Europe’s RoHS 10-Year Anniversary Gives U.S. a Pointer

Twenty years ago, I remember hearing talk about lead-free soldering at a turnkey manufacturing facility in Massachusetts. At that time, the factory managers were already contemplating the possibility that future regulation would ban the use of lead in electronic circuits and were studying possible alternatives.

Five years later, in 2002, the European Union (EU) passed Directive 2002/95/EC on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS). Also called “the Lead-Free Directive,” RoHS was implemented to ban and limit the uses of lead, mercury, cadmium, hexavalent chromium, and certain flame retardants in electrical and electronic devices.

After several amendments, the directive entered into full effect on July 1, 2006, and any product not in full compliance with the requirements was banned for import or manufacture in the EU. Distributors and retailers had an additional year to sell non-compliant products they already had in stock.

One of the most important effects of RoHS in the past decade, one rarely mentioned in the press, is the reduction of exposure of factory workers worldwide. It has probably saved hundreds, if not thousands of lives, as factories reduced and in some cases eliminated the use of those harmful substances in their manufacturing process. Lead soldering alone can cause a wide range of adverse health effects. These include fatigue, irritation, and anemia, and it has been linked to reproductive effects such as spontaneous abortion.

Although it is impossible to eliminate all traces of the banned substances in the final product, the directive is very clear about the maximum allowable levels of those substances. It's also very clear that these substances must not have been intentionally added to the component.

RoHS 2 is even tighter

 In 2011, the European Commission approved the second version of the directive, the recast Directive 2011/65/EU, referred to as “RoHS 2.” It started to come into effect in 2014 and full compliance will be required by 2019. The main changes are the reduction of the compliance factors and the inclusion of medical equipment. According to the European Commission FAQ document “the adaptation of the Directive to the technical and scientific progress concerning the use of hazardous substances in EEE particularly in medical devices and monitoring and control instruments;” and “preventing risks to human health and the environment, with a particular focus on workers involved in the management of electronic waste.”

This diagram illustrates the different phases of implementation of RoHS 2:

Source: European Commission

Source: European Commission

The initial cost for a manufacturer to comply with RoHS can be high, but could provide additional benefits on the long run. Research from a study conducted in 2008 by researcher Technology Forecasters found that the RoHS directive cost the global electronics industry more than $32 billion for initial compliance and about $3 billion annually to maintain compliance.

However, companies that have invested in RoHS compliance also noticed several benefits related to their supply chain processes. Many of those companies have increased their market share, as non-compliant competitors are no longer allowed to sell in the European Market. Their reputation has also improved, as consumers become more concerned about the risks of certain elements in electronic waste.

Contract manufacturers, or EMS, found the greatest benefits from implementing RoHS compliance: 60% improved their supply-chain processes, 50% saw a market-share gain, and 50% rationalized their product lines, according to the study.

While the United States doesn't have an equivalent legislation at federal level, several states have implemented some of the RoHS requirements. Currently Minnesota, Maine, Maryland, New Jersey, Tennessee, Vermont, Washington, and Wisconsin have RoHS-like legislation enacted. The number of states considering similar legislation could expand in the next few years creating enormous costs for companies that will have to comply with these requirements.

One example is California where they passed the Electronic Waste Recycling Act (EWRA), which has a narrower scope, in 2007. The California act only applies to computer, plasma, and LCD monitors larger than four inches (items that are also covered by the EU directive). From Section 66260.202, Restrictions on the Use of Heavy Metals in Covered Electronic Devices:

(a) On or after January 1, 2007, no person shall sell or offer for sale in California, a covered electronic device if the device is prohibited from being sold or offered for sale in the European Union on or after its date of manufacture, due to the concentration of one or more heavy metals in the device exceeding its maximum concentration value, as specified in the Commission of European Communities' Decision of August 18, 2005, amending Directive 2002/95/EC (European Union document 2005/618/EC), or as specified in a subsequent amendment to the Directive.

The fact the RoHS directive is now in effect in the EU has forced manufacturers to modify their tooling and materials, and it is no more a cost issue to comply. Some major companies such as Intel, Apple, Dell, Samsung, and HP now manufacture all their products in full compliance with the EU directive, irrespective of their destinations.

Let us know in the comments section below how the U.S. should be managing the question of hazardous substances. Should we take a page from the EU's book?

0 comments on “Europe’s RoHS 10-Year Anniversary Gives U.S. a Pointer

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.