RoHS & REACH approach to substance restriction
The basis for RoHS and REACH substance restrictions are quite different. Restrictions in the original RoHS directive were based on hazards – if a substance is hazardous and there are alternatives, then it could be banned. REACH restrictions are introduced only if a risk to human health or the environment can be proven, it cannot be controlled and safer substitutes exist.
The original six RoHS restrictions were imposed without a full assessment of the impact of the possible alternatives even though some were not fully tested. It was enough to show that there is a potential risk without evidence of an actual risk. For example, lead is banned by RoHS but there is no evidence that its presence in electronics has, or is, harming human health or the environment (except at end-of-life where unsafe recycling is carried out). Also, the possible substitutes had not been identified when this restriction was imposed in 2002, and although less hazardous substitute solder alloys have since become available, their impact was not known until some years after the RoHS lead ban. The impact of lead solder substitutes is now known because the US EPA carried out a life cycle assessment which shows that neither lead solders nor lead-free solders are clear “winners” overall as they each have different properties and impact. Too late for the politicians I fear, but it would have been interesting if this data had been available in 2002.
REACH restrictions are based on lengthy risk assessments that consider research into the impact of the substance in its entire life cycle and also the possible alternatives. This also considers the control measures used by industry to minimise risk and social and economic issues. REACH restrictions are likely to be application specific where a risk is identified, although total bans are also possible.
The other main difference is that RoHS bans substances present in electrical and electronic equipment that fall within the scope of the 8 product categories (currently) of the directive. REACH affects all chemicals including those used to make the equipment (alloys, solvents, paints, etc.) and chemicals present in finished products of all types. There are very few exclusions and exemptions.
In Europe industry is starting to prefer the REACH approach and there increasingly appears to be a consensus by both industry, the EC and many politicians that this approach should be used for future RoHS restrictions once the recast enters force.