Just when you thought it was safe!

Just when the US Design Engineer was getting used to the idea of ROHS with its mix of broad product categories, restricted substances and exemptions, the European Commission (EC) decides it’s time for change.

The EC has commissioned a comprehensive review of the scope. Here we look into our crystal ball and consider the potential outcome.

It is certain that the review will lead to more products falling within scope. The two missing categories from the WEEE (Waste Electrical and Electronic Equipment) directive, categories 8 and 9 (medical and monitoring & control instruments) have been reviewed by UK consultants ERA Technology, and they have recommended the inclusion of both, although implementation is not expected before 2012.

Some of the definitions will also be clarified, such as fixed installations (CCTV, alarms, heaters, air-conditioning etc) generally the kind of thing you would leave behind if you moved out of a building. Previously such products were considered to be out of scope, but this could change. Large-scale stationary tools will also be defined more clearly.

It is not obvious what the outcome of the review of “spare parts” will be. A component that repairs or ensures a product functions, such as a fuse, could fall within scope but it is not clear about accessories such as a PC mouse.

While it is certain that an extended product list will result it is also possible that there could be new restricted substances. More flame retardants, plasticisers (softens, and makes plastics more flexible) are candidates, while the likes of arsenic and beryllium are likely to be considered.

So, we have more products, and more substances in the pipeline and then a final sting in the tail, a complete review of all the exemptions that are currently in place.

All 29 exemptions will be looked at, and whether or not a suitable, more environmentally friendly, alternative is now available. If there is, the exemption is likely to be withdrawn.

The onus is on industry to submit technical data where they believe an exemption should continue. Maybe the alternative is no more beneficial to health and the environment than the current exempted substance. Seven new exemption categories will also be considered.

These will be important decisions as most equipment depends on at least one exemption, with probably the best example the many Passive components that depend on the “lead in glass” exemption.

In summary, more products, more substances and maybe some changes in exemptions are looming.

The published results are expected around the middle of the year with implementation likely to be 2010-2012.

About the author
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.