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ElectroIQ
By Lev Shapiro, Component Master Ltd.
The European Commission (EC) proposes several changes to its RoHS Directive. Medical devices and other exempted end products will be affected, product labeling will change, and the character of the RoHS legislation will be reinvented. However, calling this revision "RoHS2" is a misstep, based on the informal but generally accepted RoHS5/6 terminology.
On December 3rd, 2008, the Commission of the European Communities issued the proposed revision of the original RoHS Directive. The objective of proposed reforms is to develop "a better regulatory environment, one that is simple, understandable, effective and enforceable".
The major changes that are in these proposed amendments include:
1. Categories 8 (medical devices) and 9 (monitoring and control instruments) of WEEE will be included in the scope of RoHS Directive in a stage manner commencing 2014 through to 2017.
ElectroIQ
By Lev Shapiro, Component Master Ltd.
The European Commission (EC) proposes several changes to its RoHS Directive. Medical devices and other exempted end products will be affected, product labeling will change, and the character of the RoHS legislation will be reinvented. However, calling this revision "RoHS2" is a misstep, based on the informal but generally accepted RoHS5/6 terminology.
On December 3rd, 2008, the Commission of the European Communities issued the proposed revision of the original RoHS Directive. The objective of proposed reforms is to develop "a better regulatory environment, one that is simple, understandable, effective and enforceable".
The major changes that are in these proposed amendments include:
1. Categories 8 (medical devices) and 9 (monitoring and control instruments) of WEEE will be included in the scope of RoHS Directive in a stage manner commencing 2014 through to 2017.
2. Exemptions will be granted for a maximum validity period of four years (currently exemptions are granted with no expiration date).
3. It is provided a binding list of products for each category of equipment covered by RoHS.
4. For demonstration of compliance, products must have an EC declaration of conformity from the manufacturer and they must bear the CE mark.
5. The term "producer" is replaced with "manufacturer," distributor," "importer," or "authorized representative" — to be collectively known as "economic operators."
6. The list of banned substances is not changed; however, four substances are identified for priority assessment in view of a possible future inclusion in the list of banned substances.
In official European Commission documents, there is no concrete and definite name for this proposal; however, in many articles and publications, the revised RoHS Directive is already called RoHS2.
An erroneous name like RoHS 2 may seriously mislead the electronics industry and generate wrong interpretations. For example, the terms RoHS5 and RoHS6 became popular a few years ago. These terms are related to existing exemptions of RoHS (section 7 of the Annex), "... lead in solders for servers, storage and storage array systems, network infrastructure for switching, signaling, transmission as well as network management for telecommunications ..." According to this exemption, the products of exempted industries may use components and materials containing lead (Pb) on second level interconnect (components-to-PCB connections). For these products, only 5 of the 6 restricted substances are described as within the scope of RoHS. Lead is exempted. In other words, RoHS5-compliant parts do contain lead >1000 ppm, but meet the concentration limits for the other five hazardous substances. Such leaded components and applications are called RoHS5, in comparison with RoHS6, which reflects a full RoHS compliance.
The terms RoHS5 and RoHS6 are slang abbreviations that have not been formally adopted by the EU Commission. They are not defined either in the RoHS documents or in any standards related to lead-free technology. Despite this, today they are wide-spread definitions. In a Google search, about 20,000,000 references are found for RoHS5 (RoHS-5 or RoHS 5/6).
Intel and many other semiconductor manufacturers, together with manufacturers of passive and electro-mechanical components, offer the ROHS5 compliance certificates and sometimes even define the RoHS 5 (RoHS 5/6) components in their data sheets. Under these circumstances and this terminology history, the name RoHS 2 for new RoHS proposal will be erroneously perceived by many users. Based on the analogy of RoHS5, some may conceive of RoHS2 as a vague "two substance" restriction.
The European Commission must define a correct name for the revised RoHS Directive and avoid the doubtful name that is exposed to wrong interpretations. Otherwise, the main objective for proposed revisions to make RoHS legislation more "simple" and "understandable" will be not achieved.
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Lev Shapiro, Lev Shapiro, M.Sc. E.E., may be contacted at Component Master Ltd., Tel Aviv, Israel, lev@compmaster.co.il. Read his recent article for SMT, Avoiding Counterfeit Electronics: The Role of Component Manufacturers, OEMs, and CEMs.
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