RoHS: The tip of the environmental iceberg
The European directive restricting the use of lead and other substances in electronics is the beginning of a wave of global environmental laws.
By James Carbone -- Purchasing, 6/15/2006 6:00:00 AM
For the past two years, most electronics companies have been working diligently to comply with the July 1 deadline of the European Union's (EU) Restriction of Hazardous Substances (RoHS) law that prohibits the use of lead and five other substances in electronics equipment.
The good news is most large OEMs and electronics manufacturing services (EMS) providers say they are in compliance with the law and have the necessary documentation to prove it. The bad news is any buyer who thinks RoHS compliance is the endgame of environmental regulation is sadly mistaken. Other countries have passed, or are considering environmental laws regulating hazardous materials in electronics equipment, including China, Korea, Japan, Argentina and other South American countries.
And if you think electronics is the only technology covered by new environmental initiatives, think again.
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The European Union's REACH (Registration, Evaluation and Authorization of Chemicals) Directive puts requirements for listing and testing on manufacturers of chemicals. It's similar to the U. S. Toxic Substance Control Act. Cement is considered a chemical for regulatory purposes.
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The End of Life Vehicle Directive from the European Union restricts the use of certain hazardous substances in cars, vans and certain three-wheeled vehicles. The directive affects the dismantling, recycling and disposal of the vehicles.
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As of September 15 last year, all wood packaging material (both coniferous and nonconiferous) coming into the U.S. must be certified as treated to prevent importation of harmful pests. The regulation (International Standard for Phytosanitary Measure 15, or ISPM 15) adopted by the U.S., is being phased in from now through July 2006. Goods shipped into the U.S. on pallets or other packaging must have an official stamp indicating compliance on the pallet or container.
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And there are other regulations covering cosmetics, detergents and toys.
Some of the legislation is similar to RoHS. For instance, China's Regulation for Pollution Control of Electronics Products law bans the same substances as the EU's RoHS directive. However, the law is stricter than RoHS because there are no equipment exclusions or exemptions.
"RoHS is just the tip of the iceberg," says Jackie Adams, RoHS procurement engineer at IBM, in Armonk, N.Y. "China's regulations are going to be tougher than the EU's and Korea's will probably be tougher than China's."
U.S.-based companies that sell equipment just in North America may not have to worry about environmental laws in Europe or Asia, but they will have to deal with environmental regulations in individual U.S. states.
California has passed a law similar to RoHS and the EU Waste Electronic and Electrical Equipment directive. The California law takes effect next January. In addition, more than 20 other states are considering similar legislation that bans the use of certain substances in electronics equipment.
"People like to talk about RoHS, but what is coming is going to make RoHS look like a little pebble," says Seb Nardecchia, director, environmental compliance for Flextronics, of San Jose, Calif., the world's largest electronics manufacturing services (EMS) provider. He says the biggest challenge for the electronics industry will be China RoHS, which goes into effect March 1, 2007.
"The scary thing about it is China hasn't been clear on the requirements of the law," says Nardecchia. "We thought there was ambiguity and interpretation with the EU RoHS," but there is even more ambiguity with China RoHS, he says.
No free pass
Nardecchia says the same six substances are banned by China RoHS, but the law is different from EU RoHS because it has no exemptions or exclusions.
"So, if you are in the networking business or medical or military, you are not exempt," says Nardecchia. EU's RoHS has exemptions for those industries.
Another way the two laws are different is EU RoHS is a self declaration process and doesn't require any formal certification.
"The Chinese government has commissioned 18 laboratories in China, which will be used to provide certification," says Nardecchia. "Just as we have CE (Community European) marked products, we are going to have products going into China with a CCC (China Compulsory Certification) label to show they are compliant." Every new product will have to be checked and be certified, he says.
In addition to China's laws, buyers need to keep an eye on another European directive called the Energy-using Products (EuP) law, which is scheduled to go into effect August 2007.
"EuP is complementary to RoHS," says Michael Kirschner, president of Design Chain Associates, a supply chain consultant in San Francisco. "It addresses more material usage in terms of amount rather than type as well as energy utilization during the manufacturing and use phase of the product," he says. The directive covers electronic products that are shipped into the EU or sold there if quantities are 200,000 or more. It would include products such as computers and televisions and other consumer electronics equipment.
This year, the directive makes no legal requirements for electronics equipment manufacturers, but that will likely change next year.
"Right now it is a framework directive," says Kirschner. "What the EU wants is for industry to define an ecological profile for products, which will be a metric. This metric would be used by a consumer who is trying to decide what type of notebook computer to buy, for instance," he says. So, in addition to such attributes as the type of microprocessor and the amount of memory in a computer, the consumer would have an ecological profile of the notebook. "It would show how ecologically good the computer is in terms of energy utilization, and materials utilization," says Kirschner.
He notes that the Energy Star seal gives an indication of energy use, but the EuP directive "extends that backwards toward manufacturing." It would measure the amount of energy needed to process the raw materials used by the computer and in the manufacture of it and energy usage of the computer through its life.
"What's interesting is some of the EuP research documents for a PC showed that 25% of the energy used in the lifetime of a computer occurs just in the manufacture of it," says Kirschner. He adds most electronics equipment is in that range.
Kirschner says analyzing the types of raw materials used to build a piece of equipment is important because different materials require different amounts of energy. Less energy is used for recycled metals and plastics than for virgin metals and plastics, he says.
The European Commission (EC), which oversees the directive, is trying to figure if it needs "implementing measures." Such measures would result in legal requirements on electronics manufacturers. "Hopefully the industry can rally and agree on voluntary standards and not have to be regulated," says Kirschner.
By July 2007, the EC will decide if implementing measures are needed and Kirschner says some measures are likely.
| Related RoHS information: http://www.inemi.org/cms/projects/ese/lf_hottopics.html http://ec.europa.eu/environment/waste/weee_index.htm http://ec.europa.eu/enterprise/eco_design/index_en.htm |
Be prepared
Although there are no legal requirements yet, the EuP directive is more significant than RoHS, according to Pamela Gordon, president of Technology Forecasters, a consultant and market researcher for the electronics manufacturing services industry.
“It is a much more powerful directive in that it looks at the environmental impact of a product during its entire lifecycle,” she says. She says the electronics industry has to prepare for the directive.
“At this point, what an electronics company should do is get all of their stakeholders—designers, purchasers, marketing people—together in a multidisciplinary team and get them trained in design for the environment,” says Gordon.
She says the team should look at various considerations in the design of a product, including:
• What materials should be used to reduce energy consumption?
• Should the product be in a plastic or metal case?
• Can the product be reduced in size and use fewer parts to reduce energy consumption.
• Can the product be lighter or smaller so it uses less energy?
• What is the energy consumption, be it battery or alternating current, over the lifetime of the product?
She says the sooner electronics companies start working on EuP the better.
She says some companies were slow to work on RoHS compliance and had to scramble to meet the
deadline. “By waiting to the last minute those companies had to spend more money than they otherwise would have if they got an early start. With EuP, companies don’t want to make the same mistake they did with RoHS,” she says.
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