Critical Links

The REACH (registration, evaluation, authorization and restriction of chemicals) regulations and the ROHS (restriction of certain hazardous substances) directive approach the matter of substance restrictions in a different way.

ROHS restricts -- effectively bans -- six substances in electrical and electronic equipment that fall within the scope of eight broad categories of product (both the number of substances and product categories are likely to increase in the near future). There are also numerous exemptions. REACH, however, affects all chemicals, including those used to make the equipment (alloys, solvents, paint, etc.) and chemicals present in finished products of all types. There are very few exclusions and exemptions.

ROHS restrictions are based on hazards -- if a substance is hazardous and there are alternatives, then it could be banned. On the other hand, REACH restrictions are introduced only if a risk to human health and the environment can be proven, it cannot be controlled and substitutes exist.

ROHS restrictions can be imposed without a full assessment of the impact of the possible alternatives, even though they may not have been fully tested. It is enough to show that there is a potential risk without evidence of an actual risk.

For example, lead is banned by ROHS, but there is no evidence that its presence in electronics has, or is harming, human health and the environment. Also, the possible substitutes had not been identified when this restriction was first imposed in 2002, and although less-hazardous substitute alloys have since been found, their impact was not known until some years after the ROHS lead ban.

The US EPA carried out a life-cycle assessment that shows that neither lead nor lead-free solders are clear “winners” overall as they each have different properties and impact. Too late to impress the politicians, I’m afraid, but it would have been interesting if such data had been available prior to 2002.

REACH restrictions involve lengthy risk assessments that consider research into the impact of the substance in its entire life cycle and also the possible alternatives. This also considers the control measures used by industry to minimize risk and social and economic issues. REACH restrictions are likely to be application specific where a risk is identified, although total bans are also possible.

So, there are two differing approaches, with a move now within industry in Europe to prefer the REACH method. However, the Oko Institute, which carries out many of the reviews for the European Commission, still recommends the ROHS mechanism.
Expect on-going debate on this one.

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.