RoHS: An update on this important Green Initiative

Abhishek Gupta, Cypress Semiconductor

March 05, 2012

Abhishek Gupta, Cypress SemiconductorMarch 05, 2012

In 2003, legislation was introduced in the EU to promote the collection, treatment, recycling, and recovery of waste from electrical and electronic equipment. This legislation is known as the ‘Waste Electrical and Electronic Equipment (WEEE) Act’ and is formally dictated by directive 2002/96/EC of the European Parliament.

A complimentary directive, the Restriction of Hazardous Substances (RoHS), was also introduced in 2003 given by 2002/95/EC of the European Parliament. Beginning July 1, 2006, RoHS legislation restricted the amounts of Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent Chromium (Cr6+), Polybrominated Diphenylethers (PBDEs), and Polybrominated Biphenyls (PBBs) in electronic and electrical equipment.

These chemicals are known to present a risk to human health and the environment. Each European Union member state will adopt its own enforcement and implementation policies using the directive as a guide.

Manufacturers outside the European Union may wonder what RoHS has to do with them; after all, it's a European directive. The reality is that RoHS principles are global. The directive indicates that anything covered by RoHS entering the European Union must be compliant, whether they include cables made in China, parts molded in the USA, or PCBs made in Japan.

If a product is eventually destined for the EU, it is impacted by RoHS. In addition, the EU is not the only global entity taking steps to reduce the toxins in electronic devices. California's Electronics Waste Recycling act of 2003, for example, echoes the RoHS directive and has been implemented since January 1, 2007. Japan, China, and Korea are also expected to follow with laws of their own:

Japan: A ministerial ordinance Japanese industrial standard for Marking of Specific Chemical Substances (J-MOSS), effective from July 1, 2006, directs that some electronic products exceeding a specified amount of the nominated toxic substances must carry a warning label.

South Korea: South Korea promulgated the Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles on April 2, 2007.

China: Final Measures for the Administration of the Control and Electronic Information Products (often referred to as China RoHS) has the stated intent to establish similar restrictions, but in fact takes a very different approach. Unlike EU RoHS, China RoHS does not give exemption to any type of product. Either the product is China RoHS compliant or is not a China RoHS Compliant.

Getting down to RoHS specifics
RoHS is often referred to as the lead-free directive, but it restricts the use of the following six substances:

1. Lead (Pb)
2. Mercury (Hg)
3. Cadmium (Cd)
4. Hexavalent chromium (Cr6+)
5. Polybrominated biphenyls (PBB)
6. Polybrominated diphenyl ether (PBDE)
(PBB and PBDE are flame retardants used in several plastics.)

The maximum permitted concentrations are 0.1% or 1000 ppm (except for cadmium, which is limited to 0.01% or 100 ppm) by weight of homogeneous materials. This means that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically—for example, the sheath on a cable or the tinning on a component lead.

In an effort to close RoHS loopholes, in May 2006 the European Commission was asked to review two then excluded product categories (monitoring and control equipment, and medical devices) for future inclusion in the list of products that must fall into RoHS compliance.

The directive applies to equipment as defined by a section of the WEEE directive. The following numeric categories apply:

1. Large household appliances.
2. Small household appliances.
3. IT & Telecommunications equipment (although infrastructure equipment is exempt in some countries)
4. Consumer equipment.
5. Lighting equipment—including light bulbs.
6. Electronic and electrical tools.
7. Toys, leisure, and sports equipment.
8. Medical devices (currently exempt)
9. Monitoring and control instruments (currently exempt)
10. Automatic dispensers.
11. Semiconductor devices

It does not apply to fixed industrial plant and tools. Compliance is the responsibility of the company that puts the product on the market, as defined in the directive; components and sub-assemblies are not responsible for product compliance. Of course, given the fact that the regulation is applied at the homogeneous material level, data on substance concentrations needs to be transferred through the supply chain to the final producer.

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