Furthermore, the EU has been refining REACH, which focuses on regulating chemicals considered to be an endangerment to human health or the environment. The Helsinki-based European Chemicals Agency (ECHA) may require specific authorization for the use of these Substances of Very High Concern (SVHC).
ECHA recently announced the first batch of SVHC, the so-called candidate SVHC list, for authorization. The list includes 15 substances and will be updated regularly as more substances are identified as SVHC. REACH could potentially include as many as 1500 SVHCs.
Designed to replace more than 40 existing directives, REACH consists of 1000 pages of legal text and technical language. It’s so complicated that the EC recently said it’s trying to address problems related to “perceived inconsistency” with other EC environmental legislation, such as those that overlap with REACH.
Gary Nevison, the legislation and environmental affairs manager of Newark and Farnell, two business units of the U.K.- based distributor Premier Farnell plc, calls REACH “unbelievably complex” with “a different set of challenges” than RoHS. Another company’s executive summary of REACH simply calls it “overarching” in its depth and complexity.
PROHIBITIVE AND OBSOLETE
Further complicating the lives of design engineers, some substances may become obsolete, mainly because of prohibitive costs reaching 0.5% to 7% in potential price increases, according to research estimates. Some products have already been phased out or replaced with “different” alternatives. The EC estimates that at least 2% of electronic products currently shipped into the EU will be obsolete.
It’s not clear how many substances will be banned under REACH. But at this point if you’re a manufacturer or distributor and you import substances (chemicals), or mixtures of solutions of substances, or an “article” that by the EU’s definition forms a product (electronic components, a finished piece of equipment, and even packaging would apply), REACH will impact how you do business in the EU.
With REACH already becoming a moving target in terms of updates and other changes, Nevison says the demand for information on REACH has been huge. “I’m averaging about 20 calls a day from the U.S.,” he says.
Unlike RoHS, which allows each EU member country to write its own regulations under a set of guidelines, REACH impacts all EU states equally and, by extension, the entire electronics and chemical industries globally as it is written.
If there’s any good news here for designers, especially with smaller and medium-sized companies, it is that some of the new RoHS rules might not be implemented until 2012. This gives them plenty of time to think about China RoHS and Korea RoHS.
China’s Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation, published on March 1, 2006, declared March 1, 2007 as an enforcement date. Korea’s Ministry of the Environment set January 1, 2008 as the compliance date for Korea’s Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles.
While the scope of EU RoHS currently focuses on eight broad categories of finished products and six substances, China RoHS covers all electronic information products. There’s also an extensive list of products not covered by the EU directive, such as radar, medical equipment, and measurement instruments.
China’s Ministry of Information Industry expects to phase in the rules and requirements of its version of RoHS. Labeling rules came into force in 2007, but a long-anticipated catalog of restricted substances is long overdue.
The bottom line is that responsibility for implementation of the China RoHS rules falls on manufacturers and importers of any products on the list. One big break for the industry is that products will only be listed in the catalog if they can be replaced by a mature technology and at a reasonable price, even if they contain hazardous substances.
While Korea RoHS is similar in some ways to the EU’s RoHS and China’s RoHS, there are differences. For example, unlike China RoHS, Korea does not require OEMs to label their product as compliant. According to Siemens, which offers product lifecycle management software to help customers work their way through the complex RoHS, REACH, and other regulations, all manufacturers have to do under Korea RoHS is register and say their product will comply with the legislation. But Siemens says in one of its reports that some of the critical details of Korea RoHS have still not been released.
Japan is well ahead of the rest of the world on many of these issues, and Japanese companies have been working hard to comply with the EU’s environmental directives (Fig. 3). India, meanwhile, is cranking up its own RoHS, though little information is available on its hazardous substance directive. Newark & Farnell’s Nevison says India is under pressure to do something similar to the EU’s RoHS and that “there’s a lot of activity in India aiming at developing its own RoHS.”
Another EU directive, Energy Using Products (EuP), may end up having the biggest impact on engineers designing a broad range of electrical and electronic products.
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