The Indian Electrical & Electronic Manufacturers’ Association organised a seminar to propagate the RoHS directive recently

The EU directive, RoHS (restriction of use of hazard-us substances in electrical and electronic equipment) has come into effect from 1 July 2006 and is of significant importance to Indian manufacturers and suppliers exporting finished goods or components to EU countries. The European Union adopted the RoHS 2002/95/EC directive in February 2003 and is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling, and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste (any broken or unwanted electrical or electronic appliance. It is a point of concern considering that many components of such equipment are considered toxic). The RoHS directive restricts the maximum concentrations of lead, mercury, cadmium, hexavalent chromium (also known as chromium VI or Cr6), polybrominated biphenyls and polybrominated diphenyl ethers in the manufacture of various types of electronic and electrical equipment.

Speaking at a seminar organised by IEEMA in Pune recently, Jonathan K W Lam, regional business development manager – APAC region restricted hazardous substances, Intertek Testing Services Hong Kong, said, “RoHS and WEEE directives aim at reducing the environmental impact of waste electrical and electronic equipment and protect human health and the environment by restricting the use of certain hazardous substances in the equipment.” He drew attention to the 10 categories of WEEE – large household appliances, small house-hold appliances, IT and telecommunications equipment, lighting equipment (except filament light bulbs and household luminaries), electrical and electronic tools (except large stationary industrial tools), certain toys, leisure and sport equipment, medical devices except where implanted or contaminated, and automatic dispensers.

hazardous chemicals used in electronic manu-facture, Lam said, “The WEEE directive covers all electrical and electronic equipment (EEE) designed to operate at a maximum voltage of 10000 volts AC-1500 V DC and placed on the market after 13 August 2005 and should contain the ‘Wheelie Bin’ symbol with a solid bar underneath according to the EN 50419: 2005.” He added, “The marking shall be accessible, durable, legible and indelible. The producer shall decide the location of the mark on the product. A fixed supply cord will have a flag. There will be instructions for use and a warranty certificate.”

“The RoHS directive is running in parallel with the WEEE directive and was transposed into national law by 13th August 2005,” said Lam. Com-pared to the 10 categories of WEEE, the 8 product categories of RoHS includes large household appliances, small household appliances, compu-ting and communications equipment, consumer electronics, lighting, power tools, toys and sport equipment and automatic dispensers. The products that are currently exempted from ROHS compliance are large stationary industrial tools, control and monitoring equipment, national security use and military equipment, medical devices, some light bulbs and some batteries, and spare parts for electronic equipment in the market before July 1, 2006.

Drawing attention towards homogenous materials, Lam put it: “A homogenous material is the one that cannot be mechanically disjointed into different materials. Homogenous, thus means,” said Lam, “material with uniform composition throughout like individual types of plastics, metals, glass, etc. Mechanically disjointed materials are those that can be in principle separated by mechanical means – by unscrewing, cutting, crushing, grinding and abrasive process.” Of the six hazardous materials, the maximum concentrations are 0.1 per cent for lead (Pb), 0.1 per cent for mercury (Hg), 0.01 per cent for cadmium (Cd), 0.1 per cent for hexavalent chromium (Cr6), 0.1 per cent for polybrominated biphenyls (PBB) and 0.1 per cent for poly-brominated diphenyl ethers (PBDE). PBB and PBDE are flame retardants used in some plastics. The limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically – for example, the sheath on a cable or the tinning on a component lead.

“A laptop could have up to 300 homogenous materials,” said Lam. “The printed circuit board has three homogenous materials – coatings (green, white, lacquer) on epoxy resin board, copper metal on epoxy resin board and epoxy resin board excluding coatings and copper metal.” Everything that can be identified as a different material must meet the limit. So, if it turns out that the case was made of plastic with 2300 PPM (0.23%) PBB used as a flame retardant, then the entire radio would fail the requirements of the directive. (Note that batteries are not included within the scope of RoHS; therefore, NiCd, Lead-acid and mercury batteries are permitted despite the use of restricted substances.)

While every OEM is required to certify that their products meet all regulatory requirements and do not exceed certain levels of hazardous substances, such as lead, mercury, cadmium, hexavalent chromium and certain types of brominated flame retardants, according to Lam, RoHS directive exempts certain electrical and electronic equipment that falls under the purview of ELV. ELV is End-of-Life Vehicle and directed towards the auto industry primarily. Automotive electronics are not under the scope of the WEEE and RoHS directives. It is covered by the ELV (End-of-Live Vehicles) directive 2000/53/EC, which is in force since September 2000.

WEEE does not apply to fixed industrial plant and tools. Compliance is the responsibility of the company, which puts the product on the market, as defined in the Directive; components and sub-assemblies are not responsible for product compliance. Of course, given the fact that the regulation is applied at the homo-geneous material level, data on substance concentrations needs to be transferred through the supply chain to the final producer.

RoHS applies to these products in the EU whether made within the EU or imported. Certain exemptions apply, and these are updated on occasion by the EU. There is also legislation in China (often referred to as “China RoHS”) that has similar restrictions. Unlike EU RoHS (products are included unless specifically excluded), there will be a list of products to which the regulations apply (products are excluded unless specifically included). There are some products that probably will be included for China RoHS, which are not in scope for EU RoHS – e.g., radar systems. However, the details of the requirements and list of included products have not been finalised by the Chinese government. The legislation is scheduled to take effect 1 March 2007. Japan does not have any direct legislation dealing with the RoHS substances, but its recycling laws have spurred the Japanese manufacturers to move to a lead-free process. These companies have also been proactive in phasing out other harmful materials, which will, in effect, make their products RoHS compliant.

Speaking about Intertek’s services to restricted substances (IS2RS), Lam said, “Intertek conducts testing services, has developed ISCAN and undertakes audit consulting services and product listing schemes.” The lab, which has a facility in Mumbai and is setting up another at Delhi to cater to the North Indian market, does chemical testing, XRF screening and FPP (finished package product) testing. Drawing attention towards the fact that most OEs insist on PoHS testing by a third party, Lam said, “Testing and other RoHS related services may turn out to be costly and it is therefore a good initiative to run it at the bottom of the chain where the raw material supplier conducts RoHS testing and follows the directive.” “This”, added Lam, “will help the OEM to compile a detailed and cost-effective documentation/certification on his equipment. ISCAN is Intertek supply chain assurance network and a web- based RoHS documentation monitoring system that helps build RoHS
compliance file on every single RoHS related product.”

While labs like Intertek extend their expertise to electrical and electronic equipment manufacturers, all over Europe, Asia and the US, the RoHS and WEEE directives are resulting in the majority of the production industry changing their processes to lead-free soldering and various other initiatives. This will also help to address compliance issues at the level of SMEs involving availability of compliant components and management of change within their existing business processes including stock management, bills of material, quality assurance, design and documentation. (Indian Electrical & Electronic Manufacturers’ Association. Tel: 022-24930532. Fax: 91-22-24932705. E-mail: mumbai@ ieema.org).