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RoHS Redux: What's Next?

If you thought European restrictions on hazardous substances in the manufacturing process were burdensome, wait until you get a look at what China may have in store for you.

Complying with Europe’s RoHS (Restriction of Hazardous Substances) regulations is more than just manufacturing products that meet certain standards. Almost daily, there are new standards coming onto the market from countries outside of the European Union, and some of these, especially China's, have far-reaching effects into a manufacturer's production line.

In short, to remain competitive, manufacturers have to make environmental considerations part of their business plan so they will not be shut out of lucrative markets as new regulations are added.

"'Right now, the manufacturing community needs a forum to work towards the harmonization of regulations throughout the world and even within the U.S. or there will be chaos," warned Robert Pfahl, vice president of iNEMI, (International Electronics Manufacturing Initiative), a consortium of electronics manufacturing organizations.

Currently, several trade organizations are working with various global governments to push for one set of regulations. If some type of harmonization of standards cannot be achieved, the result will be a chaotic set of rules that no one will be able to follow successfully, Pfahl predicts.

In the U.S. it would be more desirable if the government agreed to one set of requirements, or a more stringent set of requirements. For now, several individual states are using California's environmental standards as a guideline for their own laws, but having to meet individual requirements for 50 states would not be productive, Pfahl noted.

"For U.S. manufacturers to keep ahead of environmental regulations, they must become more proactive in evaluating alternatives and paying attention to environmental concerns," he said.

There needs to be better evaluation of the tradeoffs in alternative technologies versus existing technologies, for instance. If certain materials and components cannot be used in the manufacture of a product, then alternatives need to be found. Of course, that's sometimes easier said than done.

"Finding alternative materials is a complex process," Pfahl said. "It can take a long period of time to find an alternative material, and then test it to make sure the product is still viable."

As an example, Pfahl describes the activity surrounding the search for an alternative to lead soldering, as RoHS and other directives require lead-free soldering in product manufacturing. (Because an equivalent manufacturing process has not been developed yet, there are exceptions allowed to the regulations.)

"When you are developing alternative materials, there are many factors that must be taken into consideration," Pfahl said, "such as risk of failures, environmental concerns, and end-of-life impact. In some cases, the question could be: 'Is the cost of finding an alternative worth the environmental risk'?"

Guaranteeing product life is another area of concern for manufacturers when substituting alternative materials for known materials.

"We know that lead terminations have a long life and have worked well in product assembly," noted Jeff Shafer, senior vice-president of Newark InOne, a distributor of electronic and component test equipment. "Although alternative materials are now being used, there is no track record for performance, and that makes it harder for manufacturers to predict the lifespan of a product."

As for the harmonization of regulations, it’s not just manufacturers that are looking for simplicity but their suppliers, too. This, coupled with customers who are looking for more environmentally conscious products, puts a lot of responsibility on the shoulders of the manufacturer, and takes the environmental impact of products beyond RoHS requirements.

"These RoHS regulations came up fast, and will continue to crop up in other areas around the world, such as in Korea and China," commented Pfahl. "The smarter manufacturers will not be caught off guard if they have been proactive in addressing environmental issues."

And the China RoHS regulations are just around the corner – March 1, 2007, to be exact. The important thing to remember is that the China RoHS regulations are not just Chinese versions of the EU regulations – there are significant differences.

The EU RoHS regulations cover the final production of a product and are self-declarative. A manufacturer can self-declare that a product meets EU RoHS regulations – stating that the product has compliant components, was manufactured according to compliant procedures, and was tested before the product was packaged and shipped. The EU does not test products to validate their compliance.

"But this will not be enough to meet China RoHS regulations," cautions Shafer. "The Chinese regulations require compliance for the entire product, all components and packaging. Labels must be adhered to the outside of the packaging delineating the contents, and China will not accept a self-declaration from a manufacturer."

Rather, China will test products as they arrive in the country and before the products can be sold on the market. "They have set up 18 test houses that will break down a product, test it for compliance, and keep this information in a database," Shafer explained. "I'm not even sure if some U.S. manufacturers understand the extent of China's aggressiveness in moving forward with environmental standards."

Meeting these new China RoHS regulations can change how a manufacturer looks at its whole supply chain and manufacturing process. Will manufacturers produce two types of products or packaging - one for the EU and one for China? Can a manufacturer afford not to ship to China? And conversely, will China find fewer products on its shelves if manufacturers cannot comply with the regulations?

"There just aren't any definitive answers yet," said Shafter. "And we're not even really sure how China will enforce the RoHS regulations, but certainly U.S. manufacturers need to look at their entire supply chain, including suppliers and distributors, and start moving forward on how they plan to meet these restrictions."

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