Essential updates on RoHS and REACH; an Electronics Yorkshire (EY) Seminar Mid Yorkshire Golf Club, Pontefract, Yorkshire, UK 20 November 2012

Citation

Goosey, M. (2013), "Essential updates on RoHS and REACH; an Electronics Yorkshire (EY) Seminar Mid Yorkshire Golf Club, Pontefract, Yorkshire, UK 20 November 2012", Soldering & Surface Mount Technology, Vol. 25 No. 2. https://doi.org/10.1108/ssmt.2013.21925baa.021

Essential updates on RoHS and REACH; an Electronics Yorkshire (EY) Seminar Mid Yorkshire Golf Club, Pontefract, Yorkshire, UK 20 November 2012

Article Type: Conferences and exhibitions From: Soldering & Surface Mount Technology, Volume 25, Issue 2

There are a number of pieces of European legislation that have global ramifications for the electronics industry. Two of these are the RoHS Directive and the REACH Regulations; both of which have had a major impact on electronics manufacturers, not only in Europe but across the world. Whilst this legislation has been in place for some time, RoHS and REACH are both still evolving. Electronics Yorkshire's “Essential Updates on RoHS and REACH” seminar was aimed at providing up to date information on these important pieces of legislation and the recent changes that have been implemented. The seminar was opened by Dr Leigh Holloway from Eco3 Environmental Consultancy who welcomed the attendees to the Mid Yorkshire Golf Club. Roger Gibbeson of Electronics Yorkshire then gave a brief overview of EY and the services and courses that it could offer around training, inspection and testing.

The first presentation of the seminar was from Gary Nevison, Head of Legislation and Compliance at Premier Farnell and his presentation was on “RoHS Recast and Beyond”. He began by giving a comparison of the differences between the original RoHS Directive and the new RoHS “Recast” version, outlining the deadline dates for the changes to be implemented. In addition to the inclusion of medical electronics, there would also be a new “Category 11” to cover many other types of products including wardrobe interior lights and heated clothing! There were also new definitions of equipment, which would mean more products were subject to the legislation. Cables would now be specifically included in the scope of the new directive. There was still a list of exemptions and this included military equipment, equipment designed to be sent into space and R&D equipment, etc. Non-compliant electrical and electronic equipment that was outside the scope of RoHS 1 could still be made available on the market until July 2019. However, the entire supply chain must be “cleansed” by July 2019. There would also be a RoHS 2.1 version and a planned review of restricted substances by July 2014. RoHS Recast applied to finished products and needed compliance with material restrictions, a CE mark, a declaration of conformity and a technical file. At this time, components were not directly in scope but obviously needed to be compliant if used in equipment that was to comply with the legislation. The current plethora of RoHS compliant symbols had to be replaced by the CE mark, although basic RoHS symbols were still allowed. All exemptions to the directive would expire after five years, unless there was an application for renewal. There had also been 34 new requests for exemptions, mainly from the medical sector. Manufacturers were now responsible for a single declaration covering all CE mark directives that applied to a product and this had to be to a format described in Decision 768/2008 and as also described in Annex VI of Recast 2011/65/EU. There were various voluntary standards that could be used, e.g. EN50581 and EN62474 and these were available from BS.

The second presentation of the seminar was given by Dr Leigh Holloway of Eco3 and this was on the REACH Regulations. He began by presenting an overview of the raft of EU legislation that included WEEE, RoHS, EuP and several other directives in addition to the REACH regulations. He also outlined the objectives of the regulations. The REACH regulations came into force in June 2007 and there were legal implications for manufacturers of products, which were the same across all European member states. It applied to substances, preparations and articles, but there were also a number of substances that were specifically excluded, such as waste, radioactive materials and non-isolated intermediates. He then gave definitions for what was impacted by REACH and also detailed substances of very high concern (SVHCs). There were currently 84 of these substances on the European Chemical Agency's list of SVHCs and it was important to know if these were present in the products that a company produced. There were various obligations under REACH for substances in articles and these varied depending on a company's activities. There may also be a need to register substances for use in specific applications. It was important to have a good understanding of what substances and preparations were present in articles and to know at what levels they were there. There were specific legal obligations if an article contained a SVHC from the candidate list in a concentration above 0.1 per cent by weight (in terms of the weight of the whole product). This obligation applied as soon as a substance appeared on the candidate list. Companies should be in a dialogue with their suppliers and seek to understand what chemicals were likely to be present in their products (Figure 1).

Figure 1 L to R: Leigh Holloway (Eco3) and Gary Nevison (Premier Farnell)

The final presentation was given by Professor Martin Goosey, Industrial Director of the UK's Innovative Electronics Manufacturing Research Centre (IeMRC), and he covered the impact of legislation on the electronics industry. He began by giving an overview of the IeMRC and the research work it supported for the benefit of the UK electronics industry. The focus then moved on to the RoHS Directive and the REACH Regulations and he covered the estimated costs of complying with these two pieces of legislation. These costs had undoubtedly been huge and were likely to have major global implications for manufacturers. Example data from various reports was shown. However, although these costs were a burden on manufacturers, the key question was whether there were any real benefits from compliance, bearing in mind that there was no option but to comply. The example of moving to lead-free electronics assembly and the use of brominated flame retardants in circuit boards was given. The transition to RoHS compliant lead-free assembly had resulted in a number of reliability issues that were still causing concern and a lot of on-going research. The examples of tin whiskers and conductive anodic filament formation were cited. The RoHS Directive had generated a lot of pressure for brominated flame retardants to be proscribed and this had resulted in PCB laminate suppliers now offering halogen-free laminates, even though the brominated flame retardants used in circuit board materials were not yet banned. Examples of the benefits possible from compliance were then presented and discussed. The European Commission had estimated that there were substantial health benefits occurring from the implementation of the REACH Regulations and the value of these could be valued at as high as 50 billion over the next few years. Martin concluded his presentation by giving examples of the research work the IeMRC was supporting on sustainable electronics manufacturing and which was aimed at benefitting the UK electronics industry (Figure 2).

Figure 2 L to R: Gray Nevison (Premier Farnell), Rogger Gibbeson (Electronics Yorkshire), Martin Goosey (IeMRC) and Leigh Holloway (Eco3)

The large number of questions that were asked by the audience about these two important pieces of legislation gave a good indication of the real level of concern that companies still had regarding compliance and Electronics Yorkshire are to be congratulated for organising this timely and apposite seminar. More information about Electronics Yorkshire can be found at: www.electronicsyorkshire.org.uk

Martin Goosey