By Gary Nevison, Legislation & Environmental Affairs, Premier Farnell
Design engineers have had a lot to consider, with proposals that would lead to many more products falling within scope, potentially more substance restrictions and even a new geography with the first draft, some two years late, of the China RoHS “Catalog”.
2009 saw proposals to amend the scope of the RoHS Directive. Further recommendations from the European Commission (EC) in September were quickly followed by the first draft of a recast in November.
The political process will move forward and there will probably be a further recast towards the end of 2010 or early next year. providing the European Commission, Council of Ministers and European Parliament can agree on several key issues. The final draft will then be passed to governments for transposition.
Among the possible changes to impact design engineers would be a new Category 11, where the scope would simply be “other electrical and electronic equipment not covered in any of the Categories 1 to 10”.
It is also possible, if agreement is reached, that the current exclusion of large-scale stationary industrial tools would be deleted; therefore, all EEE, including manufacturing production line equipment, would fall within scope.
“Equipment that is part of another type of equipment that does not fall in scope” is proposed to change to “part of stationary installations or transport equipment that is not EEE”. This would
bring into scope all electrical products used in buildings and transport, all “fixed installations” and electrical parts in aircraft, trains, ships and commercial vehicles. Equipment covered by the new Category 11 would enter into force in 2014.
The list of restricted substances could increase under the proposals and include PVC, chlorinated plasticizers, organohalogens, flame retardants and three phthalates.
The second batch of 14 REACH substances of very high concern was announced in December 2009 by the European Chemicals Agency (ECHA). This takes the total to 29 with a further batch expected later in 2010. ECHA sources think that as many as 600 to 700 SVHCs could be added to the Candidate List over time.
REACH, unlike RoHS, is not simply a case of providing a certificate of compliance but drives the flow of safety information down through the entire supply chain.
This includes automatically providing a Safety Data Sheet (SDS) both at the point of first order, as well as when the SDS is revised. Gathering the SVHC data has proved a challenge with a generally slow response from many manufacturers at the top of the supply chain.
We witnessed this with the RoHS Directive during 2005 and 2006, but the response to requests for REACH data has been worse. Seven substances have been approved for authorization
of use and this costly exercise must be completed within a specified period of time, otherwise the substance cannot be used. Thereafter, any downstream user can only procure the product from the source of the authorization request, assuming it has been granted.
In October 2009 the Chinese Government published the first draft catalog of Electronic Information Products that will be subject to China RoHS restrictions. While the catalog will be updated periodically, the initial scope is limited to telephones and all types of printers that attach to a computer. Substance restrictions and maximum concentration limits are generally the same as with RoHS in the European Union. Ten of the EU exemptions are used for telephones and 12 for printers.
Companies exporting products into China for sale within the country will be required to test their products and be certified compliant by an approved Chinese test house. In the future this may create a bottleneck, as the obligations will enter into force just ten months after the legislation is adopted by the Chinese Government. When the catalog is revised, it is likely that the consumer products theme will continue.
So, what will the next 12 months bring? Definitely more substance restrictions, more products falling within scope of the regulations, more revised exemptions, more data requests up and down the supply chain and probably more frustration.
