What's New for RoHS?

November 20, 2017

 

I took this video of friends on their new Surf boat – what a cool example of new technology.  Also, something potentially designated as a future electronic product.  As countries try to get a handle on the tons of garbage, all sorts of things fall under the heading of electronic waste.  2017 was an interesting year as companies begin to digest the European Court of Justice ruling on O5A – ‘once an article, always an article’ which had profound impact on both the supply chain and EU national enforcement authorities (NEAs).  The Director says that how to grasp the 0.1% threshold in real life will present a challenge.  A project for Q2 2018 is planned with inspections scheduled by the end of that year.   EU RoHS Category 11 products (almost everything else) will fall into that scope in mid-2019.  The scope was expanded to include much more than TVs, cell phones, and toasters in 2011 which brought in a much larger and non-electronic supply chain.    Here are a few expansions of RoHS legal landscape which might affect your business next year.

  • Global Impacts as other regions such as India considering an End-of-Life Vehicle scheme that would include scooters, to China RoHS with similar substance bans.  Add in countries from the Ukraine to the United Arab Emirates, and now we have global scope for RoHS.   That will effectively eliminate the use of many popular plasticizers and flame retardants.  Hint: You should be tracking those substances used in your purchased parts.

  • New Industries affected due to new RoHS2 scope includes products as varied as medical devices, monitoring instruments, and stand alone generators.  There will be new OEMs, new suppliers, and new requirements coming from unfortunately untrained companies supplying the electronics assembly or durable goods market.  Perhaps…you want to reach out to suppliers who traditionally haven’t had to do chemical content reporting.

  • RoHS overlap with other regulations from REACH to the EU Biocidal Product Regulation to California Proposition 65 Labeling requirements.  

    • REACH is probably going to live up to the promise of 400 Substances of Very High Concern by 2020. 

    • The Biocidal Product Regulation (BPR) is only applicable if the substance is used as a biocide within a treated article.  Lots of new concepts.

    • CA Prop 65 is a ‘right to know’ law that requires new labeling (with communication needs similar to OSHA for employees) that inform consumers about exposure to chemicals known to cause cancer and other reproductive harm.  This has introduced the concept of ‘bounty hunter’ lawyers who are suing ‘deep pocket companies’ with products potentially containing any of the 800 listed chemicals sold in CA that haven’t been paying attention.  Do you know if your products have phthalates, BPA, & etc…?

In conclusion, between the new scope, China RoHS, and CA Prop 65 a company should have a robust strategy and working team to achieve the proper information flows that have to occur within your company and out to the public.  I’d like to help!  Please feel free to contact me at B Cubed for further discussions or questions.  B3  www.bcubedconsulting.com

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