New changes to the European Union’s ROHS (restriction-of-hazardous-substances) directive will force design engineers to carefully watch their BOMs (bill-of-materials) costs, as the industry targets the phasing out and expiration of a number of ROHS exemptions in the coming years. For now, the EC (European Commission), with guidance from its technical consultants Öko Institute and Fraunhofer IZM, has permitted exemptions in cases in which no technical alternative exists. Overall, the EC seeks to eliminate exemptions, however.

“The theory is [that] it will stimulate efforts to find alternatives that are more environmentally friendly,” says Gary Nevison, director of legislation and environmental affairs at UK-based Farnell and its US sister company Newark. The EC proposes to withdraw six of the directive’s 29 exemptions (see sidebar “Withdrawn ROHS exemptions”). “The announcement of the exemption eliminations is likely to be in 2010, and the Öko Institute is suggesting an 18-month grace period for manufacturers to comply, so we’re looking at 2012,” says Nevison. That time frame gives manufacturers little time to comply if alternatives are not readily available.

Moves to retire exemptions will likely continue over the coming years, and the industry will likely add restricted substances to the ROHS directive over time. “This is a trend,” says Fern Abrams (photo), director of environmental policy and government relations at IPC—Association Connecting Electronics Industries. “It was clear from the beginning that the EC did not want to give any exemptions,” she says. “[It] resisted exemptions and viewed them as evasive. The fact that there were exemptions showed that some part of the Commission was receptive to reality and what was technically feasible.”

One of the big challenges for engineers comes when a product has a long life cycle because there is always the possibility that exemptions will change during the lifetime of a product. These challenges particularly affect industries such as automotive, aerospace, and medical equipment because of the long life cycle of the products.

Much of the compliance responsibilities with ROHS and other directives such as the European Union’s REACH (registration/evaluation/authorization-of-chemicals) regulation fall on the shoulders of engineers who select components for design-in, and doing so is more difficult than choosing ROHS-compliant parts when exemptions are changing. “People will have to redesign some of their products because of restrictions,” says Ken Stanvick, vice president of Design Chain Associates, which helps manufacturers with environmental compliance. “You may lose one of your suppliers because an exemption went away,” he says. “It becomes a guessing game as to what will affect your product, so you need a system to alert you.”

Some engineers use consultants for help in predicting whether components will be safe from changes in environmental laws. Others turn to their distributors “If you’re designing a product that will have a long lifetime, you need to have a process in place that assigns someone to look at all of the changes and check them against your BOM so you can accommodate these directives sufficiently in advance,” says Steve Schultz, director of strategic planning and communications at Avnet Inc. “We take a high-level view, but we also zoom down to the individual component and work with our customers to review their BOMs,” he says.

So far, it seems that the electronics industry is coping well with the announcement of the elimination of six of the exemptions. “I haven’t heard any calls in real panic or even mild panic,” says Abrams. The quiet phones at IPC may indicate that the industry has simply become accustomed to progressive restrictions in substances contained in components.