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New ROHS proposals seek to change scope

September 17, 2009

Following discussions between EU Member States and the Council of Ministers, new proposals have been put forward by Sweden, which currently owns the EU presidency, to amend the scope of the ROHS (Restriction of Hazardous Substances) directive.

Under the proposals the scope will change to encompass all electrical and electronic equipment unless specifically excluded. Currently there are eight product categories with binding examples of what products fall within scope. A recast, published in December 2008, also proposed the phased in addition of categories 8 and 9 (medical devices and monitoring and control instruments).

Under the new proposals all electrical and electronic equipment (EEE) will fall within scope, unless specifically excluded. Annex I (the 10 broad product categories) and Annex II (binding list of product examples) have been deleted from the text of the ROHS recast and will now sit, as before, within the WEEE (Waste Electrical and-Electronic Equipment) directive, although Annex II is referred to as indicative as opposed to a binding list.

There are new exclusions from the ROHS text such as large-scale stationary industrial tools (LSIT), but the impact of the revised proposals is clearly to include products that are not currently in scope.

It is also proposed to delete Annex III that lists four substances - BBP, DBP, DEHP, and HBCDD for priority assessment, leading to possible restrictions.

However, the Commission intends to adopt a methodology for the review of the restricted substances in Annex IV (the original six possible, but unlikely) and new substances where deemed necessary in the future, based on the process set out in Articles 69 to 72 of the REACH (Registration, Evaluation and Authorization of Chemicals) regulations.

This would look to review a substance used in EEE, or the waste derived from it, that poses a hazard to human health or the environment that is not adequately controlled.

However, industry will be interested in the scope, where any product that relies on electricity to function could be included, as well as the status of some of the grey area products. No longer will there be the “is it in scope or is it out” issues as with, for example, semiconductor development tools at present, as everything will be within scope unless specifically excluded.

ROHS was previously unclear, especially for fixed installations, and it is probable that these proposals are an attempt to resolve this. However, “equipment that is part of equipment that is out of scope is itself out of scope” remains in the text so uncertainty is likely to continue.

Posted by Gary Nevison on September 17, 2009 | Comments (19)

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In response to: New ROHS proposals seek to change scope
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In response to: New ROHS proposals seek to change scope
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November 8, 2009
In response to: New ROHS proposals seek to change scope
Matt Boland commented:

WEEE is definitely a better concept than RoHS. RoHS was a kneejerk reaction to the word "lead". I think WEEE has the ability to push quality back into goods so that they last longer, are designed to be servicable, and are designed to be broken down to recyclable parts when they finally give up the ghost. The funny thing is that this is how people used to design things, and they didn't need a bunch of politicians to tell them to do it. Everyone can help. Buy well made products that are designed to be serviced and that have good spare parts available. Don't wait for the politicians to tell you that's better for the environment. Note that I didn't say expensive products, though there must be some up front cost paid for quality.


September 25, 2009
In response to: New ROHS proposals seek to change scope
Guido Körber commented:

I am all pro environment protection and that is why I am against such bullshit as RoHS. Lead free solder reduces product life time, increases energy required for soldering, and increases production failure rate by higher solder temperature and worse solder behaviour. Since the RoHS legislation came into effect we had to add a humidity controlled cabinet and moisture barrier bags to our material flow. Introducing a compuond packaging material that is hard to recycle and an energy guzzler that runs 24/7. I wonder how many years it will be until Greepeace and the other run-amok NGOs find out that their good intentions created an even bigger heap of even more toxic waste. If any of them actually cared about net results they would go for ending the illegal export of waste electronics to third world countries where the stuff is roasted over open fire. Proper recycling at the state of the art of all the electronic waste would not only reduce environment poisoning, it would also preserve valuable resources.


September 22, 2009
In response to: New ROHS proposals seek to change scope
Greg USA commented:

Even though I'm in USA -no ROHS legislation it has still effected us .. mfrs not buying leaded parts just in case they want to sell product outside USA or in case electronic component mfr decides not to make leaded . I think the whole process ROHS was complex and gov't buracracy... There is some doubt raised by comments about others on lead in electronics being environmental problem... But the point is lead and other materials in electronics don't pose much environmental risk in mfr or electronics use but rather end-of-life disposal... So... why not just concentrate on end-of-life recycling since that's where the problem is... Make it easy such as local pick up with other recycleables ..... they already have trucks pick up or drop off locations for paper, glass, plastics .. why not electronics? hold on let me repeat for gov't oficials MAKE IT EASY, CONVENIANT! COST EFFECTIVE. ! As an independent disty of electronic parts I can tell you some parts are going to dump without being used just because there is no market now for leaded parts and they aren't worth recycling unless they have gold --which normally is only military parts... So how smart is that environmentally? Ditto for fact now equipment will not be repaired but rather in trash. Also, more important this is going to put businesses -small businesses under , out of business! I mean isn't it hasrd enough already to compete and stay alive in this economy --worst in 50 YRS!


September 20, 2009
In response to: New ROHS proposals seek to change scope
Markus Unread commented:

I remember when ISO9000 came out. It was explained as - "These two blokes are in a bar and one says "How can I make money without actually doing anything". "Come up with a standard that people have to pay you to become certified!" "Brilliant! Let's give it a go..." I wonder how many ROHS founders own stock in tin mines... M


September 18, 2009
In response to: New ROHS proposals seek to change scope
Kip commented:

If you'll think about it, environmentalism is about control. It's the new communism and it jumps borders. Why do you think Gorbechev founded Green Cross International and was one of the sponsors of the Earth Charter. It's about control.


September 18, 2009
In response to: New ROHS proposals seek to change scope
Timbalionguy commented:

This is what happens when you get a bunch of people where 'green', animal rights, etc. becomes a 'religion'. What it is really all about is control. They just want to see everyone else jump through hoops for some sadistic satisfaction. And they are motivated enough to use any means, right or wrong, to pursue their ends. I can't wait until a tin whisker in a pacemaker, etc. kills someone. I hope the family of the victim sues the greens, the EU, etc. instead of the electronics manufactrers. Hopefully, it will start to return us to greater sanity. At least, the RoHS stuff has gotten little traction here in the US.


September 18, 2009
In response to: New ROHS proposals seek to change scope
Articles on ROHS Compliance Please commented:

Dear Gary Nevison, I would appreciate an article or series on design for ROHS compliance. Our small company cannot afford to get it only 99 percent right. We need directions to the ROHS requirements which are preferable FREE and easy to read. We need a clearing house of vendors for PCB assemby and enclosures which know how to be compliant. Thanks, Forrest Erickson


September 18, 2009
In response to: New ROHS proposals seek to change scope
DCE commented:

The biggest fraud of RoHS was the removal of lead from solder. The tin/lead alloy has not been a problem in regards to lead leaching into groundwater from land-filled electronics as the alloy is relatively stable (even the EPA says so). The problem has been elemental lead in car batteries, tetra-ethyl lead in gasoline, and lead acetate in paint. The EU bureaucrats all saw the word 'lead' in each of these and assumed that all lead in all compounds under all circumstances was a problem. Hence, the banning of lead from electronic solders because "lead is bad!!!" While lead-free solders may not be much of an issue for consumer electronics items like cell phones (useful life is somewhere around 2 years), it has been a real pain in the butt for our products (test equipment) as we've started seeing more field returns for failures ultimately caused by tin whiskers. Adding even more substances without critical review of their actual hazard to humans would be a bad idea. (The powers that be wanted to add TPBBA to the list (a fire retardant used in PCBs) even though it has been proven over the last few decades to pose no threat to the environment or human health. The only reason they were considering the ban? Because it contains bromine, another "bad" element that, in this compound, it totally benign.


September 18, 2009
In response to: New ROHS proposals seek to change scope
LCC commented:

the old exemptions excluded monitoring and instrumentation equipment - relatively low volume stuff with product design lives of 10 years and high dollar value that has useful lfe of 10-20 years in many cases. It may make some sense for high volume consumer products with design cycles under a year and production life cycles of 1-2 years and useful life to scrap times of 2-3 years to meet ROHS. But redesigning all the instrumentation products is going to be very costly.


September 18, 2009
In response to: New ROHS proposals seek to change scope
Danger and liability commented:

A dangerous development, and the EU will be held liable in courts. Let's get all lawyers to take this on and sue the crap out of these governments in the EU. Airbus crashes, etc. Bummer.


September 18, 2009
In response to: New ROHS proposals seek to change scope
ill engineer commented:

On a personal level, since the introduction of ROHS lead free soldering processes I have had health issues, to a point that I no longer work with lead free solder unless the fume extraction can ensure zero exposure, if I sat down and soldered a handful of joints my chest would tighten, nose run and eyes itch or burn, in over 20 years in industry exposed to varying levels of fumes and vapours I have never had this reaction. How many other engineers are in the very same position ?


September 18, 2009
In response to: New ROHS proposals seek to change scope
George Macdonald commented:

This just the madness of the EU and its ruling body, the EC... made up of unelected, self-regarding "officials" who are answerable to nobody and whose every blunder & misstep gets rubber stamped by a parliament made up of failed "politicians" who are unelectable at the local level. On top of that every country's representatives want to put their particular national crackpot idea on the table for uhh, discussion and approval... Sweden, of course, being the archetypal nanny state. It all boils down to: if you are not capable of innovative development, restrict those who are. The results of their persistent, malicious meddling and tampering are already evident in every field they touch. Electronics is an easy target for them - the general public knows little of the true effects of so-called green legislation and unfortunately, the final results will be years in making themselves evident.


September 17, 2009
In response to: New ROHS proposals seek to change scope
krishna commented:

Already there are enough proof that RoHS complience would make things worse instead of making it any better. Fighting with Tin whiskers is going to be much toughter task than the hazardous, toxic, Lead. Else, an alternative material for replacing tin whiskers needs to be found. More needs to be done to make it "really green and safe"....Till then, RoHS can be put on hold to avoid complicating the less complicated.


September 17, 2009
In response to: New ROHS proposals seek to change scope
XRF instrument maker commented:

I make the test equipment for RoHS, and I see our customers struggle, trying to make sense of what we all know is actually making pollution worse- since the things we use instead of lead have a much higher mobility and EPA tests have shown definitively are more toxic. I am sad to see the place where Vikings came from try to further this destructive idea, because some politician was told by a non-scientist is "greener than the old way". RoHS is terrible for the planet, terrible for the economy, and wastes the working lives of decent hardworking people. What a waste


September 17, 2009
In response to: New ROHS proposals seek to change scope
Small businessman commented:

I am so sick and tied of these rules that tie up small companies, tied of the moving goal posts, tied of the additional paperwork, tied of getting paperwork from suppliers. If you are a company of 100 technical people it costs a company a lot less overall to comply BUT for a small company of sat 10 technical people the cost is large with little or no return and what is achieved nothing. Other countries and states are bringing in their own rules, this will cause a nightmare because there will be no common language, misunderstanding in translations, lack of clear understanding by enforcement personnel unless they are experts in the technology. What happens where a product is designed as being exempt due to the type of product and is then used in a non exempt application more time waisted going through whatever loops the enforcers want to put you through. As Lio pointed out about Australia we (Australia) going through this silly exercise currently where the government if it does not get its way threatens to dissolve parliament and call an election 12 months early. WHERE IS COMMON SENCE


September 17, 2009
In response to: New ROHS proposals seek to change scope
John commented:

..... Road to hell , paved with good intentions...... ROHS, a mis-guided effort, going further down the wrong road...now our pacemakers will have crappy connections/ tin whiskers/ tin rot.. great.


September 17, 2009
In response to: New ROHS proposals seek to change scope
Lol commented:

What a waste of time. How many leaded TVs does it take to equal the disposal of a single car battery? 1kg of pure lead plate in every of the millions of cars in existance. Its almost as ludacris as Australia lowering its emissions while China puts out 1000x more. Ever heard of the word 'insignificant'.

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