The EU RoHS directive – a worldwide issue
The RoHS compliance laws apply to all products entering the EU, and thus affect component engineering companies worldwide. The US is a major exporter of electronic products to Europe, and anyone producing components, embedded firmware etc. for this market have to abide by the EU rules. Although the EU RoHS directive does not apply to products manufactured for the home market, some US states have launched their own environmental compliance laws in line with EU legislation. But it isn’t just RoHS compliance that component manufacturers have to be aware of. There are other EU rulings which affect us too, such as the ELV, WEEE and REACH directives. The environmental compliance laws in North America vary enormously between states, as do those in countries outside the EU and USA. In addition, the EU is constantly updating and modifying its RoHS/WEEE directives. This all makes environmental compliance management extremely complex for COTS (commercial off-the-shelf) manufacturers. Rather than customizing, say, a PCB design to fit round individual compliance laws, it makes sense to have just a single bill of materials which fits all criteria worldwide. With an eye to the future, several large manufacturers have developed their own standards, some of which are even stricter than those laid down by the EU. IBM, for example, banned DecaBDE as part of its environmental compliance management program, even though it was RoHS-exempt. Later, however, it became a RoHS target. This was overturned by the European Court in 2008, but at least IBM was covered in the interim. For all issues concerning BOM management, you can rely upon us at Enventure Technologies to come up with the right solutions – however draconian the environmental compliance laws become.
The RoHS and WEEE directives – recent developments
Electrical and component engineering companies exporting products to the EU are heavily governed by ROHS/WEEE legislation. As this effects companies located outside of the Union, it is essential to keep up to date with the latest changes, and have an effective master data management scheme that includes obsolescence management tools. RoHS/WEEE legislation is a complex area, but an essential one for PCB designers and component manufacturers, as it covers areas like tin-lead solders and semiconductor finishes. Both directives are in the process of being revised. It’s important to realize that the laws simply act as a template, and that each European country may have its own specific regulations. These can vary considerably between borders and be changed at any time, so it’s vital you keep stringent, up to date records, especially when dealing with different export destinations. The US Department of Commerce has a web portal (Buy USA Gov) to assist US engineering companies and component engineering firms exporting EEE (electrical and electronic equipment) to Europe. A valuable resource, it has country-by-country information on RoHS/WEEE implementation, and issues regular news updates. The latest news concerns revisions to the RoHS directive, which took place on November 24, 2010. A key change was the extension of the directive to cover all electrical and electronic equipment, apart from that covered by exclusions, with a transitional period of 8 years. A 3-year impact assessment plan has been suggested with an 18-month period before the changes become legally binding, but the implications are obvious. We at Enventure Technologies have a number of enterprise data management solutions in the area of environmental compliance, covering ELV, GADSL, ROHS, WEEE and REACH regulations.
REACH EU and US Defense Exports – The Continuing Saga
ROHS, WEEE and REACH regulations may be European initiatives, but their influence is far-reaching. The EU is a major importer of products produced outside the European Union which come under its environmental compliance laws. These range from agricultural chemicals to FPGA designs. Here, we address the latest developments in REACH compliance as it applies to defence. REACH legislation governs the import and production of chemical substances within the EU. Certain products produced for the defence industry are exempt. However, exemption decisions were very much made on a national basis, and varied between member states. It became obvious to the EDA (European Defence Agency) that REACH compliance required a more harmonised approach. Creating a transparent, open European Defence Market aligning national exemption policies would considerably simplify matters for component manufacturers and other producers, not least those wishing to export into the European Union. In March 2010, the pMS (participating Member States) of the EDA agreed a Steering Board Decision which set common standards for REACH exemptions in the defence industry. A public web portal was also established to provide transparency over national policies and procedures. The PMS are now in the process of adopting the new international standards, which will be reviewed annually starting in 2011. In realisation of the fact that the REACH Regulation affects non-member countries of the EDA, such as the US and Canada, the Steering Board invited these “third member” states to adopt the new REACH legislation principles, further harmonising the process of supply. The Steering Board decision is a promising development in a controversial and confusing area. We at Enventure Technologies offer a number of solutions to help you cope with the complexities of ROHS, WEEE and REACH legislation.
The REACH directive and US defense exports
REACH legislation doesn’t just affect member states of the EU. Any mechanical, electrical or component engineering company exporting into Europe needs to be aware of the REACH directive as it relates to their particular area of expertise. This is especially true of defence engineering, which is subject to a number of policies and exceptions. These were recently overhauled. REACH, launched in 2007, is the acronym for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is one of several European initiatives tackling environmental compliance, providing a system for the registration and regulation of chemical substances. The aim is to encourage the substitution of dangerous or environmentally harmful chemicals for less damaging ones. Since the pre-registration period ended in 2008, production and importing of chemicals in the EU has been tightly regulated. By law, a full registration dossier stating the nature and intended use of each chemical must be submitted to the ECHA (European Chemicals Agency) by the chemical producer or importer. In addition, newly registered chemicals must be tested by the manufacturer and the results given to the ECHA for approval. REACH compliance applies to all areas of industry, including the defence sector. However Article 2, paragraph 3 allows certain substances to be exempt in the interests of defence. This can be a confusing area for many, especially companies outside the EU, but was clarified in March 2010 with the “Steering Board Decision on REACH – National Defence Exemptions”. We at Enventure Technologies offer a number of environmental compliance solutions specific to the REACH directive.
How do you keep customers happy with ROHS compliance?
Many customers are understandably worried when they hear that engineers are altering their customised hardware in accordance with ROHS compliance. Even if the hardware designs appear superficially unaltered, their components most definitely are not. ROHS compliance affects every area of PCB design, including transistors, semiconductors, diodes, solders and programmable chips. To maintain an uninterrupted supply chain, ensure continued integrity of their system designs, and continue to offer customers good value, engineering companies must have a watertight environmental compliance management system. This includes: Obsolescence management tools incorporating PCN alerts. Bill of Materials (BOM) management tools. Component cross referencing software for easy tracking of replacements for obsolete semiconductors. Effective enterprise data management tools, to maintain open paths of communication between end users and suppliers. One problem is the confusion and uncertainty over expiry dates for RoHS Category 8 and 9 products, which were given temporary exclusion from RoHS legislation. The original feasibility study suggested the exclusions remain in force until 2012 or 2018. However, this was never implemented by the EU, who in September 2010 substantially revised the list. Over half the exemptions now carry expiry dates of 2011 or earlier. This is particularly worrying for engineers who specialise in FPGA and VHDL designs for medical equipment. They can’t simply switch obsolete semiconductors for RoHS compliant ones. The product has to go through a series of approval tests first. In the meantime, what does the medical staff do? Believe it or not, there are solutions to all these problems. We at Enventure Technologies offer full manufacturing support in all areas of RoHS/WEEE compliance, from component engineering services to enterprise data management.
Categorically speaking, the RoHS isn’t complying with its own rules
When the ROHS WEEE directive first came into force, some mechanical designers were delighted to find their products were exempt from the ruling. However, the expiry dates for many of these exemptions has expired, and many more are due to expire in 2011. This is not the way it was originally going to be. Companies with well organised enterprise data management systems, using compatible part obsolescence management tools, will be aware of this. They will have amended their system designs to use alternative components, or found component engineering companies able to fashion RoHS compliant versions of components made obsolete by the RoHS ruling. However, a lot of others will be in the dark; they may not even realise their exempt products had an expiry date. In July 2006 the EU commissioned a study into the application of the RoHS directive to products in Categories 8 and 9. At the time, the final report stated products would remain exempt until 2012 or 2018 depending on specific criteria. However, the goalposts have not so much been moved as shifted to another playing field since then. Many exempt products were re-evaluated and as a result their exemption dates expired earlier this year. Many more are due to expire in 2011, and there are few if any products with an expiry date of 2018. We at Enventure Technologies will be the first to admit that that RoHS compliance is a confusing and complex area. This is why we specialise in environmental compliance management solutions for engineering companies such as yours. We offer a range of high value engineering services including obsolescence management, BOM management, component engineering and data cleansing solutions.
The ROHS directive Category 8 and 9 – where are we now?
There is still much confusion over the RoHS directive in mechanical engineering companies, especially with respect to the category 8 and 9 exemptions. These were hardware devices which: 1) Generally had a long lifespan and were manufactured in small amounts. 2) Were often used in mission-critical applications where their failure would have catastrophic effects. The reliability of lead-free components and solders was unknown (five years being the minimum period for risk assessment) and so these products were made exempt. The exemptions covered mainly the medical, military/defence, monitoring/recording and telecommunications fields. However, the exclusions were only temporary, lasting as long as it took for RoHS compliant alternatives to be quality assessed. Mechanical engineering companies must not get complacent just because they manufacture medical or aerospace equipment on the exclusion list. This list is constantly being reviewed, with products being deleted at regular intervals, either due to re-evaluation or because the expiry date has passed. The EU recently published an updated list of the exemptions that had either expired or been removed. They included: Lead in RIG (rare earth iron garnet) Faraday rotators of fibre optic communication systems. DecaBDE in polymeric applications. Lead solder in transducers of high-powered loudspeakers. Hexavalent chromium used in corrosion protection and Electromagnetic Interference Shielding of certain IT and telecommunications equipment. Cadmium optocoupler photoresistors used in professional audio equipment. Mercury as a cathode sputtering inhibitor in DC plasma displays. It is essential your obsolescence management is up to scratch in order to keep ahead of RoHS and REACH compliance issues. Luckily, we at Enventure technologies have obsolescence management tools and master data management services to keep you totally RoHS compliant.
Getting up to speed on ELV compliance
Automotive recycling was always a lucrative area for those in the trade. 75% of each car was easily turned into cash, with healthy returns on scrap metal, part-worn tyres and second-hand automotive components. However, the new ELV directive is calling for at least 85% of each vehicle to be recycled, which means recycling plastics, which isn’t traditionally a money spinner. Automotive plastic recycling is still in its infancy and, currently, there is no proven technology in common use. However, several mechanical design firms in the EU have come up with their own solutions, which they have sold on, so there is a profit there somewhere. In the Netherlands, the 85% minimum target has been met courtesy of impressive government subsidies. In countries where such funding is not forthcoming, such as the UK, firmware development and mechanical engineering companies are working to create affordable, compliant recycling solutions. ELV compliance is one of three EU rulings specific to the automotive industry. However, the ELV directive is the most expensive to implement. The days of the local scrap dealer making a sideline in second-hand auto parts is spent. Any company handling end-of-life vehicles today must be an Authorized Treatment Facility (ATF), investing in specialised plant machinery and with facilities for removing hazardous residues as per REACH regulations. The site must have a complex infrastructure to ensure it achieves the standards required for ATF licensing. If you are finding ELV compliance a problem, we at Enventure Technologies have master data management and cost reduction consultants to help you.
Recycling an end-of-life vehicle – more than just a metal cube
The complex new GADSL, ELV and REACH directives mean heavy work for vehicle dismantlers, or rather, Authorized Treatment Facility engineers. It goes a lot further than simply “cubing” a car that failed its MOT test. So, what is involved when a car reaches the end of its life, or in other words, becomes an ELV, or end-of-life vehicle? ATF plants have to dispose of all hazardous materials, and recycle at least 85% of the rest. The first thing to be removed is the battery, then the fluids; engine oil, fuel, hydraulic fluids, anti-freeze, and even the windscreen wash. Holes are drilled to facilitate this, with oils and fluids suctioned or drained into special containers. Recyclable components such as tyres are also removed. This all sounds familiar, but ELV, GADSL and REACH regulations mean extra care with hazardous components. Lead balancing weights, mercury-rich internal switches and trims containing hexavalent chromium must all be removed and disposed of in an environmentally compliant manner, such that they do not re-enter the supply chain as recycled goods. Other physically hazardous components, such as air bags and seat-belt pretension mechanisms, must be removed or made inactive. The car must be totally safe before being sent for further recycling. There, things become more complex, with a drive to recycle everything, from plastic fascias to fabric upholstery. ATFs invest large sums of money to reach ELV compliance. Mechanical engineers, FPGA design consultants and system development teams are working overtime to get novel recycling patents off the ground. We at Enventure Technologies can help, offering manufacturing support at every level.
Taking the initiative on ELV compliance
The most easily recyclable part of a motor vehicle is its metal component, but there’s a lot more to a modern car than that. Although scrap yards recycle as much as they can (tyres, useful engine components etc), a significant amount of the average ELV, or end-of-life vehicle still ends up in landfill sites. Much of this content contains substances, such as lead, which are hazardous to the environment and our health. For this reason, the ELV directive was introduced. The ELV directive was imposed by the EU to ensure a minimum level on vehicle recycling, and in a sustainable fashion. Introduced in 2000, and legally implemented in 2006, the ELV directive states that at least 80% of each ELV vehicle in the EU must be recovered for recycling, with a further 5% retrieved for use in energy-recovery processes. By 2015, these environmental compliance figures will rise to 85% and 10%. An ambitious plan, fraught with difficulty, the status report for November 2005 stated that although most member states were trying to achieve ELV compliance, the targets were far from being reached. A lot of the problem lay in the plastic component. Metal, fuel, tyres, fluids, batteries etc can all be recycled easily. However this still left a shortfall of around 5% to meet the EU target. At present, a number of mechanical engineering companies are working on systems to recover automotive plastics. We at Enventure Technologies offer a range of ELV compliance solutions, from master data management for recycling plants, to 3d modelling of novel hardware to furnish those plants.