REACHing Across the Divide
Just as component engineering companies had got their heads around the intricacies of RoHS and WEEE legislation, along came the REACH EU directive, the most complex of the European Union laws yet. Much as there is a need for environmental compliance, mechanical design companies are feeling distinctly frazzled at this latest addition to their workload. But they’re in good company. REACH compliance affects everybody in the supply chain: Importers and distributors, who must ensure products from outside the EU comply with the new legislation; component manufacturers, who must recall non-compliant products and develop replacements; downstream users, who must ensure they use only REACH compliant products, and end-users, who must ensure OEMs are obeying the rules, and dispose of non-REACH compliant products correctly. Obsolescence management has never been so important. Initially, the hazardous chemicals listed by the ECHA (European Chemicals Agency) as coming under the REACH directive numbered just 16. This was in June 2008. Currently, the figure stands at over 30,000 – and is rising as more data becomes available. The ECHA has estimated that the high cost of REACH compliance will have at least 2% of the listed chemicals driven off the market, leaving manufacturers to come up with environmentally compliant alternatives to the products incorporating them – or declare those products obsolete. As kinks start to appear in the supply chain, users will be seriously compromised. The good news for electronic and mechanical design companies is that there is plenty of manufacturing support from distributors, component manufacturers – and us at Enventure Technologies. From obsolescence management tools to component engineering services, our high value engineering solutions will ensure you always REACH compliance.
PCN Alerts – A Growing Problem With REACH Regulation
With the dreaded “gang of three” – RoHS, WEEE and REACH compliance – now in full force, obsolescence management systems are going into overdrive, not least in the fields of electronic component engineering and mechanical design. With environmental compliance now central to everything engineering companies do, it’s no wonder they turn so many of the tasks over to us at Enventure Technologies. Obsolescence management comes under the umbrella of enterprise data management, and along with environmental compliance is essential in the engineering workplace. Normally, it takes around three years for components like semiconductors to become obsolete. Until the RoHS and REACH regulations came into force companies could expect a steady trickle of PCN alerts, which were easy to deal with as suppliers invariably held back-stock of obsolete semiconductors and other outdated components in store. That trickle has now become a torrent, with component manufacturers disposing of their “non-green” stocks rather than holding on to them. Some continue to supply obsolete semiconductors containing SnPb (tin-leaded) residues, as certain end-users are not yet subject to RoHS, WEEE or REACH legislation, but these exemptions are slowly being phased out. Responsible engineering firms want to be seen as “green” as possible. In the lead-up to RoHS and REACH legislation being made law, authorized distributors took the role of communicators, creating awareness and offering advice to clients. Now, they have shifted to obsolescence management, offering practical solutions and alternatives to discontinued products. Early communication is essential between end-user and supplier, to minimize disruptions in the supply chain. Our obsolescence management tools play a vital role in this.
Obsolescence Management and REACH Legislation
The REACH directive is an unwanted burden to companies already struggling under the weight of WEEE and ROHS compliance. RoHS/WEEE legislation covers just six main chemicals – more than enough for the average CAD designer or DSP programming engineer. REACH covers thousands more, affecting hardware design companies who were previously RoHS-exempt, as well as those already struggling with the rules. The most complex of the European Union’s environmental rulings to date, the REACH EU legislation has wide-ranging implications on electrical and mechanical design companies. It was established to control the production and use of chemical substances thought to be a risk to health, safety and the environment. So far, comprehensive risk assessments and safety data have been published for 30,000 substances, with many more implicated in the next decade. Obsolescence management was once a straight forward affair. System designers realised that as technology expanded, component engineering would have to follow suit. Generally, they could expect electronic components to be around for about three years before they were out-of-date. So, they happily absorbed each new PCN alert as it came along, relegating obsolete semiconductors to the bin and purchasing better drop-in replacements. However, the new directives have compromised things to the point where firmware development companies despair of giving an effective service to their clients. With RoHS legislation exemptions now expiring, plus the growing REACH directive list, the industry has been hit by a flood of PCN alerts and end-of-life notifications from component suppliers – who are similarly concerned. Thankfully, we at Enventure Technologies offer obsolescence management tools and environmental compliance solutions which are specially tailored for the needs of each customer.
Obsolescence Management – RoHS Directive Exemptions
The Restriction of Hazardous Substances and Waste Electrical and Electronic Equipment (RoHS/WEEE) directives became legally binding in 2006. Although a number of applications were exempt from the rules, the dates for many of these have expired – with more to follow. This has had tremendous repercussions on hardware design companies whose products are dependent upon what are now, effectively, obsolete semiconductors. Obsolescence management is a necessary part of firmware development. As electronic technology advances at an ever increasing rate, so do end-of-life (EOL) dates. On average, semiconductors become obsolete within 3 years of being introduced. Once the product is announced as discontinued, customers have at most a year to find a replacement, or redesign their system so it no longer needs that component – though generally, drop-in replacements are available. However, technological advancement is not the only reason for product change notification. PCN alerts due to pending expiry dates on the RoHS directive exemption list are increasingly of concern. Many aerospace, medical and telecommunication system designs are dependent upon components with a high SnPb (tin-lead) content. Finding alternatives has become a major problem in obsolescence management. There are many ways around the problem. For example, reverse engineering using non-lead derivatives has enabled companies to find replacements for obsolete semiconductors which don’t contravene RoHS legislation. System redevelopment is another option. The main thing is to be prepared – don’t just wait for the EOL date to arrive. We at Enventure Technologies can’t change RoHS directives – but we do have obsolescence management tools to ensure they are of minimum risk to your clients.
The WEEE Problem of Obsolete Semiconductors
Following toxic chemical concerns, the EU RoHS WEEE (Regulation of Hazardous Substances/Waste Electrical and Electronic Equipment) directive became European law in February 2003, with the deadline for full compliance being set at August 2004. The result was thousands of suddenly obsolete semiconductors which had to be replaced with lead-free alternatives. There were six banned chemicals in all, including mercury, cadmium, hexavalent chromium and polybrominated bi and diphenyls. Luckily, a number of component manufacturers were able to supply lead-free products compatible with the obsolete semiconductors being discontinued – often even when the component was not available in lead-free form from the original manufacturer. To soften the blow, many suppliers kept the cost of the lead-free versions the same as the lead-soldered ones, which continued to be sold. Some component engineering companies, for example those producing medical equipment, are currently exempt from RoHS legislation. There was some outcry over the cost of the RoHS WEEE directive from electronics manufacturers, who from August 13, 2005 were financially and physically responsible for WEEE compliance. Under the ruling known as extended producer responsibility, or EPR, manufacturers had to deal with the collection, recycling and recovery of electronics goods which had come to the end of their lives, in an ethical and responsible manner. Since “end of life” often meant the disposal of perfectly serviceable products that failed RoHS standards, it was a double expense, since these products had to be replaced. If you are struggling to comply with all the RoHS, WEEE and REACH directives, we at Enventure Technologies have a number of solutions to help you keep on track – and keep expense to a minimum.