Confusion over RoHS
Jim Carbone, Executive Editor, Electronics, Purchasing Magazine -- Purchasing, 5/26/2005 6:00:00 AM
There is widespread confusion in the electronics supply chain about what electronics companies need to do to show their products comply with the European Union law than bans the use of lead and other hazardous substances in electronic equipment.
The law takes effect July 2006. So far, there have been no set rules about what documentation will be needed to show compliance to the Restriction on the Use of Hazardous Substances (RoHS) initiative.
"We are all diligently awaiting those rules," says attorney Holly Evans, president of Strategic Counsel, a firm that advises companies on environmental regulations. "There is frustration in the industry because the rules have not been decided and the deadlines are looming."
She says electronics companies are trying to put in place compliance programs, but "they are operating in a vacuum. Without more information from the EU and member states it is a guessing game."
Evans says the European Commission has formed the Technical Adaptation Committee (TAC) which is comprised of representatives from member states. TAC is supposed to establish a process for ensuring that RoHS provisions are met. She says options being discussed by TAC are supply chain declaration and market surveillance/ testing.
While TAC has not made any decisions yet about compliance and enforcement, Evans says RoHS compliance will be a self declaration system. "Companies will declare that they are in compliance. The question is how do you support that declaration?" says Evans.
Until the EU issues rules for compliance, Evans recommends buyers follow guidelines issued by the United Kingdom’s Department of Technology and Industry. The UK has proposed a "due diligence" approach which may be used by other European countries. Rather than expecting manufacturers to prove that every part they buy is lead-free, EU member states will likely want manufacturers to establish documented and auditable systems to prevent non-compliant products from entering the EU, says Evans.
Such systems could include forming a corporate-wide compliance team, developing a corporate RoHS statement and developing a RoHS compliance roadmap.
Buyers at companies also need to take a close look at the parts they purchase from suppliers to determine where RoHS substances may exist within the company’s equipment. Lead in solder and surface finishes are obvious, but hazardous substances can also be in cables and plastics and housings.
Purchasers should also establish a supply chain material declaration process, says Evans. RoHS requires manufacturers to know what substances are prohibited in their products. Companies should establish a database for the information that they will receive from their suppliers so they can use it to determine compliance, she says.
"The more you document, the more you show that your supplier assessment and analysis appear reasonable, the better you can argue that you have done all you could to ensure prod-uct are RoHS compliant," says Evans.
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