[tinwhiskers] RoHS2 is coming - will it work better than RoHS?

From: "Bob Landman" <rlandman@xxxxxxxxxxxxxxxxx>
To: tinwhiskers@xxxxxxxxxxxxx
Date: Fri, 09 Jan 2009 12:43:10 -0500

Oh ohh...

Bob Landman
H&L Instruments,LLC

http://www.electronicsweekly.com/Articles/2009/01/08/45225/rohs2-is-coming-will-it-work-better-than-rohs.htm

RoHS2 is coming - will it work better than RoHS?

by Paul Chinery
Thursday 8 January 2009

Nearly two and a half years on from the introduction of the RoHS Directive, it
may be an appropriate time to examine how did we all do?

If the National Weights and Measures Laboratories (NWML) experience is
typical across Europe, then probably not very well. In the early days of
transition, they claim "99% of products are 99% compliant". Or, put another
way, only 1% of products complied fully.

A 2008 Impact Assessment by the European Commission reveals we still have a
long way to go, stating "Current Member States' checks revealed that up to 44%
of EEE
checked were not fully compliant."

That's a pretty poor return on what was a significant investment when one
considers that initial compliance is estimated to have cost industry $32bn,
with a further $3bn needed annually to maintain compliance, according to a
study by researcher Technology Forecasters Inc (TFI). The Commissions own
study puts the average overall cost related to RoHS at 1.9% of turnover.

In an attempt to reduce costs, resolve uncertainties and to increase market
surveillance and enforcement, the European Commission revealed plans to recast
the RoHS Directive in December 2008- effectively creating RoHS2. They state
the objective of the proposed reform is "... to develop a better regulatory
environment, one that is simple, understandable, effective and enforceable."

So, will we do any better second time around? Will RoHS2 really be simple,
understandable, effective and enforceable?

On first reading, the recast appears significantly larger than the original
RoHS Directive, running to some 46 pages compared to the original 5. In
reality, both are of a similar size when the introductory memorandum is
removed and one considers seven Commission Decisions have been integrated into
what will be (at least initially) one all
encompassing Directive, defining its own scope, definitions and exemptions.

So is this proposal simply a housekeeping exercise, removing the need for
various legislative 'add-ons' that co-exist alongside the current Directive?
Is it actually that
different from what we have today?

Whilst a lot of what is proposed has already been published in one form or
another, there are a few significant changes that will affect everyone that
currently falls within the scope, and most of those who are currently fall
outside the scope.

In terms of scope, RoHS2 now has its own, no longer relying on the annex of
its sister legislation, the WEEE Directive. However, its scope is, to all
intents and purposes,
identical to what we have today with the addition of medical devices and
monitoring and control instruments (category 8 & 9 equipment). This will be
disappointing to many, as one of the biggest challenges 'old' RoHS presented
was that of grey area products in relation to its scope. Does a 'widget' fall
within the scope or not?

At present, this recast is simply a proposal and isn't yet in force - the EU
Parliament and the Council must first formally agree its text before it enters
the Official Journal (OJ).

However, as this is a Commission proposal based on two (industry) stakeholder
consultations and several expert studies, it is highly likely it will be
adopted in its entirety.

So, will RoHS2 be simple, understandable and effective? That's for the global
electronics industry to decide during 2009.

Would these proposals be enforceable? Yes. Bear in mind, with the
introduction of compulsory CE marking for RoHS, another enforcement agency,
Trading Standards, is theoretically introduced. And, by having a visible
indicator for the first time, it would also be possible to exclude products at
a member state's border.

Paul Chinery is Principal RoHS Specialist at Agile Business Consultants, former
Managing Director of Distributor Dionics plc

[tinwhiskers] RoHS2 is coming - will it work better than RoHS?

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