Proposed RoHS Revisions

The Restriction of Hazardous Substances (RoHS), which was finalized by the European Parliament and the Council of the European Union on January 27, 2003, bans the placement of new electrical and electronic equipment (EEE) containing lead, cadmium, mercury, hexavalent chromium and both polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants as of July 1, 2006.

TThe much anticipated review of the European Union’s (EU) RoHS Directive was released on December 3, 2008. The proposed revisions attempt to simplify and clarify the Directive without repealing it altogether. The revisions suggest that no additional substances should be included in the ban; including tetrabromobisphenol(a) (TBBPA). TBBPA is the most widely-used flame retardant in printed circuit board (PCB) manufacturing. However, four substances have been identified for priority assessment and possible ban under RoHS; Hexabromocyclododecane (HBCDD), Bis (2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP). The proposed revisions more closely align RoHS with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), the Energy-Using Product (EuP) Directive, and the Waste Electrical and Electronic Equipment (WEEE) Directive. The proposed revisions expand the scope of RoHS to include medical devices and monitoring and control instruments.

Manufacturers, importers, and distributors of electrical and electronic equipment (EEE) will be required to place a CE marking on the EEE in order to show the product is compliant with RoHS. Although manufacturers, importers, and distributors all have obligations under RoHS, the manufacturer will assume responsibility for EEE compliance for products placed on the EU market; obligations of manufacturers, importers, and distributors can be found in Articles 7, 9, and 10, respectively, of the Directive. A copy of the proposed revisions can be found at http://ec.europa.eu/environment/waste/weee/index_en.htm.

IPC continues to urge the Commission to avoid changing the scope of RoHS at this time since the full technical, social and cost implications of the RoHS Directive’s implementation are still being discovered. IPC has also encouraged the Commission to address any further substance restrictions under the EU’s current REACH Directive in order to avoid duplicative and overlapping regulations.

• December 9, 2008 –Proposed RoHS Revisions Released
  IPC Remains Cautious Until Directive is Finalized
• September 17, 2008 –The Electronic Interconnection Supply Chain’s Response to Öko-Institut Recommendations for Proposed Revisions to the RoHS Directive
• June 25, 2008 –IPC Brussels Meeting on RoHS Revisions Identifies Concerns with Öko-Institute Study
• June 18, 2007 – IPC Brussels Meeting Agenda and Presentations
• June 11, 2008 – IPC Letter to EU Commission Regarding Concerns Over the Oko-Institute Report” “Study on Hazardous Substances in Electrical and Electronic Equipment, Not Regulated by the RoHS Directive” (.pdf)
• May 19, 2008: IPC Initiates Scientific Dialogue on Proposed RoHS Expansion Industry Experts Urged to Attend Special Meeting
• May 9, 2008 – IPC Letter to EU Commission Regarding the Öko-Institute’s Lack of Transparency During Development of its “Study on Hazardous Substances in Electrical and Electronic Equipment, Not Regulated by the RoHS Directive” (.pdf)
• April 28, 2008: Study on Hazardous Substances in Electrical and Electronic Equipment, Not Regulated by the RoHS Directive
• March 27, 2008 – IPC Comments to the Öko-Institute Regarding its List of Potentially Hazardous Substances in Electrical and Electronic Equipment (.pdf)
• January 10, 2008 – IPC Comments to the EU Commission Regarding the RoHS Review (.pdf)

The Waste Electrical and Electronic Equipment (WEEE) establishes maximum recycling targets for electronic equipment and was amended in December 2003 (.pdf). Timelines for complying with WEEE (.pdf) are summarized graphically.

Under EU law, each of the EU member states were required to implement the RoHS and WEEE directives into national law by August of 2004. The  United Kingdom has studied the implementation of RoHS throughout the EU (.pdf).