RoHS Is Here - And Manufacturers Aren't Ready

Many manufacturers are not ready to demonstrate RoHS (Restriction of Hazardous Substance) compliance or due diligence, based on their documentation management capabilities, according to the RoHS Readiness Survey released Monday by Arena Solutions, a provider of on-demand product lifecycle management systems.

According to survey results, 83 percent of respondents were at severe to high risk of not being able to track, document and report on RoHS compliance.

While the study found that a majority of respondents had implemented a RoHS transition plan, 69 percent indicated that they did not have a centralized compliance management solution in place that was accessible to employees and suppliers.

Current regulations require a complete compliance record – from certificates of compliance to supplier audit reports and component risk evaluation procedures – to demonstrate due diligence, and that the record be kept for four years after the product has been put on the market.

Having a reliable compliance management system in place is critical to ensuring a company can instantly produce a complete and accurate compliance report, and to facilitate ‘design for compliance’ for new products. A simple spreadsheet with “check marks” is not sufficient evidence.

The research also indicated that:

          • 59 percent of respondents do not have a good understanding of the regulations or how to demonstrate compliance and due diligence;

          • 60 percent of respondents are not confident that they track all parts and materials in their products, have a complete compliance record associated, and can verify compliance independently of any regulatory requirement;

          • 65 percent of respondents would not be able to confidently report compliance based on a complete and accurate product compliance record; 

          • 73 percent of respondents agree that they do not have sufficient controls and documentation around change management, compliance verification of incoming parts, and a closed-loop process for non-conforming materials; and

          • 63 percent of respondents recognize that their current solution to track compliance will not scale for multiple regulations, and compliance for history revisions is not well kept.

“Converting products to become RoHS compliant before the July 1st deadline is only half the battle,” said Michael Topolovac, CEO of Arena Solutions. “Manufacturers need to be prepared to report and ‘live’ with compliance, meaning they need to have a robust compliance management solution in place that allows them to track, document, and report compliance as well as demonstrate due diligence when required.”

The European RoHS Directive, which went into effect on July 1, 2006, stipulates that six substances - lead, cadmium, mercury, hexavalent chromium, PBB (polybrominated biphenyls), and PBDE (polybrominated diphenyl ethers) - are no longer allowed to be used in products manufactured or sold in the European Union.

The EU RoHS regulation is the first environmental regulation manufacturers must comply with as the global market transitions to more responsible manufacturing practices. Similar environmental regulations, including China RoHS, Korea RoHS and the California directive for RoHS, are the next wave in the ongoing stream of new compliance mandates being imposed around the world.

“RoHS is just the tip of the iceberg when it comes to new environmental regulations,” said Topolovac.  “As the world becomes more aware of the environmental hazards of product manufacturing, more regulations will be forthcoming, requiring compliance management to be an inherent part of product development moving forward.”

To assess your own compliance risk level, go to www.arenasolutions.com/rohssurvey to access the free survey.