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.
What's different
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).
Summary
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.
Ann, any change in existing system can cause additional costs to the companies and it’s a onetime investment. But at the same time, it can address many of the issues facing by employees while handling such chemicals and hence a corresponding impacts to the environment too.
It is encouraging that many other countries are following Europe's lead. I hope they are enforcing it too and not simply paying it lip service as that puts Europe at a cost disadvantage.
Bolaji you may be right, the cost impact of RoHS 2 may be minimal, as mentioned by you. But we won't know the full impact until later on the year. I think.
hm good point and I understand your view. However, these rules are here to stay. Failure to comply will attract fines or some forms of punishments. What changes would you like to see?
So many good comments! Yes, the RoHS directive has indeed resulted in safer electronics. Yes, RoHS 2 compliance will require more time and money. While the product categories (and substances) covered remain the same until 2014, supplier obligations will increase on January 2:
*manufacturers will need to provide updated (RoHS 2) declarations of compliance,
*manufacturers will need to provide technical documentation of RoHS 2 compliance on request,
*finished goods manufacturers will have to assure CE mark compliance, and
*components, spare parts, cables and development kits must be RoHS 2 compliant.
The CE mark requirement gives the EU more leverage to go after non-compliant suppliers. It remains to be seen how aggressive the EU will be in enforcing these new requirements. It also remains to be seen how ready manufacturers are to meet these new obligations.
@Anna: Incremental cost of all these approval agencies becomes significant part of product cost. And relatively speaking, they are not appropriate. Electronics industry obeys more stringent agency approvals as compare to other industry e.g. auto.
From business perspective there is no doubt that companies has to shell out more to meet such laws.
I agree Jacob, RoHS 2 will affect wider range of other business sectors, thereby adding to manufacturing costs as some suggests. I think the environmental impact and benefits of this directive outweigh any additional cost to an organisation. Don't you think?
Bolaji, I think change in the existing thing or product line may end up in shell out more from the production/company side. But I agrees that for a long run, it may be negligible.
Ken, I think the RoHS 2 is expanding its wings to all electrical and electronic equipments. Most of the devices are covering under its umbrella and ofcource its good when concerned with human health. From business perspective there is no doubt that companies has to shell out more to meet such laws.
The US Senate Armed Services Committee uncovered approximately 1,800 cases of suspected counterfeiting over a two-year period. One Air Force supplier alone supplied 84,000 counterfeit devices.
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.
Archived Dialogues
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.
Euro-Crisis: What It Means for High-Tech Firms Join EBN Editor in Chief Bolaji Ojo and Contributing Editor Jennifer Baljko on Thursday, July 12, at 10:00 a.m. EDT for a Live Chat on high-tech and Europe's economic difficulties.
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.
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.
To save this item to your list of favorite EBN content so you can find it later in your Profile page, click the "Save It" button next to the item.
If you found this interesting or useful, please use the links to the services below to share it with other readers. You will need a free account with each service to share an item via that service.
Tweet This