Supply Chain Reaction

As we’ve reported here at EDN, the European Union’s ROHS (Restriction of Hazardous Substances) directive is currently under review. This review, as mandated by Article 6 of the directive, could see expansion in scope of ROHS including additional substance restrictions, the elimination of existing technology exemptions, and the inclusion of more electronics equipment.

The Government Relations and Environment, Health and Safety Committees of IPC — Association Connecting Electronics Industries this week voiced it concerns, encouraging the European Commission to make no changes at this time and urging that any proposed changes be held until the technical feasibility of their implementation can be reviewed thoroughly.

“Why compound the problem by expanding the scope of ROHS, when there are unresolved adverse reliability interconnect issues and greater adverse environmental, global warming and resource depletion impacts with the lead-free alternatives?" asked Lee Wilmot, director, Environmental, Health & Safety for TTM Technologies, and chairman of the IPC Environment, Health and Safety Committee, in a statement released Monday.

Dan Feinberg, president of Fein-Line Associates, and chairman of the IPC Government Relations Committee, backed Wilmot: “The industry is still dealing with the reliability effects of the lead-free provisions of ROHS. We’re urging the Commission to allow for a complete understanding of the effects of what has already been regulated, as well as new proposed regulations, before they are enacted into law. We also encourage the members of our industry to respond to the Commission’s invitation for comment and send their own specific concerns.”

IPC is making a common argument in the environmental compliance initiative arena: one for full life-cycle assessment. The trade association is looking for a comprehensive evaluation of the design, use, and end-of-life impacts of proposed substitutes before any changes take effect, but this may be a futile argument. If such an assessment wasn’t enacted before – proven by the continuing existence of design and end-product issues from lead removal including tin whiskers – there’s doubt that a full evaluation will take place this time around.

Cheers to IPC for standing up and voicing this concern on behalf of its 2,500 member companies. However, as important an argument as it is – and one that is becoming increasingly common – true full life-cycle assessment is often an ignored measure by the EU.

Of course, the EU has had no problem mandating life-cycle assessment by the electronics supply chain with EuP, a framework directive on eco-design of energy-using products. EuP and its requirements force manufacturers to consider the entire lifecycle of product groups -- from raw materials, acquisition, manufacturing, packaging, transport and distribution, installation and maintenance, use and end-of-life disposal -- and to assess the ecological profile of the equipment by requiring manufacturers at each stage to evaluate consumption of materials and energy, emissions to air and water, pollution, expected waste and recycling/re-use. Yet, the life-cycle assessment favor isn’t returned when it comes to the likes of ROHS or REACH. 
 
Speaking of REACH, IPC is also urging the Commission to consider that any further substance restrictions be regulated under the chemicals directive to avoid “unnecessary confusion” and “to prevent overlapping and duplicative chemical regulations.”

A copy of IPC’s full comments is available at www.ipc.org/commentRoHS.

Comments on ROHS can be submitted to the Commission until February 13.

See “ROHS: It ain’t over” and “Ring in the new rules” for more on the review of ROHS. 

Share your thoughts on this arguement and the ROHS review below.