RoHS Part II Finally Arrives

The new RoHS Directive became law on July 21, 2011. Key points:

• No new restricted substances
• Nine (9) exclusion categories - military, space, transportation (trains, planes, autos), fixed installation, large industrial tools, off-road machinery (i.e., bulldozers), implantable devices, solar panels, and R&D equipment
• Compliance timeline - medical and monitoring/control have 3 years, in-vitro medical has 5 years, and industrial monitoring/control has 6
• Exemptions will end in 5-7 years, including telecom and high lead
• CE mark required
• Larger companies must go beyond certificates of compliance
• Your EU importer is now also liable
• Oh, and don't forget India

See how this differs from our reporting two years ago. What will this mean? More paperwork and more testing. Need help? Contact Craig Hillman, chillman@dfrsolutions.com.

RoHS II Has Arrived

Approved two weeks ago by the European Parliament, this major update to environmental legislation does not provide too many surprises. Key things in the document to be aware of: no new restricted substances; there are nine (9) exclusion categories - military, space, transportation (trains, planes, autos), fixed installation, large industrial tools, off-road machinery (i.e., bulldozers), implantable devices, solar panels, and R&D equipment; medical and monitoring and control have three years to be compliant, in-vitro medical has five years to be compliant, and industrial monitoring and control has six years to be compliant; all exemptions will die out in five to seven years, including telecom / enterprise and high lead (Pb); and you will need a CE mark. For more information on RoHS, including compliance and transition, please contact Craig Hillman, chillman@dfrsolutions.com.

Environmental Legislation: The Latest News

EU RoHS
The latest proposed modifications to RoHS include covering ALL electronic equipment (that means military and avionics), elimination of brominated and chlorinated flame retardants (BFR / CFR), polyvinyl chloride (PVC), and nanomaterials, and requiring a CE mark to demonstrate compliance. At the same time, consumer electronic companies are actively supporting the elimination of BFRs and PVCs. Why? Maybe because Greenpeace is watching closely and aggressively weighing in on each exemption.

US RoHS
The American RoHS is expanding through IEEE Standards 1680.2 and 1680.3. These standards expand beyond the current RoHS by banning Tetrabromobisphenol-A (TBBPA) and requiring inventorying of over 100 other substances. This will affect you because these standards drive the Electronic Product Environmental Assessment Tool (EPEAT) and all new government procurement must be compliant to EPEAT.

China RoHS
The Chinese Ministry of Industry and Information Technology (MIIT) has released a new general requirements document for China RoHS. The biggest changes? The scope has broadened from Electronic
Information Products listed in a catalog to any Electronic and Electrical Products powered below 1500 VDC or 1000 VAC. In addition to the restricted six (Hg, Pb, Cd, Hex Cr, PBB, PBDE), there is the possibility of "State regulations of other harmful substances" and inspection will be performed at both entry AND exit and items will be subject to quarantine (say goodbye to the building of SnPb electronics in China).

Oh, and don't forget conflict metals and India RoHS.
Have a headache? Don't go for the aspirin. DfR helps hundreds of companies each year with the challenge of meeting environmental requirements, including Design for Environment (DfE). For more information, please contact Randy Schueller, rschueller@dfrsolutions.com.

...and where will RoHS be Tomorrow?

As made clear in the IPC and our ruminations, the consumer industry is supportive of RoHS expansion. And the EU is willing to oblige. The rapporteur is now recommending that all electrical equipment be covered under RoHS and all brominated and chlorinated flame retardants be banned (see the full proposal and arguments.) Amendments are possible until end of February and an initial vote is not expected until late April, so stay tuned. For more information on RoHS, please contact Craig Hillman, chillman@dfrsolutions.com.

Where is RoHS Today...

The last half of 2009 was rife with predictions on the status of RoHS2, including the mysterious 11th Category, exemption recommendations, and DfR's own insight. However, all speculation ceased when the proposed RoHS2 was released. While a more complete list of changes is provided here, the biggest ones are:
• Medical and Monitoring / Control Equipment will be covered
• The list of banned substances has NOT changed
• Compliance to RoHS will now require the CE mark
• All lead (Pb) solder/plating exemptions remained, but will be phased out in four years