В 2008 году Еврокомиссия пересмотрит 29 действующих в настоящее время исключений, освобождающих от выполнения требований ROHS и рассмотрит [[семь дополнительных запросов на освобождение]] [англ.]
ROHS is currently under a scheduled review, as Article 6 of the directive requires. The EC is examining the directive’s current 29 exemptions, plus an additional seven requested exemptions; categories 8 and 9 of the directive, which include effects of materials on medical devices and monitoring and control instruments; and some definitions within the directive.
The EC will review each of the 29 exemptions, and, if it deems they are no longer required because substitutes now exist, the commission will delete them, according to Gary Nevison, Newark’s customer interface on legislation that affects the electronics industry. «If the consultants doing this review find alternatives, but receive no input from manufacturers who cannot replace ROHS substances, the exemptions will be deleted. It’s important for all manufacturers who rely on the exemptions to submit the required technical data to the EC.»
Nevison maintains that, although the EC is reviewing all 29 exemptions, it isn’t certain that the commission will delete any. He notes lead in ceramics and lead in the glass of electronic components as examples. «In Europe, many passive components are compliant simply because they have that exemption.»
When the EU first laid out ROHS, it included eight of the 10 product categories in WEEE (waste electrical and electronic equipment), the EU recycling directive. However, it excluded two categories, 8 and 9, because of concern over the reliability of substituted materials, especially lead-free solders, according to an EC-commissioned report on the product categories. Health and safety risks are paramount in these categories, which influence products in the medical and health-care fields, as well as test equipment.
«The recommendation to the EC is that these two categories will be added to the scope of ROHS,» Nevison says. «This review is going to lead to further additional components, [and] a larger set of product categories. … The EC [will then look] at adding extra substances beyond the original six [lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ether].»
«Obviously, this [development] is very significant,» he continues, noting flame retardants; arsenic, which can be in infrared LEDs, some ICs, and alloys; and substances such as beryllium, which can be in springs, as possible additional substances.
Additionally, the EC is looking into clarifying some of the product definitions within the directive that have caused gray areas. Nevison cites «fixed installation,» a product that would be left behind because it is fixed or permanent, such as a boiler or an air-conditioning system. «It is possible that there will be no exemptions for fixed installations, so products that we felt didn’t fall within scope may well [be there],» he says.
The EC has finished the reviews of categories 8 and 9, and you can expect the organization to announce results this year. Recommendations for these product categories call for significant time for manufacturers to embrace products; expect a suggested 2012 time frame for implementation. As to adding more substances to the ROHS directive’s restrictions, clarity of definitions will likely come out this year, and implementation could be in the near future, depending on manufacturer feedback.
Unfortunately, says Nevison, once the electronics supply chain moves through this stage, there will be additional reviews of the directive and more restrictions coming from other environmental regulations, such as China ROHS, an EU ROHS-like law set in China; REACH (regulation on registration, evaluation, authorization, and restriction of chemicals), an EU chemical-restriction directive; and Energy Using Products, an EU framework directive on eco-design.
A December 2007 Ernst and Young report stated that regulatory and compliance risk was the greatest strategic challenge facing global businesses in 2008. A JPMorgan Global Trade Services research note in December likewise stated that manufacturers are lagging in environmental compliance.
«After a lull of a year or more on legislation, everything is just moving so quickly, especially in Europe with the REACH chemical legislation. [It] is going to have a huge impact on industry and, to a lesser extent, Energy Using Products, and that [movement] will have the biggest impact on the design engineer,» Nevison says. «An awful lot of the focus of these directives is on the design stage. There are so many things for an engineer and a distributor to think about now. Once there was just ROHS and some recycling, but now, all of a sudden, we have all of these other things and so many of them different.»