Welcome RoHS in 2019 - Looking Ahead at an Increasingly Demanding Standard Presented by Joyce Costello Senior Regulatory Compliance Specialist
RoHS is evolving ● 2018 has seen a number of key RoHS-related developments ● 2019 will build on these and will require increased awareness and attention to RoHS ● EU the focus of current changes - EU RoHS is at a mature phase ● Sustained period of flux until 2021 at least ● RoHS indispensable in the EU quest to achieve a Circular Economy
Current Regime: RoHS Recast Directive 2011/65/EU EU RoHS Directive 2002/95/EC first enacted in February 2002 and in force February 2003 Forms part of a suite of EU ‘Single Market Directives’ ‘Vertical’ measure to regulate EEE sector specifically RoHS 2 in force since 2011 No distinction between EEE for consumer use and EEE for industrial and professional use
RoHS Substance Review
RoHS Substance Review - Overview February 2018 EU shortlists 7 substances for evaluation June 2018 Consultants leading the Pack 15 Project complete initial consultation June 2019 Assignment of Project tasks ends 2012 - 2014 Last assessment, resulting in enactment of Directive (EU) 2015/863 and the addition of 4 phthalates to Annex II
RoHS Substance Review - Consultations 2 Consultations so far Consultation No. 1: April 2018 Assessment of 7 substances for possible restriction Status: complete Consultation No. 2: October 2018 Draft methodology and RoHS substances inventory Status: ongoing
RoHS Substance Review - Substances under scrutiny ● Diantimony Trioxide flame retardant ● Tetrabromobisphenol A (TBBP-A) flame retardant ● Indium Phosphide used in semiconductor devices ● Chloroalkanes C14-17 (MCCPs) plasticiser in PVC ● Beryllium switch contacts, terminal conductors, integrated circuits ● Nickel sulphate and sulfamate nickel plating ● Cobalt dichloride and cobalt sulphate plating processes in surface treatment
RoHS Substance Review - Consultation outcomes 3 substances in particular causing concern: Beryllium, indium phosphide & diantimony trioxide - Beryllium: substitution often not possible - Indium phosphide: no alternatives - Diantimony trioxide: restriction unnecessary Methodology & inventory ongoing 2019: decision to be made on restrictions and relevant legislation drafted
Phthalates Restricted from 2019
Phthalates Restricted from 22 July 2019 ● Directive 2015/863 added 4 phthalates to Annex II ● DEHP, BBP, DBP and DIBP all capped at 0.1% ● Transition period ends 22 July 2019 ● Widely used and will affect a large portion of EEE industry using them in plastics ● Wires and cables, sealed radial bearings, soft rubber components, synthetic leather covers are typical high risk components
RoHS Open Scope
RoHS Open Scope 22 July 2019 all EEE in scope Restrictions for all EEE “dependent on electric current or electromagnetic fields for at least one intended function” Potentially endless list of products Categories will only be relevant for exemptions Test change: is my product covered by RoHS to is my product excluded or can I use an exemption?
RoHS Open Scope - where we are now?
EU Commission Evaluation
EU Commission Evaluation - July 2021 Article 24(2) “No later than 22 July 2021 the Commission shall carry out a general review of this Directive, and shall present a report to the European Parliament and the Council accompanied, if appropriate, by a legislative proposal” 14 September EU Commission initiates evaluation of RoHS, scheduled to be complete by July 2021 . Roadmap sets out Commission’s agenda for a comprehensive evaluation, will entail extensive consultation with both the public and interested stakeholders Designed to examine the performance of the RoHS Directive since its entry into force in 2011 Tentative dates: 12 week public consultation commencing Spring 2019 Stakeholder conference Q4 2019
Tackling Hazardous Substances Upstream
Tackling Hazardous Substances Upstream ● Core of Circular Economy in EU ● Increasingly demanding standard ● RoHS curbs practice of environmental burden shifting ● Gaining control of hazardous materials early in the product lifecycle
RoHS beyond the EU
RoHS arrives in Brazil ● First complete RoHS draft measure issued in 2018 ● Many failed attempts in the past to incorporate standard into regulatory framework of the region ● Largest Latin American market will be RoHS regulated ● Expressly draws on European model ● CONAMA (National Environmental Commission) to decide on formal draft
Implementation of China RoHS 2 - March 2019 Elements of China RoHS 2 - Administrative Measures Restriction v. control EEPs v. EIPs Labelling & information disclosure for all EEPs Substance restriction for catalogued EEPs - Product Catalogue 12 products listed - Conformity Assessment Process Undefined
Implementation of China RoHS 2 - March 2019 ● Substance restrictions from 12 March 2019 for selected EEPs ● Labelling and information disclosure still applies for all other EEPs ● Precise requirements of Conformity Assessment System (Article 18) yet to be described by the Government ● Very possible document will be released before year end
Thank You
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