Directive Decoder

Back in 2006 we can clearly remember the concerns around "Semiconductor Evaluation Boards" often referred to as "Development Tools".

Were they in scope of the RoHS Directive or not?

Certainly manufacturers hoped not, and many believed not. This eventually resulted in NWML, the UK enforcement agency, posting guidance on their website.

In October 2008 the European Chemicals Agency (ECHA) announced the first batch of so called Substances of Very High Concern (SVHC) under the REACH Regulations (Registration Evaluation Authorisation - and restriction of - Chemicals). REACH considers substances to be of high concern if they are, as a typical example, carcinogenic, mutagenic or toxic for reproduction. Also if they are persistent, liable to bioaccumulate and toxic.

The ECHA has announced legal obligations around the 15 substances that appeared on the first "Candidate List". Suppliers of articles (products) that contain substances in a concentration of above 0.1% by weight of the total article have to provide sufficient information to their customers to ensure safe use of the article.

As a minimum the supplier must advise the name of the substance and, where appropriate, provide a Safe Use Data Sheet.

Everyone in the supply chain needs to understand their obligations.

Click here for easy to follow guidance on Substances in Articles.

Directive Decoder

The proposed amendments to the RoHS (Restriction of Hazardous Substances) Directive will impact industry, but just how much?

While the implementation dates may seem a few years away industry needs to be aware of the potential impact.

While new product categories will not feature until 2014 and beyond, and the new directive enter into force until 2011-2012 allowing an 18 month period for Member State transposition, there are other elements that need consideration.

From June 2009 the Marketing and Use Directive (76/769/EEC) will become Annex XVII of the REACH Regulations.

The legislation, with its numerous amendments, imposes restrictions on hazardous substances.

Some are already banned in the European Union (EU), such as asbestos and polychlorinated biphenyls and, as a result, they cannot be sold or used. Others are restricted from use other than in certain applications. There are restrictions on certain materials that are used in toys and others, such as textiles that come into contact with the skin. Nickel cannot be used where significant skin contact occurs in applications such as jewellery and watch cases for example.

If you are involved with the REACH (Registration, Evaluation, Authorisation -and restriction- of Chemicals)Regulations you may well be involved in a supply chain, and be concerned about the ever increasing demands for information around articles.

As well as details around substances in articles, you might be asked to confirm what your company pre-registered and what your suppliers pre-registered. Downstream your customers may want you to complete detailed spreadsheets including concentrations of substances and even the horror, US born, document called IPC1752.

So what are your actual obligations?

The EC has commissioned a study into potential alternatives to DecaBDE.

DecaBDE exemption 9a was annulled, at the request of manufacturers, and deleted on 1^st July 2008.

However, each plastics manufacturer uses their chosen proprietary material so it is difficult to know what, in particular, is being used.

There are several alternatives but the choice will depend on the type of polymer. These include HBCDD, SCCP, TBBPA, various phosphorous based, and other flame retardants.

The study provides a list of 27 possible alternatives in Annex 3

EC study-DecaBDE

Directive Decoder

The UK is going to have to step on the gas to meet its collection targets for portable batteries. The New Battery Directive requires member states to collect 25% of portable batteries by 2012. The UK must step up collections from the current 900 tonnes to 7,500 tonnes per annum. The target rises to 45% in 2016.

Directive Decoder

The European Commission has published a report, by its technical consultants Oko Institute and Fraunhofer IZM, on 29 current RoHS exemptions.

21 exemptions will be continued, many with amended wording providing greater clarity, with proposed expiration dates between 2010 and 2014.

5 exemptions will be eliminated with transition periods until mid 2011. These are:

The European Chemicals Agency (ECHA), based in Finland, has published an updated list of pre-registered substances.

It contains around 143,000 substances that were pre-registered between June and December by some 65,000 companies.

The ECHA does not expect all of these to be registered.

The list consists of pre-registrations submitted by industry. In the ECHA's opinion the list contains many preparations and substances that did not require registration.

List of pre-registrations

Directive Decoder