TV in the Jungle

RoHS

RoHSwell View, Green, GoRoHS, short for Restriction of Hazardous Substances, is a set of environmental directives from the European Commission (EC) to EU member countries. Drafts were prepared starting in 2002 and have been amended and updated several times since first publication. All EC directives are binding legal mandates requiring member countries to prepare corresponding legislation as described in each directive.

RoHS 1 Directive 2002/95/EC

RoHS 1 was first published on 27 January 2003 directing member nations to prepare and issue laws and regulations by 13 August 2004. The laws were to ban six specific substances from use in electronic and electrical equipment.

The banned substances were:

  • Lead, Pb
  • Cadmium, Cd
  • Hexavalent Chromium, Cr+6
  • Mercury, Hg
  • Polybrominated biphenyl, PBB
  • Polybrominated diphenyl ether, PBDE

Original RoHS 1 directive

RoHS 1 Amendment 2008/35/EC

This amendment gives the EC full authority to amend the annex (appendix) of the original RoHS 1 directive. The annex declared exemptions to RoHS compliance for particular applications of individual banned substances. The power to amend makes it easier for the EC to alter or remove exemptions as technology advances.

I have always maintained that operating business on the foundation of a RoHS exemption is risky and a terrible idea. This amendment increases the risk while adding some randomness to the exemption-based business plan. Compliance, fully and quickly, is always a better policy.

RoHS 1 Amendment

RoHS 2 Directive 2011/65/EU

RoHS 2 reiterates the precautionary principle, which is the foundation of the original RoHS. The gist of it is that it is better to be safe than sorry. The principle itself is a response to the voluminous examples of environmental and human safety abuses of commercial enterprises beginning with the industrial revolution. More recently, there is ample direct evidence of toxicity, teratogenicity and long-term negative health consequences of the use of all the banned substances in electronics and other applications.

The grander purpose of the directive is to lay down specific rules that must apply to member nation legislation. This was motivated by a broad range of implementations based on a variety of interpretations of the original RoHS 1 directive. The new rules seek to bring greater uniformity to the letter and intent of all the derivative laws.

There is very little change in the substance of the original. This directive simply expands the original in no uncertain terms so there can be little doubt as to the intent of the derived legislation.

RoHS 2 Directive

RoHSwell View Articles on RoHS Directive

Sources:
TV in the jungle, European Commission, Environment

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