What is RoHS?

RoHS is the acronym for Restriction of Hazardous Substances and is also known as “Lead free” (though incorrectly). RoHS directive is a European Union Directive 2002/95/EC and is applicable in all EU countries. The prime purpose of this directive is to restrict the use of hazardous substances in electric and electronic equipments with an objective of promoting environment friendly mechanism of recovery and disposal of wastes from electrical and electronic equipments. This directive restricts the use of six hazardous substances found in electrical and electronic products. Under RoHS, all electrical and electronic products destined for sale in the EU market after July 1, 2006 must pass RoHS compliance, i.e., they must be free of six hazardous substances identified by the directive. RoHS directive does not apply to spare parts for the repair or reuse of EEE put on the market before 1^st Jul 2006.

Need For RoHS

Advancement in the electronics and associated segments since the invention of the first transistor in 1947 has been phenomenal. Today, we are surrounded by electronic gadgets which have become more or less the necessities of today’s lifestyle. Computers, TVs, embedded systems, etc. can be seen everywhere. In this phenomenal growth, one thing which has been neglected is the management of the wastes generated due to electrical and electronic equipments; the waste containing substances hazardous to human life.

E-waste is the term used for the electronic/electrical products which have completed their useful life. Management of these e-wastes has been a cause of concern around the world. The e-wastes contain lot of constituents harmful to human health. Lead used for soldering in printed circuit boards, glass panels and gaskets in computer monitors can cause damage to central and peripheral nervous systems, blood system and kidney. Chip resistors and semiconductor devices contain Cadmium which accumulates in kidney and liver and has toxic irreversible effects on human health. Relays and switches contain mercury which can contain chronic damage to the brain, respiratory and skin disorders. Cabling and computer housing contain plastics including PVC, the burning of which releases dioxin that can cause immune system damage and interfere with regulatory hormones. Plastic housing of electronic equipments and circuit boards contain Brominated flame retardants which disrupts endocrine system functions. Hexavalent chromium used for plating cause Asthmatic bronchitis and DNA damage. Improper disposal of these wastes can allow these hazardous substances to seep into air, soil and ground water causing acute problems to human life.

With an objective to counter the ill-effects of the e-wastes, several countries pressed upon the need to address the problems and challenges posed by hazardous electronic wastes. European Union issued a directive, known as RoHS – Restriction of Hazardous Substances to restrict the use of the substances in the electrical and electronic equipments. Following EU RoHS, other countries have also issued directives to handle management of the e-wastes.

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Force Behind RoHS

The driving force behind RoHS is the European WEEE Directive. WEEE is the acronym for Waste from Electrical and Electronic Equipment. WEEE is governed by European union Directive 2002/96/ EC which mandates the treatment , recovery and recycling of electric and electronic equipments. The prime purpose of this directive is to prevent the waste from electrical and electronic equipments and also to reduce the disposal of such wastes by re-use, recycling and other forms of recovery of electrical and electronic wastes. This directive requires producers of electrical and electronic equipment to assume responsibility for the recovery and recycling of their products.

WEEE has been enforced according to the article 175. Each country must develop a mechanism to collect the wastes from electrical and electronic equipments as defined by the WEEE directive. All electrical and electronic products launched in the EU market after August 13, 2006 must pass WEEE compliance and must carry the “Wheelie Bin” sticker. However, WEEE does not apply to those electrical and electronic equipments which are part of the equipments that do not fall within the scope of the directive.

RoHS and WEEE are inter-related because both the directives apply to the same type of equipments – electrical and electronics. RoHS directive restricts the use of certain hazardous substances upfront, right from the design stage while WEEE focuses on the collection, treatment, recovery and recycling of the wastes from electrical and electronic equipments.

RoHS OVERVIEW

· Focus of the Directive

The RoHS Directive is often incorrectly referred to as the movement toward “lead-free” electronic assemblies. While Lead is one of the six substances covered by RoHS, other five included are Cadmium, Mercury, Hexavalent Chromium, Polybrominated Biphenyls(PBBs), and PBDEs. The focus of the directive is to restrict the usage of these six substances.

· Restricted Substances & their permitted levels

Article 4.1 of RoHS directive has put the restriction on the permitted levels of the six substances in the products. For the purpose of RoHS regulations, a maximum concentration value of up to 0.1% by weight in homogeneous materials for Lead, Mercury, Hexavalent Cr, PBB, PBDE and up to 0.01% by weight in homogeneous materials for Cadmium will be permitted in the manufacture of Electrical and Electronic Equipment (EEE). It is also important to note that the presence of hazardous chemicals in packaging is also restricted.

All homogeneous (materials that cannot be disjoined by mechanical means) components within the product need to conform to the maximum concentration limits by July 1, 2006.

· Products Covered

The Annexure IA of WEEE Directive 2002/96/ EC cover a wide range of equipment falling into ten broad product categories and with a voltage of up to 1,000 volts AC and 1,500 volts DC.

Product categories listed in Annexure 1A of WEEE directive are

1. Large household appliances: refrigerators, washers, stoves, air conditioners

2. Small household appliances: vacuum cleaners, hair dryers, coffee makers, irons

3. Computing & communications equipment: computers, printers, copiers, phones

4. Consumer electronics: TVs, DVD players, stereos, video cameras

5. Lighting & equipment: lamps, lighting fixtures, light bulbs

6. Electrical & electronic tools: drills, saws, nail guns, sprayers, lathes, trimmers, blowers

7. Toys and sports equipment: videogames, electric trains, treadmills

8. Medical devices

9. Monitoring and control instruments

10. Automatic dispensers: vending machines, ATM machines

RoHS Directive 2002 / 95 / EC applies to electrical and electronic equipment falling under categories 1 to 7 and 10 listed in Annexure IA of the WEEE directive and to electric bulbs and luminaries in households.

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· Exceptions

Following products are exempted from RoHS compliance

1. Large stationary industrial tools (a machine or system consisting of a combination of equipment, systems or products, each of which is manufactured and intended to be

used only in fixed industrial applications).

2. Control and monitoring equipment

3. National security use and military equipment

4. Medical devices

5. Some light bulbs and some batteries

6. Spare parts for the repair of electrical and electronic equipment (EEE) put on the market before 1 July 006 and replacement parts designed to expand the capacity of and/or upgrade EEE placed on the market before 1 July 006.

7. The reuse of EEE placed on the market before 1 July 006.

8. Electrical and electronic equipment which is part of another type of equipment or system (e.g. a car radio).

· Who should comply

The directive applies to all products which are destined for sale in European markets irrespective of their place of manufacture. Any business that sells applicable electronic products, sub-assemblies or components directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilize any of the restricted materials.

RoHS affects all manufacturers of electrical and electronic products; only exceptions are the ones which are exempted from RoHS compliance as mentioned in previous section. Thus, it broadly affects manufacturers of IT/telecom, consumer equipments, electrical/ electronic tools, monitoring and control instruments, equipments for toys/leisure/ sports, etc. All the producers who want to market the products in European markets must comply with RoHS.

RoHS holds the end product manufacturer, rebrander, or importer (producers) responsible for product content. Since the burden of compliance lies with producers, they must direct the actions of component, PCB fabrication, assembly, materials, and other suppliers to ensure all contribute appropriately to end product compliance.

Since RoHS compliance cannot be achieved overnight, producers need to design new products ensuring RoHS compliance and also, they may need to modify design specifications of existing products and mandate alternative manufacturing processes for the components and subassemblies used in these products. For example, power supplies, housings and electrical/mechanical attachments, motors and drives, printed circuit boards, electronic components, displays, switches, sockets, connectors and wiring may contain banned or restricted substances and, therefore, may disqualify an end product for sale in Europe under RoHS.

· Obligations

RoHS place the following requirements on the producers

· Products placed on the market must not contain the hazardous substances above the maximum concentration values

· Producers must prepare documentation to demonstrate that their products are compliant before placing them on the market

· Documentation must be provided to the RoHS Enforcement Authority, on request

· Documentation must continue to be maintained for 4 years after the producer stops placing the product on the market.

· Non Compliance

Since RoHS directive prohibits the use of six substances in consumer products, the manufactures/ resellers /retailers must ensure that their products are RoHS compliant. If products are found non compliant with RoHS, legal actions are likely. Ignorance about RoHS or lack of knowledge pertaining to the presence of restricted substance in the product is certainly not the defense and cannot help the escape of the non-compliant producer. However, due diligence can.

Due diligence can act as a defense if non-compliant producer is able to demonstrate that all the actions to ensure the compliance of RoHS were taken. All the actions for RoHS compliance, preventive measures and the relevant documentation can prove in the court that he has exercised due diligence.

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RoHS GLOBALISATION

European Union implemented RoHS directive and put it into force on July 01, 2006. Soon after, other countries also formulated their own directive for e-waste management.

· China RoHS

China RoHS was put into force on March 1, 2007 and is officially known as “Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation”.

There are some similarities as well as differences when compared to EU RoHS

· Many product categories that are not included in EU RoHS are included in China RoHS. Automotive electronics, medical devices, semiconductor, packaging materials, etc.

· No exemptions are mentioned in the directive.

· Labeling requirements are quite extensive; it must include country of origin, names and contents of toxic and harmful substances contained in a product, a list of packaging material ingredients, “environmentally safe period” time frame – a type of shelf-life date that establishes how long a product can be used before it leaks harmful substances.

· Products and components imported into China will first stop at the port of entry and will be tested for compliance before entering. Products and components for re-exporting are not addressed.

· Directive will be reviewed annually.

· EU RoHS make only only importers, manufacturers and some retailers responsible for non-compliance; China RoHS make everyone in the supply chain responsible.

· US RoHS

It came into force on Jan 1, 2007. Permissible limits for restricted substances are same as defined in EU RoHS.

· Japan RoHS

Japan Directive JIS C 0950 came into force on July 1, 2006.

· Korean RoHS

Korea also implemented RoHS on January 1, 2008 and is also known as “The Act for Resource Recycling of Electrical/Electronic Products and Automobile”.

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RoHS TESTING

A number of certified laboratories offer RoHS compliance testing. These laboratories test products and packaging to find out the amounts of restricted substances. They provide details on the exact concentration of each banned substance present in the product or the packaging.

Some of the RoHS compatible test methods are GC-MS, GC-ECD, ICP-MS, ICP-OES, FTIR, and UV-vis. These methods are employed by these labs. Compliance testing is also performed using portable RoHS analyzers or XRF metal analyzers which can find out the amount of restricted substances in the products. Once a product is inspected by these labs and if a product complies with the RoHS directive, a certification is granted which can then be used by the producer as a proof of the product’s RoHS compliance.

SUBSTITUTES FOR RESTRICTED SUBSTANCES

· Lead is used as Pb-Sn Alloy for solders, Terminations, PCB coatings, component lead finishes, & cable (PVC). Pb-free soldering usingElectroplated tin, Electroless Nickel/Immersion Gold, Immersion Silver, Electrolytic Gold, Palladium/nickel are some of the options.

· Cadmium, when used as a sacrificial coating, does not corrode easily. It is also used in rechargeable batteries ( NiCd ), plastic stabilizers, electroplating coatings, metal coating, pigments, relays, etc. However, CdO is a cancer-causing agent. For electroplating, Aluminum Ion Vapour Deposition System, Zinc-Nickel alkaline plating, Zinc-Cobalt acidic plating,Tin-Nickel acid / near neutral bath, Tin-Zinc acidic bath are the options. For contacts in relays, Ag-SnO is a likely replacement. For Batteries, NiMH and Li-Ion are the options.

· Metallic Mercury is use in producing chlorine gas, caustic soda and in thermometer, dental fillings, and batteries. It is also used in thermal indicators, relays, sensors, fluorescent lamp, switches, sensors, etc. There are no viable replacements for Hg-fluorescent lamp yet. Sodium vapor lamps make all the objects yellow. Sulfur lamps match the sun light but are harmful because of presence of Sulphur.

· Hexavalent Chromium ( Cr⁶⁺ ) is used for pigments, catalysis, plating and tanning. It is also used for chromate treatment of screws, nuts, etc and as surface finish because of low coefficient of friction, High hardness, excellent corrosion resistance, high heat resistance and Anti-galling properties. For plating, techniques like electroless plating, Chemical vapor Deposition(CVD ) , surface hardening, thermal spraying, physical vapor deposition, organic polymer films, etc. may be used.

· Polybrominated Biphenyls (PBBs ) and Polybrominated Diphenyl Ethers ( PBDEs ) are commonly used in flame retardants ( FR ) in a variety of plastics. It is used in TV / Display Cabinets, PCB, Wire / cable insulation and connectors. Tetra-bromobisphenol A (TBBPA),Non-halogenated flame retardants, Zinc Borate (ZnBO₃), Antimony Oxide (Sb₂O₃) are possible alternatives

In short, no exact replacement is available. There is not yet much field data available for the new materials. In most cases, the alternative materials are costly and inferior in performance

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RoHS 2

Directive 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment (EEE) is referred to as RoHS 1 and the recast Directive 2011/65/EU is referred to as RoHS 2.

RoHS 2 entered into force on 21^st July 2011 and requires Member States to transpose the provisions into their respective national laws by 2nd January 2013. The RoHS 2 Directive is part of the European Union’s horizontal waste management legislation.

INDIAN SCENARIO

The problem of electronic waste management has much greater significance in India as India doesn’t have to deal with its own wastes but also dumping of e-waste particularly computer waste from the developed countries. Most of the developed countries dump their e-wastes in the developing countries.

Unlike in Europe where once a week the local municipality picks up the electronic waste, none of the global electronic brands have e-waste take back services in India. Mostly, consumers sell their e-wastes to local scrap dealers who dispose them unscientifically.

Though India has not issued any directive similar to RoHS, the Ministry of Environment and Forest (MoEF) has notified e-waste management rules for the first time in 2011. E-waste (management and handling) Rules, 2011 has put the onus of recycling and reducing e-waste in the country on the producers. The rules came into effect from May 1, 2012