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Ready or Not, RoHS 2 Takes Effect January 2

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

  1. 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.
  2. 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.
  3. All finished goods will require a CE mark and a reference to RoHS 2 in the product's declaration of compliance (DoC).
  4. 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.
  5. 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.
  6. RoHS liability is increasing. Violation of CE mark and technical file requirements can result in product being withdrawn from sale and fines.
  7. 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.

29 comments on “Ready or Not, RoHS 2 Takes Effect January 2

  1. SP
    December 27, 2012

    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.

  2. bolaji ojo
    December 28, 2012

    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?

  3. _hm
    December 28, 2012

    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?

     

     

  4. bolaji ojo
    December 28, 2012

    _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 . . . “

  5. _hm
    December 29, 2012

    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?

     

  6. hash.era
    December 30, 2012

    Cost is a major factor true _hm but I feel if it can do good do not worry about the cost. Catch up on your ROI

  7. Taimoor Zubar
    December 30, 2012

    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.

  8. Taimoor Zubar
    December 30, 2012

    @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?

  9. bolaji ojo
    December 30, 2012

    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.

  10. Daniel
    December 31, 2012

    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.

  11. Daniel
    December 31, 2012

    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.

  12. Anna Young
    December 31, 2012

     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?

  13. _hm
    December 31, 2012

    @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.

     

  14. kmanchen
    December 31, 2012

    Anna, Jacob, Bolaji, TalimoorZ, etc. –

    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.

  15. Anna Young
    December 31, 2012

    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?

  16. Anna Young
    December 31, 2012

     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.

  17. FLYINGSCOT
    January 1, 2013

    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.

  18. Daniel
    January 2, 2013

    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.

  19. Daniel
    January 2, 2013

    “While the product categories (and substances) covered remain the same until 2014, supplier obligations will increase on January 2:”

    Kmanchen, thanks for the details. So you mean that companies can continue with this existing set up till 2014.

  20. kmanchen
    January 2, 2013

    Anna –

    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.

  21. kmanchen
    January 2, 2013

    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.

  22. Barbara Jorgensen
    January 2, 2013

    Hi Ken,

    Have you seen any data on RoHS's success to date? For example, how mch less lead there is, less waste, etc., than in comparable years?

  23. kmanchen
    January 3, 2013

     

    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.

  24. Barbara Jorgensen
    January 3, 2013

    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.

  25. garyk
    January 3, 2013

    This is all good INFORMATION.

    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?

     

  26. kmanchen
    January 3, 2013

    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.  

  27. bolaji ojo
    January 3, 2013

    That depends on which part of the globe and the efficiency of the system, including power consumption. What's being junked in the West is new elsewhere!

  28. Daniel
    January 4, 2013

    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.

  29. Taimoor Zubar
    January 9, 2013

    @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.

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