12/8/2011 12:30:00 AM
HEADLINES
RoHS Implications Expanding Beyond Electronics Sector
Jenni Morland
The European Parliament and Council earlier this year revised the Restriction on Hazardous Substances (RoHS) Directive.
The RoHS 2 Directive – officially 2011/65/EU – extends beyond the electronics sector.
The original RoHS – adopted in 2003 and effective in 2006 – banned or restricted six hazardous substances in electrical equipment: lead, mercury, cadmium, hexavalent chromium, PBB and PBDE.
RoHS 2 extends beyond the original electronic products such as televisions, computers, washing machines and other household goods.The new Directive expands RoHS to any product using an electric current. Thus the electronic motor of a previously exempt reclining chair, now must be in compliance. This means distributors need to be aware that fasteners sold to what previously was seen as non-electronic products may now have to comply.
RoHS 2 extends not just the material, but the processes through the finished product.
Jenni Morland, European business process manager at TR Fastenings, wrote in Fastener+Fixing that fastener manufacturers and distributors “now need to consider in detail whether the legislation affects them and whether their processes are RoHS compliant.
“RoHS 2 also includes measures to ensure more effective policing. Required technical documents include an assessment of compliance and risk of non-compliance. Details could include information on contamination of trace chemicals during the manufacturing processes or mixing of compliant and non-compliant.
Documentation can include a product description, materials and test reports.
“Ultimately, if an OEM cannot prove that every component that makes up a product and the processes used to make it adhere to the directive that manufacturer will not gain a CE marking for its product,” Morland explained.
And the product can’t be marketed.
• OEMs must inform the supply chain when a product needs to be RoHS compliant. “However, to avoid problems further down the line, fastener suppliers will really need to ask questions regarding the destination of the products,” Morland wrote in the F+F article.
• Importers must review technical files and identify non-conforming products/risks.
• Distributors must not sell a product if there is a “reason to believe” the supply chain is at risk with non-compliant products.
• RoHS 2 changes from a “Due Diligence” to “Due Care.” While Due diligence requires the identification of threats and risks, due care requires action to mitigate risks.
• OEMs produce a “technical file” for the design and production process – including materials, chemicals and contamination. Distributors must add their own file for their internal processes. Morland wrote that TR Fastenings is looking at purchasing compliance risk assessment including storage and picking processes and delivery methods.
TR Fastenings has joined the BOMcheck system of streamlining the technical document process for the supply chain, Morland explained.
Though there is a cost to BOMcheck, it “supplies a robust tool for submitting full material declarations and compliance declarations to our customers, and allows us to receive the same from our suppliers,” Morland wrote.
In addition to RoHS, BOMcheck.net covers other major legislation.”Everyone needs to embrace the changes now to ensure processes comply with the Directive,” Morland said.
“Proving the process will radically change the way the supply chain works and the industry needs to pull together to successively manage this change. ©2011 GlobalFastenerNews.com
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