Critical Links

This is a question I’ve been asked many times about the ROHS (Restriction of Hazardous Substances) directive.

In fact, this very subject can cause considerable emotion, and politics often raises its head when industry challenges the basis of ROHS.

The ROHS directive was originally bolted on to the WEEE (Waste Electrical and Electronic Equipment) directive. The idea was to eliminate hazardous substances from equipment which, in turn, would make recycling easier at end-of-life. This has been partially the case as recovering lead from WEEE is quite easy, although cadmium and mercury have proved more of a problem.

Initially, most of industry in Europe ignored ROHS thinking that it would never be accepted, but now it is probably too late to change it significantly, although many iterations are likely.

Interestingly, the current review of the scope of ROHS in Europe has resulted in 46 further substances, plus many flame retardants undergoing a stakeholder consultation. Also, further product categories are virtually certain to be included within scope. The findings will be published in June.

No comparative life cycle assessments were available when ROHS was originally drafted to determine if there was true eco-benefit. The policy was simply to restrict hazardous substances regardless of impact.

Is it wise, I wonder, to restrict one substance without knowing the full impact of the alternatives on industry and the environment?

So, what about the old issue of lead in solder? Some studies in the US have looked at life-cycle assessments (LCA), comparing lead, with lead-free solders. The LCA is complex and does not show that one is better than the other. They are simply different and both have certain advantages.

It is interesting to speculate whether lead would have been restricted by ROHS if such data had been available when ROHS was first drafted.

Also, what if the Energy using Products directive (EuP) had come first, reducing power consumption, when the use of lead-free solder demands increase in energy of around 7%?
Well, it’s back to the politicians and, if the question is “is it too late?” the answer is probably yes.

Finally, no one can doubt the good intentions of these directives. ROHS restricting toxic substances, REACH looking for safer control of thousands of chemicals, EuP seeking to lower power consumption and WEEE seeking to divert electronic and electrical equipment away from landfill sites.

Yes, these directives are here to stay, and on an increasingly global scale, with the likes of China and, to a lesser extent, India adopting an approach to both ROHS and WEEE.

About the author
As director of legislation and environmental affairs, Gary Nevison is Newark's and Farnell's spokesperson and customer interface on legislation that affects the electronics industry, such as the ROHS (all variations around the world, including China ROHS), REACH, EuP, and WEEE directives. For more on Gary, click here.