Published in September 2006

RoHS Compliance
By Scott Fehl

Environmentally friendly—and EU directive.

Re RoHS: "There should be a uniform standard across every state in the US, that allows manufacturers to clearly know what is expected of them."
--Chuck Wilson, executive director, NSCA

     "Environmentally Friendly" is a phrase that sounds simple, but in reality includes a multi-layer process. As the standards requirements placed on manufacturers to reduce environmentally unsafe materials become increasingly stringent, new and existing products can require re-engineering to be compliant. To successfully implement these changes in a component-by-component level of a product, a well thought-out plan becomes critical. The US and other countries following a legal trend started in Europe to reduce the amount of hazardous substances in electrical products has made the push for an environmentally friendly plan more urgent than ever.

Move to RoHS in the US
     For the past seven years, the Restriction of Hazardous Substances Directive (RoHS) has been a key topic for manufacturers that distribute throughout Europe. Under the European Union's (EU) directive, RoHS compliance was required as of July 1, 2006. Due to a law soon to come into effect in California, RoHS compliance is now becoming an issue for manufacturers who distribute within the US. Starting January 1, 2007, manufacturers selling electronics in California will have to adhere to the state's guidelines based on the EU RoHS directive.
     Under the EU's directive, manufacturers must limit the amount of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs) in "electrical and electronic equipment." Levels of these substances cannot exceed 1000 parts per million (ppm) for all substances except cadmium at 100ppm.
     Products that fall under RoHS include small and large household appliances, information technology and telecommunication equipment, consumer electronics, lighting equipment, toys, sports and leisure equipment, electrical and electronic tools, and vending machines. Compliance in Europe is relatively simple, because each of the 25 EU members will have the same guidelines. Any item being sold in the EU member states must meet the RoHS guidelines, or it cannot be imported or distributed in the country. As part of California's RoHS, the state will also be limiting the use of the hazardous substances listed in the EU directive. As with the EU's RoHS, products will not be permitted in the state that do not comply with the standards.

Steps to Compliance
     To stay competitive, many manufacturers will have to enact a RoHS compliance plan. Bringing products up to code involves a comprehensive procedure. Every component in a finished product must be considered and evaluated. The main objective is to make the product RoHS compliant without loss of function or performance. If a component has to be changed to achieve RoHS compliance, the replacement material has to also meet the performance of the original.
     In the case of wire and cable, the two general categories of components used in manufacturing are the conductive metals and the insulating or protective, plastic-based compounds. The most likely materials that may have to be updated are specific jacketing compounds and tin-coated conductors. In the past, additives in these components may have been used to achieve particular mechanical properties or a flame-retardancy rating.
     Replacing older, non-RoHS compliant compounds with newer RoHS-complaint compounds requires that the replacements have the necessary electrical, mechanical and flame-retardancy characteristics. Sometimes, these changes can be made simply, while others may require new advancements in plastics technology.
     During our move toward RoHS compliance, we found that some products required different color chips, plastic compounds and copper conductors, although many of our materials were upgraded to be devoid of these substances years before the official project started, and compliancy was required. As a result, our implementation was greatly simplified and fulfilled in a shorter timeframe.
Telex, one of many companies around the world that embarked early-on in a program to ensure all of its products met RoHS guidelines and deadlines, marks each of its products indicating RoHS compliance.

Inventory Management Problem
     Inventory management is another issue manufacturers must consider when making the switch to RoHS. Along with newly made products, manufacturers must review their current inventory to see if it meets RoHS standards. Items that do not meet these standards cannot be sold as RoHS-compliant material. Companies that distribute products will also have to conduct research as to whether the products they distribute are RoHS compliant.
     Perhaps it is best to certify that a product is compliant if it is manufactured after a specific date. This allows for a manufacturer to make a smooth, yet specific transition, from old to new inventory.
     From a manufacturer's standpoint, this probably does not require an extra procedure because most products are already tracked by date code for quality-assurance purposes. For distributors, on the other hand, this may require an added step if they are not already considering production dates in their inventory management systems.
     To eliminate problems when exporting distributed products, distributors must have documentation from the manufacturer stating the products' compliance. In turn, many manufactures as well as distributors have started to label the shipping containers as being compliant to expedite the importation process.
There is no universal logo for this initiative. Some companies, although fulfilling RoHS requirements, are using up older stock before retooling their printing to indicate their products’ compliance.

Impact of RoHS
     Converting products to meet RoHS compliance can affect their cost. Some materials can be two or three times the cost of the non-RoHS compliant version, while other materials may have a negligible cost difference and minimal impact. Though at this time RoHS is something that is being regulated by individual states in the US, the push for "greener" products is an issue that is unavoidable. Many states, such as Maine, Minnesota and Rhode Island, already have laws in place that make it illegal for certain electronic devices to be disposed of in the regular trash, so we can assume that more states will soon follow California's lead.
     In addition to the EU, China is looking to enact its own version of the RoHS directive. Because most of the new RoHS directives are building upon those set forth by the EU, manufacturers will find that many of their products already meet the new standards. With research and careful planning, manufacturers will be able to continue supplying their customers with the products they have become accustomed to and adapt to the new standards that come their way.


NSCA Position on E-Waste and Electronics Recycling
     The European RoHS Directive doesn't relate only to new equipment being installed; it also involves electronic products going into the waste stream. Here is NSCA's a policy statement:

"The National Systems Contractors Association (NSCA) supports an approach to the e-waste challenge that includes bringing manufacturers, contractors/integrators, end users/building owners and governments alike together to develop a commonsense federal solution. NSCA believes the lack of a national policy in the United States has lead to the mix of state laws and initiatives that are in place today. These state approaches will place avoidable burdens on all of the interested parties including the governments themselves. NSCA further recognizes that e-waste is a global problem and countries have offered varied solutions. These solutions should be analyzed to better understand their potential benefits and shortfalls prior to formulating the federal policy."
     According to NSCA executive director Chuck Wilson, "I think that Europe has done this right in developing EU guidelines There should be a uniform standard across every state in the US, that allows manufacturers to clearly know what is expected of them. I would like to think that we could influence federal legislation on this matter to have a US standard as opposed to each state developing its own guidelines, which would cause unnecessary regulations and uncertainty that eventually would lead to some states becoming the dumping ground for others."
     Wilson added, Once this directive hits home here in the US, we [NSCA] will step up our training programs to cover this and the current NEC code-related issues covering removal of abandoned cable and other proper disposal issues."


PLASA EuP Directive Warning
     Just before the RoHS Directive passed into UK law, the Professional Lighting and Sound Association (PLASA) issued a warning to its members about the forthcoming EuP (Energy-using Products) Directive, which may have the potential to hit manufacturers even harder than RoHS.
     Passed by the European Parliament in 2005 and due to be implemented into UK law in August 2007, the Directive aims to improve the environmental performance of all products that use any form of energy, throughout their entire life cycle of manufacturing, use and disposal. It will do so by enforcing systematic integration of environmental aspects at the earliest stage of product design.
     Like RoHS, the regulations will apply to all relevant (in this case, energy-using) products sold within the EU, wherever they are manufactured, although it is unclear how they will be enforced. For many manufacturers worldwide, the new measures will entail potentially substantial product redesign and re-engineering. The "ecodesign" parameters for an EuP's life cycle will include raw materials; manufacturing; packaging, transport and distribution; installation and maintenance; use and final disposal.
     For each phase of the cycle, a variety of environmental aspects will be assessed, including consumption of materials, energy and other resources such as fresh water; emissions to air, water or soil; pollution caused by noise, vibration, radiation and electromagnetic fields; generation of waste material; and the potential for reuse, recycling and energy recovery, taking into account the requirements of the Waste Electrical and Electronic Equipment (WEEE) Directive, yet to be enforced in the UK.
     According to Ron Bonner and Nic Bowker of PLASA's Technical Resources Office, "As with RoHS, it is up to manufacturers to look at these proposals well ahead and respond quickly. It will be too late in a year's time.
     "There are some exemptions, but, like RoHS, the directive's wording is very ambiguous in places. For example, it appears only to apply to products of which 200,000 or more are sold on the EU market per year. People might think that will exempt them if they manufacture, say, 10,000 units of a moving light per year, but what the directive actually means is that if the total number of all sales of moving lights by all manufacturers exceeds 200,000, then all the units will fall under the scope of the EuP Directive's requirement."
     The directive can be viewed at this web page with more information available here.


RoHS-Compliant Companies
     In January 2003, the European Union released Directive 2002/95/EC, effectively restricting the use of specific hazardous substances in electrical and electronic equipment (RoHS), effective July 1, 2006.
    Many companies took this to heart from the very beginning, embarking on three-year programs to alter their materials and, sometimes changing their manufacturing to upgrade production facilities, to accommodate this directive.
     Because this is a truly international industry, this affects US-based companies as well as those in the EC, even without any "structured" directive on this side of the pond. This is changing, with California leading the way, but there still is no unified "federal" approach. For example, the EU directive lists six substances; California's only includes four.
     Although we know there are many other companies that have altered their processes/products (or their products were already compliant!), we offer a listing here of businesses that have notified us by press release that they are RoHS compliant: Telex, Minneapolis MN; GTCO CalComp, Columbia MD; AMX, Richardson TX; Lighthouse Technologies, Irvine CA; Peavey/MediaMatrix, Crest Audio, Meridian MS; Crestron, Rockleigh NJ; Timbercon, Inc., Lake Oswego OR; Aviom, West Chester PA; TV One, Erlanger KY.


Scott Fehl is product manager for Gepco International, Inc., Des Plaines IL, which manufactures and distributes professional audio and video cable and interconnect products.

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