With the recent recast of the EU’s Restriction on the use of certain Hazardous Substances (RoHS), as well as the 2010 Commission Decision (2010/571/EU) revising the exemptions, companies must take a second look at their product eco-compliance initiatives. The RoHS Recast, officially published in late May, it will go into force as early as January 2013, depending on the category of equipment.
Companies must now provide a technical compliance file (TCF) – which is likely the largest paperwork-burden on Industry since the the original publication of the RoHS Directive in 2006 . The TCF requires companies to show proof of compliance which has not been a requirement to date. To create the TCF, companies must gather information again from their supply chain to answer question of compliance.
In the coming months, more in-depth articles will assess the various changes in the RoHS Directive recast. Some of the major changes to be discussed are the inclusion of categories 8 and 9, using the CE mark and the requirement of a technical compliance file, as well as a dissemination of the updated exemptions and exemption process.
Have questions before the articles are published? Recommendations for parts of the Recast to cover? Email us at: alberieco@gmail.com.
Krista Crotty, founder Alberi EcoTech, a division of Wildest Dreams Enterprises LLC
