The Emerging RoHS Maze

Manufacturing News, Source : The Manufacturer US
Published : 12 Jan 2007 21:53

by Buck Seng Ng, Associate Director, Asia/Pacific, of Manufacturing Insights, an IDC company.

This article highlights key discussions from a recent compliance with Restriction of Hazardous Substances (RoHS) Regulations event in Singapore. The event, a day-long executive seminar entitled "Solutions to Compliance with Existing and Emerging RoHS Regulations Worldwide", was jointly organized by the Standards, Productivity and Innovation Board (SPRING) Singapore and Singapore Manufacturers' Federation (SMa), and supported by International Enterprise Singapore (IE Singapore). The event was held to raise the level of awareness regarding existing and emerging RoHS Regulations worldwide among manufacturers, resellers and exporters of electrical and electronic equipment/products. Speakers from high-tech manufacturers, compliance solution providers, as well as regulatory and standards bodies, provided information and insights that served as focal points for rich discussion among attendees.

The high-tech industry is not unfamiliar with the need for resource and environmental sustainability, as well as consumer demands for environmentally friendly products. Many have addressed these needs as part of their broader environment, health and safety (EHS) or corporate social responsibility (CSR) structures and programs. What is new to the industry, however, is a shift in focus from the environmental impact of manufacturing operations to the environmental impact of products. This is evident in product-based environmental legislation focused on eliminating/minimizing the use of hazardous materials/substances in products, and providing post-consumer recycling options for end-of-life products, amongst others. A key piece of such product-based legislation is the European Union's (EU) RoHS Directive (2002/95/EC). Coming into effect on 1 July 2006, the law requires that electrical and electronic equipment sold in Europe, with certain exemptions, be free of six hazardous substances, namely: lead, cadmium, hexavalent chromium, mercury, polybrominated biphenyl (BPP), and polybrominated diphenyl ether (PBDE). The RoHS Directive, together with other equivalent regulations throughout the world, will exert tremendous pressures on high-tech manufacturers to implement relevant compliance initiatives globally and in specific markets. As far as the EU is concerned, this will require Member States to ensure that products put on the EU market will conform to RoHS as of 1 July 2007. In this regard, the EU RoHS Directive does not foresee compliance procedures or testing methods to be applied. As part of the compliance framework, the Enforcement Authorities Informal Network issued a non-binding guidance document in May 2006 which contains guidance principles on RoHS compliance including:

􀂾ƒnCommon interpretation across Member States regarding those products which are considered to fall within the scope of the RoHS Directive

􀂾ƒnPresumption that products falling within the scope conform with its requirements

􀂾ƒnSelf-declaration by producers

Several speakers provided much needed information and clarifications on different pieces of existing and emerging legislations, including EU RoHS and Waste Electrical and Electronic Equipment (WEEE) directives, U.S.A RoHS, and China RoHS. In addition to current dominant RoHS legislation in Europe, China, Korea, Japan, U.S.A, and Taiwan, it was clear that Canada and South American countries such as Mexico, Colombia, Brazil and Chile are on the verge of similar legislation.

An interesting trend emerging from the EU Member States RoHS legislation, is the differentiation between those adopting the "straight RoHS requirements" versus those who have embraced RoHS Plus ¡V where further requirements were added over the base RoHS legislation. EU Member States adopting the RoHS Plus legislation include Greece, Ireland, Italy, Sweden, The Netherlands, Poland, and the United Kingdom (UK). In addition to the base RoHS requirements, RoHS Plus initiatives involve compliance to other environmental directives such as EU Directives on Batteries and Accumulators, EU Directives on Packaging & Packaging Waste, EU End of Life Vehicle (ELV) Directive, EU Directive on Eco-Design Requirements for Energy-Using Products (EUP), and The Registration, Evaluation and Authorization of Chemicals (REACH) Regulation (final version of legislation expected by end of year 2006 and enforcement beginning in April 2007).

The President of The Electronic Components Certification Board (ECCB), U.S.A. told the audience that early feedback regarding the EU results on the status of compliance after July 2006 was not particularly favorable, with many suppliers apparently failing to meet the RoHS requirements. In addition, a number of EU Member States continue to work closely with producers rather than issuing fines. For now, the EU RoHS authorities are focused on generating compliance and not persecution, although this may change in 2007. In the UK, the National Weights and Measures Laboratory has tested a range of electronic devices pulled from retail shelves and found few compliant products.

A representative from the Ministry of Information Industry, People's Republic of China (PRC) provided details and insights on China's RoHS requirements. His session invited a great number of questions from the manufacturing audience, many of whom wanted to know the differences between the China RoHS and the EU RoHS, and the implications for exporting products to the Chinese market, as well as their manufacturing operations in China. China RoHS, also known as Ministry of Information Industry (MII) Order #39 was promulgated on February 2006 and expected to take effect on 1 March 2007. In addition to significant differences in the scope of the electronic information products (EIP) covered by the two pieces of legislation, China RoHS looks set to cover requirements at the design, and production or manufacturing stages of affected products, whereas there are no such requirements in EU RoHS.

The speaker from Shimadzu Asia Pacific spoke about practical approaches to RoHS testing and screening. From a manufacturer point of view, confirming compliance with the essential requirements of RoHS could be in the form of: self-declaration (minimum cost, high risk), type testing (moderate cost, moderate risk), full quality assurance (high cost, no risk) or a combination of these. In addition to providing an overview of the different analytical techniques for RoHS testing such as inductively coupled plasma ¡V mass spectrometry (ICP-MS), atomic absorption spectrometry (AAS), and energy dispersive ¡V X-ray fluorescence (ED-XRF), the speaker also shared the Japanese experience in meeting similar requirements. A key point that came across was the importance of managing the entire supply chain when looking at ensuring compliance, and Japanese manufacturers' success in this include working closely with their suppliers to qualify them as "green partners". Interestingly, there were cases of RoHS compliant supplier products that were deemed non-compliant when measured against the stricter control values imposed by certain manufacturers.

The event ended with a case study presented by a Senior Sustainability Advisor of Philips Consumer Electronics. It came across that RoHS compliance is part of a much bigger sustainability focus, policy and framework in Philips ¡V the recognition that a sustainable business covers three bottom lines: economic viability, environmental care and social equity. With an established sustainability program, Philips Consumer Electronics did not have any problem with mercury, cadmium and halogenated flame retardants (PBB and PBDE) in their products, as these have been banned by the company since 1998. The company's main issues were identified as lead and hexavalent chromium. Key takeaways from its RoHS implementation include:

􀂾ƒnLong learning curve for RoHS introduction

􀂾ƒnPlanning is needed on both product and component levels

􀂾ƒnTracking and tracing is important due to process change

􀂾ƒnLogistics systems require adaptation

􀂾ƒnThere is a difference between data and real information

􀂾ƒnExtensive training of organization and suppliers is required

The RoHS Directive is not a uniform piece of legislation and has great complexities involving multiple pieces of legislation that may differ at various levels in different markets worldwide. As this RoHS maze emerges and becomes increasingly convoluted, more and more manufacturers will get "lost" in it. Many companies may expend vast amounts of energy only to find "dead ends" to their compliance problems. With the increase in business costs from the compliance, there will continue to be industry resistance and complaints about the measures. However, it is unlikely that the legislation will go away and investment in compliance is expected to continue.

Manufacturing Insights believe that the larger high-tech multi-national corporations with established sustainability or CSR programs will continue to strive beyond WEEE and RoHS compliance. Many are expected to integrate their environmental/compliance objectives with their overall supply chain management objectives ¡V building green supply chain management capabilities. Manufacturing Insights recommends that these large manufacturers consider putting in place an integrated compliance platform that will take into account both process and IT frameworks and building blocks that will allow their organizations to meet current and new compliances "on-demand". For the SMB manufacturers where things are the most vulnerable, education and awareness building will be important first steps. Despite their financial and resource constraints, SMB manufacturers can reduce compliance risks by focusing on a framework that includes: assess, plan, implement and monitor. For those SMB firms with "big brothers" in their value chains, there is opportunity to work collaboratively and tap on the expertise and experience of their bigger counterparts for successfully complying with RoHS requirements.

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Ng Buck Seng is Associate Director, Asia/Pacific, with Manufacturing Insights, an IDC company. Ng Buck Seng has been in the IT and professional services industry for over 14 years and he has extensive experience in helping organizations in both the public and private sectors make use of IT in their businesses.

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