Restriction of Hazardous Substances (RoHS) Directive

The European Union (EU) RoHS Directive significantly impacted the electronics industry with the required removal of four heavy metals and two flame retardants - lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE). All electronic products manufactured or sold in the EU must comply with the RoHS Directive. There are several exemptions for specific applications, however they all have an expiration date.

The list of restricted substances will be periodically reviewed and amended if necessary. The European Commission has officially notified the World Trade Organization (WTO) of four new substances that are to be added to the Annex II List of Restricted Substances under the RoHS-2 Directive. The four substances, which are normally used in plastics, are: Bis(2-ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), and Diisobutyl phthalate (DIBP). The proposed date of adoption for the restrictions is February/March 2015, but electrical and electronic equipment (EEE) manufacturers will have a few more years to prepare, as the transition period will end on July 22, 2019 for all EEE products except medical devices and monitoring and control instruments. The transition period for medical devices and monitoring and control instruments ends July 22, 2021.

IPC was instrumental in advocating for the revised Directive to be scientifically based. As a result, the Commission did not initially implement additional substance restrictions under the revised RoHS Directive. Further, subsequent restrictions are based on sound science and evaluate potential alternatives. IPC will remain engaged in the review process.

A number of exemptions will expire in 2016. Applications to renew these exemptions have been submitted to the EU Commission. The EU Commission summary table of exemptions applied for renewal is now publicly available at http://ec.europa.eu/environment/waste/rohs_eee/adaptation_en.htm and http://ec.europa.eu/environment/waste/rohs_eee/pdf/renewal_exemptions_oct14-jan15.pdf.

Exemptions Process (IPC Members only)

IPC, in conjunction with an international industry stakeholder group, worked to develop exemption extension applications for the following exemptions: 4(f), 6(a), 6(b), 6(c), 7(a), 7(c)-I, 7(c)-II, 7(c)-IV, 8(b), 13a, 13b, 15, 34, and 37. The complete, final applications and a presentation outlining next steps in the exemptions review process can be viewed by IPC Members only.

Under the the EU RoHS2, all existing exemptions  were set to expire by July 21, 2016. However, all exemptions for which industry submitted a renewal application will not expire until the EU Commission completes the current ongoing review of the applications, likely in late 2016 or early 2017. 

On June 27, 2015, Consultants to the EU Commission published their recommendations with regards to twenty-nine exemptions, including those listed above. 

IPC’s RoHS Exemptions workgroup and other industry members are deeply concerned that the recommendations, if implemented by the Commission, will have a significant negative impact on the industry.  Many of the recommendations provide for only a two year renewal years and reword the current exemptions in ways that will lead to increase in complexity and burden.

On July 19th, IPC and other members of the cross-industry Strategic Management Team (SMT) sent a letter to Mr. Daniel Calleja Crespo, Director-General for the Environment at the European Commission highlighting industry concerns. 

Industry

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