I was wondering too. Considering the damage to the environment, the mechanical components are equally dangerous and in any electronic gadget there's a combination of electronic and mechanical parts. I wonder why they have not yet come under scrutiny and why their manufacturing processes have not been examined.
At some point we need to stop extending RoHS further. This due to fact that it is expensive. Why not they employ RoHS for military hardware? Why are they so special and should not they be equally responsible?
_HM, Your search for empirical support for the positive effects of compliance with RoHS and other environmental do-good laws, rules and regulations most likely will end in disappointment. These are the rules you follow just because Big Daddy says "Do it or else . . . "
We all agree RoHS is very good. However, is there a survey and analysis for its effectivness by end results? How much it has helped for human helath? How much it has helped environmentally? What other objectives are achieved by this?
Ken, The industry has faced similar deadlines in the past and seemed generally to have fared rather well. We didn't have a raft of prosecution of non-compliant companies. Does this mean we have this next one nailed down too?
I was Project Managing the ROHS compliance for Motorola way back in 2006. Great to see its getting more structured. Unless its made mandatory for all electronic manufacturers this battle is still to won. Also the mechanical parts manufacturers, screws, bolts or anything needed to finish your end product must be made to undergo ROHS compliance.
EBN Dialogue enables and encourages you to participate in live chats with notable leaders and luminaries. Not only editors and journalists, but the entire EBN community is able to comment and ask questions. Listed below are upcoming and archived chats.
Thailand Stages a Comeback Join EBN contributor Jennifer Baljko on Thursday August 23, 2012, at 11:00 a.m. EST for a live chat on how electronic manufacturers in Thailand have shored up their supply chain to reduce the impact of future natural disasters.
Microsoft Surface: Potential Winners & Losers What are the implications for the electronics industry supply chain of Microsoft Corp.'s decision to launch its own tablet PC? Join industry veteran and EE Times' systems and OEM expert Rick Merritt on Tuesday, July 3, at 12:00 pm EDT for a Live Chat on this subject.
Join EBN contributor Jennifer Baljko on Thursday August 23, 2012, at 11:00 a.m. EST for a live chat on how electronic manufacturers in Thailand have shored up their supply chain to reduce the impact of future natural disasters.
Peter Drucker famously said "Trying to predict the future is like trying to drive down a country road at night with no lights while looking out the back window." Yet in the razor's-edge world of electronics—with a lean supply chain and just-in-time demands—the need to know the future is vital.
While no one really can accurately predict the future, we can take guidance from another Drucker saying which is the best way to predict the future is to create it.
You've heard the saying "the No. 1 supply chain risk is your people." That hasn't always been the case. But today's complex global supply chain requires a new type of multitalented employee. It's one who understands, finance, marketing, economics, is savvy with technology, graceful with relationships and can think analytically.
Where are these people? Are universities properly preparing the next generation supply chain professionals? How do train your existing workforce for these new, demanding positions?
Brian Fuller, editor-in-chief of EBN, will lead a 60-minute Avnet Velocity panel discussion that will ask and answer these and other questions swirling around today's supply-chain talent challenges.