ROHS to cover all electrical and electronic equipment?
A draft proposal for the recast of the European Union’s ROHS (restriction of hazardous substances) directive has been published by the European Parliament (EP).
Among the proposed changes is to include all electrical products. The approach would be to add an 11th product category to the existing 10. The scope of the new category would simply be “other electrical and electronic equipment not covered by any of the categories 1-10.” In addition, the current exclusion of large-scale stationary industrial tools (LSIT) has been deleted and so all EEE (electrical and electronic equipment) including manufacturing production line equipment would be in scope.
Equipment covered by the new Category 11 would come into scope in July 2014.
The controversial “equipment that is part of another type of equipment that does not fall in scope and can only fulfil its function if it is part of that equipment,” is proposed to change to “part of stationary installations or transport equipment that is not electrical or electronic equipment.” This would bring into scope all electrical products used in building and transport (unless covered by other legislation such as the ELV directive), all “fixed installations” and electrical parts in aircraft, trains, ships, and commercial vehicles.
So the often quoted example of the car radio would, under the proposals, now be in scope.
The list of restricted substances has been increased considerably under the proposals, and includes PVC, chlorinated plasticizers, organohalogens, flame retardants, and the phthalates BBP, DBP, and DEHP. These will not be imposed on products in Categories 8, 9, or the new Category 11, until the European Commission has investigated and proposed a date.
The exemption for spare parts will be limited to 42 months after the amended directive enters into force. However, spare parts will have an exemption where the equipment benefited from an exemption that has subsequently expired.
The substances mentioned above will also be restricted in spare parts.
On exemptions themselves, the EP proposes that the expiry period is “up to” four years and not the current four years.
The Commission will decide within six months of an exemption expiring whether or not it will be renewed. Grace periods will be allowed, but for no more than 18 months after the exemption expires.
The Commission proposes to change the definition of homogeneous materials, which would now align itself more along the lines of China ROHS. The definition states that a homogeneous material is one that consists of only one material throughout, a combination of multiple materials that can not be mechanically disjointed into different materials or, finally, a surface coating.
These proposals will be debated well into 2010 but, once again, could have a significant impact on industry, not least leading to more substance data collection on products falling within scope and several new restricted substances.
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