Directive Decoder

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

They concluded that "most evaluation boards are included under category 3 - IT equipment".

That provided clarity, but in some other countries such as Germany, the debate has run and run, and today is in chaos. Hundred's of cases are waiting to go to court while, in the meantime, there is no such concern in other Member States.

While an IT or data transfer function immediately places the evaluation board in category 3, what if there is no such function and the kit does not fit any of the other categories?

With the publication of the so called "RoHS2" proposals the subject is again on the agenda.

Here are some simple guidelines:

§         RoHS2 does not impact any current inventory of development tools.

§         Any evaluation boards that are in scope at present should not contain the current six RoHS substances except where exemptions apply.

§         Future substance restrictions will only apply to products put on the market (POTM) after the date that will need to be specified by the European Commission (EC).

§         The process for restricting additional substances could take several years and will follow on from the implementation of the "revised" RoHS Directive. At present it is not known how long this will take. The EC should allow a transition period after the decision to restrict an additional substance has been agreed and published. New POTM dates applicable to additional substance restrictions are unlikely to be before 2012 and could be much later.

§         Evaluation boards may contain some of the phthalates BBP, DBP and DEHP for example in PVC wire, sealants, inks, adhesives and lacquers.

In summary, there is no need to worry about current inventory, and those POTM before 1/7/06 are out of scope anyway. However, if the 4 proposed substances do fall within scope then manufacturers will need to start looking for alternatives in future products.

In any event, manufacturers should be ensuring that finished equipment such as emulators and the small, open PCBs that provide a prototyping area and often offer a basic programming facility, comply with the directive.

Today it is hit and miss with one major US manufacturer still supplying nothing else but non-compliant boards, and many products in circulation that do not indicate one way or the other. It is down to the manufacturers to sort this issue out once and for all and put a stop to the chaos in Germany and the likes.

Directive Decoder