As the European Commission (EC) announce details of their seventh consultation forum around the ECO design of Energy using Products (EuP) Directive (May 28th in Brussels) we take a look at their overview of this important directive. The emphasis is very much on the design stage of a product and, estimates a couple of years ago, anticipate potential energy savings of around 10% once Implementing Measures are in place.
China RoHS – Initial Products
According to contacts in China, it is still the intention to publish a restricted substances / products “Catalogue” before the end of the year that will contain a few selective products.
Two options are being considered. One is a few specific products such as personal computers, televisions etc. The other is to include materials (these are also classified under Electronic Information Products), for example – solder, where the restriction is for lead.
The second approach could have a more significant impact and could include products that are currently excluded from EU RoHS (such as aircraft) unless there are exemptions.
However, the first approach is the more likely option.
Directive Decoder
Polycyclic aromatic hydrocarbons (PAH) are a family of chemicals mainly derived from oil and coal but also as by-products from burning a variety of materials. Therefore the main environmental sources are from coke production, from petrol and diesel engine exhausts, from grilling meat and burning toast. Some PAH compounds, such as Benzopyrene are carcinogens, mutagens and reproductive toxins. Very few have direct uses although naphthalene was widely used at one time as mothballs and several are used as chemical intermediates to manufacture pigments.
The only restriction today of PAH is from the Marketing and Use Directive which bans the use of extender oil containing any of eight specified PAH in tyres.
Perfluorooctane Sulfonate (PFOS) was at one time manufactured in large quantities in the USA, mostly by 3M. It was a key ingredient in Scotchgard, a fabric protector made by 3M, and numerous stain repellents.
When 3M discovered its toxic properties, they ceased producing PFOS in 2001 with the result that it is now only used, via other sources, in applications where it is difficult to replace. Its uses included, adhesives, paper and fabrics including coatings mainly for textiles, carpets and leather. Apparently 48 tons per year was used in the UK at one time. It was used as it provided "soil, water and oil" resistance.
There have been many requests from manufacturers for RoHS “last time buy” exemptions. Such an exemption would allow manufacturers to use lead based components where no lead-free option is available. However, these are always refused as were the 9 such requests in the last batch of exemptions that the Oko Institut recently reviewed for the European Commission (EC).
The reason behind the constant refusal is based on the fact that alternatives could be used if the equipment was re-designed.
While the costs of re-design would be prohibitive, cost is one of the economic factors that neither the consultants, nor the EC, can take into account.
Directive Decoder
Regarding the withdrawal of exemption 9a in respect of deca-BDE.
I asked Dr. Paul Goodman of ERA Technology where it might be used.
"Deca-BDE is widely used including polypropylene mouldings, polyethylene cable insulation, PBT and PET - mainly in plastic connectors, Elastomers/rubbers and HIPS (enclosures).
Enclosures and connectors will be the most common uses but there will be others".
So a fairly wide impact on our industry.
Directive Decoder
As previously reported, the Oko Institut, based in Freiburg, has been conducting a comprehensive review on the scope of RoHS.
Here is the latest timetable of events:
o A period of consultation on potential restricted substances ended 28/3/08
o Oko will submit a draft final report to the European Commission (EC) by 18/4/08
o EC holding a stakeholder workshop in Brussels on 6/5/08. The results of this will be included in the final report
o Final report “due” mid June
o The original aims of the review included the clarification of such terms as “fixed installations” and “spare parts”. Whether or not they manage this remains to be seen.
o The EC will carry out an impact assessment to determine the likely benefit’s before any new legislation is adopted.
You may be wondering what has happened to the implementation of China RoHS.
As previously reported Phase 1, the labelling of Electronic Information Products came into force on 1/3/07.
However, the published date for Phase 2, the first products in the so called “China Catalogue” has slipped from late 2007 to the end of 2008 / early 2009.
A reminder of the key elements of the “Catalogue”:
Why use heat welding in preference to adhesives?
Some plastics melt fairly easily and so heat can be used to bond two pieces together. This is good because no other materials are introduced so that at end-of-life, there is only one clean plastic to recycle. If adhesives are used (also if labels are used), the plastic is contaminated and so has a much lower value. Removal of adhesives is practically impossible on a large scale.
Directive Decoder
Certain plasticisers are under review for possible inclusion within the scope of the RoHS Directive.
So what do they do?
Basically, plasticisers are used to soften plastics. Small amounts make the plastic more ductile and less brittle so they do not fracture if dropped.
Higher concentrations make the plastic flexible, hence their use in PVC wire insulation.
Directive Decoder
Thoughts on the recent decision made concerning deca-BDE (decabromodiphenyl ether) “in polymeric applications”. Here is some further background to the ruling.
The European Court has decided to annul this exemption in a case brought by the European Parliament and Denmark (supported by Portugal, Finland, Sweden and Norway) against the European Commission (supported by the UK).
The current exemption will apply until the 30th of June 2008. Therefore the exemption known as 9a ends on that date.
The European Court of Justice (ECJ) has ruled that flame retardant decabromodiphenyl ether (deca-BDE) will be “banned” from electrical and electronic equipment from the end of June.
The European Commission (EC) had originally granted an exemption for deca-BDE from the list of banned substances under the RoHS Directive.
However, in 2006 the European Parliament and Denmark, supported by other EU Member States, took the EC to court as they believed deca-BDE could be replaced with safer alternatives already on the market.
The European Union (EU) adopted the “Batteries Directive” (91/157/EC) in March 1991. This introduced restrictions on the use of mercury in most batteries and encouraged collection and recycling. However, the objectives of this Directive have not been achieved as most portable batteries are still being sent to landfill.
As a result, the EU has introduced a new directive (2006/66/EC) that will come into force on 26 September 2008, and repeal the existing directive on the same day.
For more information:
http://uk.farnell.com/images/en_UK/pdf/batteries_new_directive.pdf
Directive Decoder
The Oko Institut, based in Germany, and who is carrying out the review of additional RoHS substances for the European Commission (EC), has published a list of 46 substances, plus all brominated flame retardants, that are now subject to stakeholder consultation.
However, there is limited time to reply as their draft final report is due by the end of April. Before this time all technical issues need to be considered. At present, there is no appeals procedure expected against Oko’s recommendations.
Oko will also consider whether or not it is more appropriate to restrict substances under the REACH Regulations as REACH is based on risk assessment whereas RoHS is focussed on hazard. Both can restrict substances in equipment.
Designers continue to face problems with lead-free soldering, as well as safeguarding RoHS compliance. One well respected lead-free training house is still witnessing the following customer issues:
Major problems (as expected) with component stocks
o Segregation of stock (mixed up)
o Compliance - “change the label, no one will notice”
o Confirmation of compliance – “can the source be trusted?”
Production based issues
o Hidden stocks of lead based solder used in rework – “I will just keep this roll to do those odd jobs”
o Temperature profiles on wave and reflow – “this new stuff does not work on our (old ) profiles”
o PCB issues plating / finishes – there is a need to apply stock rotation and understand new metallurgy.
o Components melting – such as connectors
o Problems with the tip life when hand soldering
o Re-training of hand soldering skills and good soldering practice. Need to go back to basic soldering skills, i.e. leave tip well tinned when not in use, use correct size of tip. Use brass wire wipers with moderation.
To offer clarity over so called Substances of Very High Concern (SVHC) and when notification is required.
Notification of SVHC when present in articles: Article 7 of REACH details the criteria under which a SVHC would need to be notified to the European Chemicals Agency (ECHA) if it is present in an article (product). In summary, notification would be required if:
(a) the substance is present in those articles in quantities totalling over 1 tonne per producer or importer per year, and;
(b) the substance is present in those articles above a concentration of 0.1 % weight by weight (of article).
Norway has proposed to restrict 18 substances in anything intended for “consumers” or products that can reasonably be expected to be used by them.
This includes such as clothing, bags, toys etc but does not apply to food products, food packaging, medical equipment, fertilisers, tobacco as well as means of transport and associated products such as tyres.
A new Batteries Directive will come into force on September 26 this year.
The Directive will restrict the use of mercury and cadmium in batteries. The mercury restriction is unchanged from the 1991 Battery Directive but the cadmium restriction is new.
• Mercury in batteries except button cells: Maximum of 0.0005% mercury by weight of battery
• Mercury in button cells: Maximum of 2% mercury by weight of battery
• Cadmium in batteries: Maximum of 0.002% cadmium by weight of battery but
with three exemptions -
o Emergency and alarm systems including emergency lighting
o Medical equipment
o Cordless power tools (this exclusion will be reviewed by September 2010 and may be withdrawn)
Note that there is no restriction on lead in batteries but if present at > 0.004% by weight the battery must be labelled with “Pb”.
Directive Decoder
I have received one or two queries regarding PFOS recently.
Most Perfluorooctane Sulfonate (PFOS) was originally produced in the USA by 3M. It was a key ingredient in Scotchgard, a fabric protector made by 3M, and numerous stain repellents. When 3M discovered how toxic it was they stopped making it with the result that it is now only used, via other sources, in applications where it is difficult to replace.
A revised Battery Directive was adopted by the European Union (EU), and came into effect, on 6/9/2006.
Member States have two years to implement the new Battery Directive and, on the same date of 26/9/2008, the former Battery Directive will be repealed.
The former directive only applied to certain batteries containing mercury, cadmium and lead over certain permitted values. However, the new legislation applies to all batteries regardless of their weight, shape, composition or use, although limited exemptions will apply.
Subscribe to this blog's feed
Recent Comments