ROHS Recast: Electronics Industry Braces for Further Regulation

The EU (European Union) is moving through the process of recasting its RoHS (restriction of hazardous substances) environmental directive. By the end of this year or early 2011, a ROHS recast will likely carve away exclusions and possibly add new substances to the current list of six banned substances. Many industry observers are even more concerned about RoHS becoming part of Europe's CE (conformité Européenne or "European conformity" in French) mark, which would require the electronics supply chain to produce greater detail about the contents of their products.

The final vote of the full European Parliament has been put back to October. The postponement comes because the EU's Environment Committee is meeting with the Council of Ministers to get on the same page in expanding the scope of RoHS. The goal is a smooth vote from the full parliament in October. Though RoHS is a European-centric directive, most of the electronics industry adopts its restrictions to avoid producing different products for different regions.

Expanded scope, fewer exclusions
So far the Environmental Committee has agreed that RoHS should be expanded in scope to include all electrical and electronic equipment, with a few exceptions such as renewable-energy generation and certain large-scale installations and military equipment. Currently RoHS only bans substances in eight product categories, with two more slated to be added in 2014. Implementation of the October parliament vote will likely begin in 2013 or 2014.

New banned substances
The Environment Committee took a pass on adding PVC (polyvinyl chloride) and BFRs (brominated flame retardants) to the original six banned substances. Instead, they asked for further study. The electronics industry, however, is expecting these substances will eventually be added. Given that assumption, an industry coalition voluntarily stopped using PVC and BFRs and it has asked the industry to follow suit in finding alternatives. The group includes Acer, Dell, HP, and Sony Ericsson, as well as the environmental groups ChemSec, Clean-Production Action, and the European Environmental Bureau.

The group has asked the industry to eliminate the use of these substances in consumer electronics from 2015 onward. Many electronics companies have voluntarily moved to eliminate PVC and BFRs from their products. Some industry watchers are skeptical about how thoroughly these companies are restricting BFRs and PVC.

CE mark requirements
One of the impending restrictions that strikes that greatest terror into the heart of the electronics supply chain is the almost inevitable prospect of ROHS becoming a "CE mark" directive. That would require a significant escalation in reporting of content in electronic products. Presently, companies simply state their products are compliant and it's up to European monitoring agencies to test the products and prove a company's claim is false.

Going forward
In response to growing regulations, IPC has launched a campaign asking regulating bodies such as the European Parliament to make sure their regulations are based on actual science. Many in the electronics industry believe the regulations are politically based rather than based on improving the environment.

Another ongoing problem in the electronics supply chain is the lack of widespread standards for exchanging data to support compliance. Industry bodies such as IPC, NEDA (National Electronic Distributors Association), and AFDEC (Association of Franchised Distributors of Electronic Components) have worked to define standards and simplify data collection since RoHS took force, but outside of major suppliers, adoption is still low. This problem will compound if RoHS becomes a CE mark regulation.

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