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Welcome to the October 2018 Design Chain Associates E-mail Newsletter!
In addition to DCA's newsletters, keep an eye on DCA's bi-monthly articles in TTI's MarketEYE Resource Center.
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The electronics industry and its supply chain need a conference in North America, and ChemicalWatch is bringing it to you! While DCA will present (on the CPSC's proposed organohalogen restriction, its history and implications) and even chair at least part of the conference, ChemicalWatch has assembled an all-star cast of presenters on a wide range of topics key to the industry. Hear from, meet and interact with regulators, standards bodies and your peers who are responsible for ensuring that their company's products meet or exceed market requirements.
Visit the conference website here for more information and to register.
NEW: My newsletter subscribers get a 25% discount on the registration fee! Email me for information about how to get the deal.
I look forward to seeing you here in San Francisco!
I have railed against the incorrect and premature use of the term "RoHS 3" (and equally misguided and misleading terms like RoHS 2.1, RoHS 5/6, and so on) and have been only marginally successful in eradicating it from the industry lexicon. To recap:
EU Directive 2011/65/EU is RoHS 2. Directives that amend 2011/65/EU, including 2015/863 (which added phthalate restrictions), do not create a new RoHS regimen. Until the European Commission replaces it with a new Directive we will continue to operate under RoHS 2. The Directive replacing 2011/65/EU will be RoHS 3.
In Directive 2011/65/EU, Article 24, paragraph 2 says
No later than 22 July 2021 the Commission shall carry out a general review of this Directive, and shall present a report to the European Parliament and the Council accompanied, if appropriate, by a legislative proposal.
The Commission's review has just begun. To kick-off the process, a call for comment is now open through October 12. A longer and more in-depth stakeholder comment period will open in the spring. The purpose of the current evaluation is to
assess the performance of the RoHS Directive since its entry into force in 2011, and where necessary will look back further to its predecessor legislation. It will evaluate the delivery of its objectives of (i) protecting human health and the environment, including the environmentally sound recovery and disposal of waste electrical and electronic equipment, and (ii) of guaranteeing the functioning of the internal market. It will also identify whether regulatory simplifications or improvements to the legislation could be possible.
So stay tuned, get ready to participate, and remember: this is RoHS 2...it's not RoHS 3...yet.
DCA has (finally) produced English translations of the first China RoHS 2 Catalog and the accompanying list of applicable exemptions. Please visit DCA's China RoHS website for more information and to order them.
With the substance restriction phase of the China RoHS 2 regulation slated to come into force on March 1, 2019, we are - somewhat surprisingly - still awaiting definition of the "conformity assessment system" that Electrical and Electronic Products (EEPs) specified in the first catalog must be validated by.
The organization responsible for producing this, the Ministry of Industry and Information Technology, has an unfortunate track record of producing clarifying documents such as FAQs and guidance documents far later than is comfortable for industy. I'm disappointed to see this trend continuing.
On the other hand, the Chinese government, in its rush to produce more standards than any other country or Standards Development Organization on the face of the planet, has, over the past 7 years, produced numerous standards that either are, or appear to be, relevant to the China RoHS 2 regulation that came into existence in January, 2016. The application of some of these is as yet unclear and in one cases two of the standards appear to be redundant:
We fully expect (or hope) the conformity assessment system and any guidance the Chinese government produces will shed some light on this situation. Stay tuned!
I couldn't pick a single article from Go Global Compliance President Peter Merguerian's latest newsletter to share here! The newsletter contains a raft of updates regarding EMC, safety and other regulatory requirements for electronic products from
August 17, 2018 TTI MarketEYE: Lead is now an SVHC - Implications for Manufacturers + Prop 65 & RoHS. Now nearly every manufacturer of EEE will have to disclose an SVHC. Read why in this month's article.
July 17, 2018 Capitol Weekly: Regulating lead-acid batteries. I opine on how DTSC should focus for the next set of Priority Products, and that one of them should not be lead-acid batteries.
November 8-9, 2018: San Francisco, CA. Chemicals Management for Electronics and Electricals USA 2018. Get 25% off for being a subscriber to DCA's newsletter!
June 11-13, 2019: Reston, VA. ACS Green Chemistry & Engineering Conference. Got examples of - or challenges with - implementing green and sustainable chemistry in the electronics supply chain? Get in touch with me!
More to come! Stay tuned.
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Best Regards,
Michael Kirschner
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