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RoHS: To comply or not to comply

Making a habit of complying with the directive is good practice, but not always required or necessary

BY RUSS MUNYAN
It was on July 1, 2006, that the world of electronics manufacturing was probably changed forever, and many would say for the better, with the implementation of the Restriction of Hazardous Substances Directive (RoHS). Of course, the RoHS reach has been huge, broadly impacting the electronic products industry. But as the European Union (EU) marks two years of the directive this summer, some confusion remains as to when the RoHS requirements apply and when they do not.

A few more details

RoHS restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment: lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE). PBB and PBDE are used as a flame retardant in commercially available plastics and are targeted because they are suspected to be carcinogenic. RoHS does not quite ban the six restricted substances, but it is close. For cadmium and hexavalent chromium, products must contain less than 0.01% of the substance by weight at raw homogeneous materials level. For lead, PBB, and PBDE, there must be no more than 0.1% of the material when calculated by weight at raw homogeneous materials. Any RoHS-compliant component must have 100 ppm or less of mercury, and the mercury must not have been intentionally added to the component. RoHS was developed as a follow-up and companion directive to the EU's Waste Electrical and Electronic Equipment (WEEE) directive, which sets collection, recycling, and recovery targets for electrical goods to help solve the problem of toxic e-waste. RoHS reduces the amount of hazardous materials entering electronic products while WEEE deals with reducing the amount of electronics entering landfills. RoHS is the beginning, and WEEE is the end. Finally, common pronunciations of the acronym include ROSS, ROSH, ROZE, and ROE-HAAS, with no singular pronunciation the universal standard.

When to choose RoHS

Let us consider when electronic products manufacturers, assemblers, importers/exporters, distributors and retailers need to specify RoHS-compliant components and goods. If a product's final destination is an EU country, then it needs to be RoHS compliant. The directive also extends to the European Economic Area (EEA) which includes Iceland, Liechtenstein, and Norway. Not only does a product need to be RoHS-compliant if its final destination is in the EU/EEA; it also needs to be compliant if it will only be assembled in the EU/EEA, even if its final destination is in a non-RoHS country. That is because waste is commonly inherent in the assembly process, and the purpose of RoHS is to prevent additional quantities of the restricted materials from landing in European landfills.

RoHS in the states

In addition, products heading for some U.S. states will need to comply with certain RoHS-like requirements, but the actual requirement depends on the destination. Multiple states are considering and/or implementing RoHS-like requirements, resulting in a patchwork of state green laws. For example, "California RoHS," which took effect Jan. 1, 2007, prohibits the sale of eight types of electronic devices if they contain more than the specified concentrations of lead, mercury, cadmium, and hexavalent chromium allowed under the EU's directive. In contrast to the EU, California does not restrict PBB and PBDE. State rules restricting mercury have been enacted in Connecticut, Florida, Illinois, Maine, Maryland, New York, Rhode Island, Vermont, and Washington.

Green is always good

So while the statutory reasons to produce RoHS-compliant products may be both complicated and compelling, the directive's environmental benefits may be all that a company needs to tip the scales in favor of going "green." That is because it is good for any landfill, regardless of its location or governing body, to receive fewer toxins, and so RoHS is always a good idea. Of course, market and cost realities may affect an electronic product manufacturer's ability to choose RoHS compliance. Some manufacturers may be forced to conclude that they do not have the luxury of RoHS compliance in certain markets. After all, an RoHS-compliant product will do the environment no good if it just sits on a store shelf or in a distributor's warehouse because it has been priced out of the marketplace by non-RoHS-compliant competitor goods that are moving off the shelves, eventually heading for landfills. But two considerations may make environmentally friendly decisions easier. First, "green" is a well-proven marketing tool, and consumers' eyes are "greener" than ever. If RoHS-compliance ends up with a product costing a bit more, it is likely that at least some sales lost to price-point can be made up for through labeling that promotes that product's environmental-friendliness. For example, well prior to the introduction of RoHS in July 2006, Toshiba released its first RoHS-compliant laptop, gaining valuable visibility among environmentally conscious consumers and groups. Second, savvy purchasing department managers may discover there is little significant difference in cost between RoHS-compliant and noncompliant materials. "In most cases, we've seen only a minimal cost increase in RoHS-compliant materials," reports Joe Caligiuri of Interpower, a U.S. manufacturer of electric cords and components for electronic products. Interpower currently sells both RoHS- and non-RoHS-compliant products, but does not intend to retain the business model in the long term. "There are still non-RoHS raw materials available," explains Caligiuri, "and, yeah, those can sell at reduced prices. But as the industry becomes more and more RoHS-oriented, the RoHS-compliant products are getting more and more competitive."

When not to choose RoHS

Despite the increasing orientation toward RoHS, there remains some demand for non-RoHS compliant products. "Mission-critical devices are exempt from RoHS," explains Bijan Dastmalchi, a principal with Symphony Consulting, a manufacturing outsourcing, procurement and supply chain consulting firm. "That includes the military, aerospace and medical fields." That is because of a phenomenon called "tin whiskering," in which electrically conductive, hair-like crystalline tin structures may grow from mostly-pure tin-finished surfaces, such as RoHS-compliant tin solder joints. Tin whiskers can grow to be several millimeters, and even up to 10 mm, and can cause short circuits and electronic system failures. However, lead in the solder joints prevents tin whiskering, thus increasing system reliability. In addition, mission-critical devices, products destined for the U.S. market and are neither manufactured nor assembled in EU/EEA countries, do not have to be RoHS compliant; in those cases, makers have the luxury of choosing whatever components they wish for whatever reasons, such as economic or environmental stewardship. The following other products are currently exempted from RoHS compliance:

1. Large stationary industrial tools

2. Control and monitoring equipment

3. Some light bulbs and some batteries

4. Spare parts in the market before July 1, 2006.

"However, I strongly encourage businesses to choose RoHS compliance," says Ray Franklin of Big Leaf, LLC and www.rohswell.com, which helps businesses comply with RoHS, WEEE, China RoHS, and other green initiatives. "That eliminates the need to stock two inventories and eliminates a chance that their non-RoHS line will end up in an EU country. And in general, simple electronic parts that are RoHS-compliant are not that more expensive."

Enforcement

Since the EU is not a sovereign nation, RoHS enforcement is left up to the member nations to codify and enforce it according to their own legislative and executive means. But RoHS has no formal preregistration or labeling requirements, and compliance throughout the EU is based on a "Presumption of Conformity," meaning that a key enforcement principle is self-declaration from producers. If a member nation has a concern about a product's compliance, "producers must be able to demonstrate compliance by submitting technical documentation or other information to the enforcement authority" and "the employment of testing . . . to verify compliance with the requirements of the RoHS Directive will usually be seen as a last resort." (Source: "RoHS Enforcement Guidance Document" developed by the EU RoHS Enforcement Authorities Informal Network.) While all of that may clarify RoHS a bit, manufacturers should not settle in to complacency. This summer, the EU will begin the process of revising the directive by July 2009, which was required in the original directive. Therefore, additional requirements may be added and some exemptions may be dropped in the next version of RoHS. "So be careful about building a business around a single exemption from the first round of RoHS, because that could change," warns Franklin. Finally, if a business is considering manufacturing non-RoHS compliant materials, it will probably do well to engage the services of a qualified consultant on the matter in order to ensure both immediate compliance and solid long-term decisions.

US and Asian governments are about to impose their own versions of the EU's ROHS directive. Rather than targeting each region's regulations, manufacturers may standardize on the most stringent "green" directive. This move will affect even products that are exempt from regulation, as component manufacturers move away from noncompliant parts.
For the past three years, the electronics industry has been eyeing this month as the time that the European Union's ROHS (reduction-ofhazardous- substances) directive was supposed to take effect for some electronic products. Barring any last-minute legal maneuvers or postponements, electronic products bound for the multibillion- dollar European consumer market will need to satisfy the directive's limitations on six hazardous materials: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated biphenyl ethers (Reference 1). The directive mandates that electronic products that do not comply with the directive's restrictions, calling for the elimination of these six substances, will face removal from the market and their manufacturers will have to pay fines.