The RoHS Directive update has appeared in draft form with more substances, a link to CE Marking, clear documentation requirements, and legal responsibility for much of the supply chain.

There are four new substances.

Through a technicality, the draft does not actually ban the chemicals known as HBCDD, DEHP, DBP, and BBP but it proposes to ban them in the future.

"The good news is that TBBPA has been dropped off the list as it is used in 94% of circuit boards," said Dr Aidan Turnbull, RoHS specialist at environmental consultancy Environ.

There are two types of TBBPA, and the one in PCBs was not going to be banned. "With the removal of all TBBPA, there is no possibility of confusion," said Turnbull.

RoHS compliance will now be part of the CE marking process, which means there is no way to avoid raising a Declaration of Conformity in the hope no one will notice.

This move may also increase enforcement within the UK as Trading Standards police CE marking in the UK, and National Weights and Measures pursues RoHS violators.

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Defaulting EU countries will no longer be able to turn a blind eye to RoHS enforcement. "Obligations are much more clear on Member States to carry out surveillance of RoHS," said Turnbull.

The definition 'producer' has now gone, replaced by 'manufacturer', 'importer', and 'distributor'.

'Manufacturers' are now responsible for carrying out the technical assessment and for declaring conformity.

'Distributor' includes retailers and is any organisation in the supply chain which is not a manufacturer, importer, or consumer.

Distributors can no longer supply anything that they "consider or have reason to believe" to be non-compliant, which means they are now legally responsible for any RoHS-covered item that they sell.

"They at least need to receive the Declaration of Conformity, as without this they would 'have reason to believe'," said Turnbull.

See also: Electronics Weekly's WEEE Directive In Full Force, a roundup of content related to the Waste Electrical and Electronic Equipment regulations, and a RoHS special, on the European Directive regarding 'Restriction of Hazardous Substances'.