Firms on Track to Meet RoHS Rules

Jul 11, 2006 Ι Industry In-Focus Ι Electronics and Computers Ι By Ben, CENS
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Electric and electronic products exported to the EU have to comply with RoHS by July 1 this year

Beginning from July 1 this year, the European Union (EU) will enact a directive governing the restriction of hazardous substances (RoHS) in products sold in the EU. This will have an especially strong impact on electrical and electronic equipment, such as notebook computers, mobile phones, and a host of other gadgets and appliances.

The RoHS regulations are especially significant for Taiwan as many of these products or components for these products are manufactured on the island. According to statistics compiled by the Ministry of Economic Affairs (MOEA), most of the companies here that will be affected seem to have got the message.

Lin Fenn-yeu, a researcher of the MOEA's Industrial Development Bureau (IDB) says, "We are confident that 90% of Taiwan's firms in the manufacturing sector will be RoHS compliant by July 1."

The most recent figures available from the MOEA put the annual value of electrical and electronic goods exported from Taiwan to EU community at NT$244 billion (US$7.5 billion at US$1:NT$32.5). If Lin's 90%-compliance figure is correct, that means 10% of Taiwan's exported electrical and electronic goods, amounting to NT$24.4 billion (US$750.7 million), will be effectively shut out from the EU marketplace. This figure becomes even more disturbing when mainland China, Japan, South Korea and a number of American states are also introducing similar legislation.

No one doubts that the RoHS regulations are necessary. Its purpose is to protect human health and the environment. This legislation is an addition to the EU's Waste Electrical and Electronic Equipment (WEEE) directive which was introduced in 2002. The effectiveness of the WEEE regulations is heavily dependent on a country's government establishing a sound infrastructure for the collection and recycling of waste materials. This is taking some time to fully implement. Meanwhile concerns over health and the environment are growing.

A Step Towards Earth- and Health-friendly Electronics
Intertek is an international leader in testing, inspection and certification of products and commodities, with 294 laboratories in 102 countries, including Taiwan. The company has been very active in helping Taiwan businesses comply with RoHS.

Intertek Taiwan's chief operation officer Paul K.H. Yao, speaking on the necessity of the RoHS directive, says, "An increasing amount of electronic waste and a tremendous quantity of heavy metals and hazardous materials are being dumped without proper environmental controls. Tests carried out at dumping sites found very high levels of toxicity. This implies that a horrific amount of hazardous materials are getting into the drinking water and the soil in which we grow our crops."

The RoHS directive bypasses some of the implementation difficulties of the WEEE regulation by reducing the offending substances at the manufacturing process rather than having to deal with them later at the waste stage.

The six substances which are restricted by the RoHS directives are lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs). The list of products singled out for scrutiny under the RoHS directive are as follows: large and small household appliances, information-technology and telecommunications equipment, consumer equipment, lighting equipment, electrical and electronic tools, toys, leisure and sports equipment and automatic dispensers.

According to a government guidance issued by the United Kingdom's Department of Trade and Industry (DTI), certain appliances such as large-scale stationary industrial tools are exempt from the RoHS regulations. There is also an exemption for spare parts used in the repair of equipment placed on the market before July 1. The legislation also does not apply to the re-use of equipment placed on the market before the commencing date of the RoHS legislation.

Hurdles
The regulations in the EU directive are very clearly defined, but what happens if the specifications concerning the limits on hazardous materials differ from country to country: Is it possible that a product may be deemed RoHS compliant in one country but not in another:

Intertek Taiwan's Yao replies, "A company can get around these problems by ensuring, through testing and compliance management, that its products meet the very strict test of the RoHS regulations."

The problems seem not to be so much with reaching agreement on which substances need restricting and the limits that need placing on them. "The real problem is that there is still no internationally standardized method for testing and sampling products," Yao says.

Yao went on to describe the complexities involved in establishing international testing methods. There is a question over how you determine toxicology. Do you test a product as a whole or break it down into its various components? Do you cut or grind a component up? Do you dissolve it in chemicals and in that case which chemicals do you use? There is also a question concerning the stage at which a product should be tested as different components come from different parts of the world. So should it be tested in the manufacturing country or the importing countries? Non-compliance can come down to a minor detail like the plating used on a tiny screw. How do you separate the plating from the screw?

Yao says, "These factors cannot be used by companies to escape compliance. What you have to do is find the best way to comply and trust that in time a common processing standard will be established."

Complying with the RoHS regulations can be expensive, adding an estimated 20% to the cost of raw materials, notes Yao, "What the manufacturers have to do is to weigh these costs against the consequences of being found non-compliant by the trading standards agencies. For instance, when the Sony Corporation of Japan was forced to recall 3.5 million faulty power adapters for its PlayStation 2 (PS2) game consoles it was fined 17 million Euros (approximately US$22 million)." Yao refers to the companies that might think that getting compliant is not worth the time, money and effort involved. "At the very least they would be putting themselves at a great disadvantage. At worst they would be putting themselves out of business. They simply won't be able to exist."
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