On Friday 30th June, our fearless leader made a news post announcing that, for those who didn't know already, the RoHS directives would come into effect the following day. That day has come and gone, so now that we're into the month of July, perhaps it's time we asked what RoHS is really about and how it's going to affect us?
What is RoHS?
RoHS stands for 'Reduction of Hazardous Substances', or if you fancy the rohs.gov.uk's version; "The RoHS Directive stands for 'the restriction of the use of certain hazardous substances in electrical and electronic equipment'." Nice expansion of the acronym, there.
What the enforcement of RoHS means is that electrical and electronic equipment sold in the EU must have no more than maximum amounts of a list of substances considered harmful to the environment.
The substances in question are lead, mercury, cadmium, chromium VI, PBB and PBDE. These substances are used in a variety of ways in manufacturing. For example, lead has for many years been a key component in solder, which when mixed with the right amount of tin gives a relatively low (~190ºC) melting point. There are a number of techniques for soldering electronic and electrical components in manufacturing, but regardless of technique, a lower melting point is preferred, particularly for electronic equipment, where the heat required to solder a component could in fact damage it.
With RoHS, it's impossible to use this kind of lead/tin solder and comply with the regulations, so lead-free alternatives need to be used. However, these have higher melting points and behave differently, the end result being a greater risk of component damage and in some cases shorter product lifespans due to the degredation of solder joints.
Other uses for some of the 'big six' include improving fire resistance in products, and lead, mercury and cadmium are all used in batteries. However, it's here that we hit the first exemption; batteries don't count under the RoHS directive. So just what does need to comply, and what are the limits?
For any non-exempt electronic or electrical equipment, there's a maximum of 0.01% for cadmium, and 0.1% for the other five nasties. However, this isn't the overall amount of a product, or parts of it. Anything that is separable from the product must comply. So, if the circuit board is fine, the whole product might not be because of the packaging on a microprocessor, or even something seemingly trivial like the insulation on a cable.
Even if a part is in no way electronic or electrical, it might need to be RoHS compliant if the end product depends on it. Examples from rohs.gov.uk include dice in an electronic game and the carry case of a power tool. However, packaging that's thrown away after the purchase of a product (so boxes, plastic bags, etc.) don't count.
We've only really scratched the surface here. There are loads more exemptions and things to consider, but we'll stop there, because you get the idea. We're sure you can see that it's all a bit complicated and where there's complication, there's loopholes. That puts the whole RoHS directive at risk of being undermined and ineffective, costing money to enforce with no real benefit. Speaking of enforcement, how are they going to do that, anyway?
Here in the UK, the National Weights and Measures Laboratory (NWML) has been given the honour of setting up the body to enforce RoHS. Similar setups are being put in place in other EU countries. So now comes the problem of whether different enforcers will do things differently. How does a company show it's complying? What happens in they don't? One of the problems is that the RoHS directive isn't a law. Yet, sell non-compliant equipment and you're technically breaking the law. Surely that makes the grey area even greyer?
You might have seen on certain manufacturers' websites that they're now making RoHS compliant products. Hilariously, that might be China's version of the RoHS directive, which is different from ours. Now that could lead to more fun confusion.
Luckily for you and us, we don't have to worry about RoHS quite as much as manufacturers and retailers, but we are a bit concerned that certain products might start disappearing from shelves, or replacing components might become fun (there are more loopholes there though, you'll be pleased to know.) It seems our small quest to find out a few answers about RoHS and how it all works has simply lead(-free?) to even more questions, and a lot of concern.
Hopefully in the coming weeks things will get clearer and maybe as the directive is tested we'll see how it'll really shape up. Let's just hope it does actually do the environment some good.