For over a year, the EU Commission has been reviewing the exemptions associated in the Restriction on the use of certain Hazardous Substances in electrical and electronic equipment Directive.
On 24 September 2010, the European Commission finalized and published in the Official Journal an update of all exemptions within the RoHS Directive.Two highlights of the update are (1) the splitting of exemptions and (2) the association of expiration dates with some exemptions.
There were no new exemptions, but the update did publish several exemption splits.The splitting of the exemptions provides industry with for more clarity on the exemptions; and further allows the Commission to place expiration dates on part(s) of the original exemption.This updated numbering scheme does require companies using exemptions to review their tracking system and determine if the further granularity of the exemptions requires an update to their tracking systems.Fortunately, the Commission is not removing expired exemptions and renumbering all the exemptions.Again, companies need to review their tracking systems and see if adjustments are necessary based on the splitting of exemptions.
In addition to the splitting of exemptions, some exemptions were assigned expiration dates.The exemptions with expiration dates already associated with them did not change.With the publication of expiration dates in the update, only about half have expiration dates (38 of the 77).Many of the expiration dates are associated with exemptions applicable to lighting.Fortunately, the exemption for use of lead solder in specific applications does not have an expiration date at this time.
The update publication of the exemption affects all levels of the supply chain within the electronics industry.It should be of concern for component manufacturers, EMS providers, and product manufacturers – anyone within the electronics industry already affected by the RoHS Directive.
RoHS Recast Vote
The exemption review has been independent of the EU Commission’s Recast of the directive.With the exemptions now updated and published, the Commission has shown there is agreement on the existing exemptions; and ultimately shows agreement is possible within the Commission. This is an indication for industry agreement is possible within the Commission.
The vote on the RoHS Recast date did slide from October to November, and may move again, depending on the Commission’s view of consensus. If there is no consensus prior to the scheduled vote, postponement until early 2011 is expected.
Krista Botsford, Botsford EcoTech Partners LLC can be contacted at firstname.lastname@example.org or by visiting www.BotsfordEcoTech.com.