Now that the EU’s Restriction on Hazardous Substances (RoHS) has been around awhile, manufacturers have a pretty good idea what’s necessary to comply with the directive. Now RoHS 2 is on the horizon, and the role channel partners play in environmental compliance efforts will be expanded.
“What [RoHS 2] does is expand the requirement for conformity beyond the [end-product] manufacturer,” says Ken Stanvick, senior consultant for SGS, a global inspection, verification, testing and certification company. “RoHS focuses on the finished product: RoHS 2 extends that requirement to companies that do board-level work or the assembly of a system component such as hard disk drives sold directly to end-users.”
In other words: RoHS 2 directly impacts distributors. The channel increasingly is providing hardware solutions to the electronics market that involves some type of value-added. These products, typically treated as subassemblies, are now subject to the same requirements as finished goods. Suppliers of these products now need to provide “trustworthy” documentation of compliance and the CE mark.
This is only one of many changes outlined in RoHS 2. The most significant development is the original directive – which bans the use of lead, cadmium, mercury and other substance from electronics products — has been expanded to include medical electronics, which so far have been exempt. Manufacturers of these products may be facing the same kind of challenge commercial and industrial equipment makers faced in 2005, including the elimination of lead from solder and components. Other adjustments include the sourcing and control of lead-free materials and components; rewriting supplier contracts; supplier education; the redesign of legacy products; managing the end of life for products; and the Identification and updating of material content information.
The electronic components industry, of course, has largely made the transition to lead-free. But buyers will be playing a more active role in overall compliance efforts under RoHS 2. RoHS 2 specifies that suppliers provide “trustworthy” documentation of compliance. Not all components and subassemblies are lead-free, Stanvick explains. “You can’t always tell [compliance] by looking at a component,” he says. “A component may be a form-fit-function equivalent [to an original device] but not be lead-free.” Companies that are already RoHS compliant face more stringent requirements regarding the documentation, marking and record-keeping of their products under RoHS 2.
Globally, the effort to make electronics products more environmentally friendly is ongoing and increasingly complicated. Two leading environmental consultancies, SGS and Environ, are hosting a free EU RoHS2 compliance seminar on October 14 in Fort Worth, Texas. UK RoHS 2 Regulator Chris Smith will be making a presentation on “RoHS 2 Compliance and Enforcement.” Smith is technical manager for the UK’s National Measurement Office (NMO), which is responsible for enforcement of the RoHS 2 directive. In addition to enforcement, Smith and his organization provide education on RoHS obligations for manufacturers, importers, distributors and the general public.
Those efforts include clarifying the use of the CE mark on an electronics product. When RoHS first hit the electronics market, many manufacturers began using a green leaf or a lead-free symbol on their products to demonstrate RoHS compliance. These marks are not recognized by enforcement bodies as RoHS-assurance. The CE label is accepted as a visible identification of RoHS compliance, but companies must undergo a rigorous audit process before they can use the label.
RoHS compliance continues to be a moving target, Stanvick says. “Manufacturers may want to keep in mind what applies today may not apply tomorrow; and what works in one region may not work in another,” he concludes.