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."