Environmental laws continue to play havoc with industry companies trying to keep up with changes in the rules and regulations.
The dynamics of the electronics industry, from its quick-turnover innovation cycles to the rapid expansion of maturing market sectors, are forcing environmental regulators to re-evaluate, or “recast,” many of the substance restrictions they began discussing in the mid-1990s. As a result, the European Union’s Restrictions on Hazardous Substances (RoHS) and its Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations are affecting—and, in some cases, straining—virtually every level of the electronics manufacturing supply chain.
“Customers are asking for a complete environmental compliance solution which would allow their engineers to be free of the compliance headache and keep them free to work on design and manufacturing issues,” says Peter Robinson, vice president of Total Parts Plus, which specializes in environmental compliance and obsolescence management.
The EU continues to tweak RoHS to ensure that the revised version of the directive is fully aligned with REACH, which regulates all materials and substances made in, or imported into, the EU, as well as all products that enter the EU. Discussions on the RoHS substances list, which initially banned six substances—lead, mercury, cadmium, hexavalent chromium, polybromated biphenyls (PBB), and polybromated diphenyl ether (PBDE)—are currently underway about adding new substances, possibly by early 2012.
Several industry sources believe the REACH list of substance requirements could top 130 by the end of 2012. Among the changes are additions to the original list of six RoHS substances by the EU’s Environmental Committee. As a result, a coalition of industry companies that includes Hewlett-Packard, Dell, and Sony Ericsson is looking for alternative materials for the most likely candidates, such as polyvinyl chloride (PVC).
The EU’s parliament, commission, and council met in late September and a vote on updating the language of RoHS could come as early as late November. Fern Abrams, director of government relations and environmental policy for IPC – Association Connecting Electronics Industries, a global trade group that represents more than 2700 member companies, believes there are now three key issues before the EU’s legislative bodies. The first is open scope. The second is substances restrictions, and the third is substance exclusions.
“The substances seem to be the area where there is the most controversy,” notes Abrams. In fact, she says that largely because of lobbying by IPC, other trade organizations, and individual companies, it’s not likely that any substances will be added to the list, at least not any time soon.
Several companies, ranging from private consultancies to trade and standards organizations, are focusing more on environmental issues. Most of them advise smaller and medium-sized companies to assess their compliance with current regulations and their ability to meet new demands for implementing future rules changes.
Total Parts Plus has developed a Compliance Complete Service, a Web-based management tool to help OEMs produce and present their customers with completed environmental compliance reports on their products. Reports can be generated in IPC-1751, IPC-1752, JGPSSI (Japan Green Initiative), and any future format required by the OEM’s customers. Also, Design Chain Associates LLC and Technology Forecasters Inc. now jointly offer a service called the Design-for-Environment Process Integration Roadmap (DPIR) to help companies proactively address current and emerging global environmental requirements while minimizing costs.
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