Journal of SMT Article

DEVELOPMENT OF A "SYSTEMS BASED" COMPLIANCE APPROACH TO THE EUROPEAN UNION'S ROHS DIRECTIVE

Author: Holly Evans
Company: Strategic Counsel, LLC
Date Published: 1/1/2006   Volume: 19-1

Abstract: In February 2003, the European Union (EU) enacted Directive 2002/95/EC on the restriction on the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive). The RoHS Directive bans the use of lead, mercury, cadmium, hexavalent chromium, and certain flame retardants in electrical and electronic products sold on the EU market by July 1, 2006. The Directive is silent as to what corporate actions will constitute legal compliance with the Directive.

Legal compliance will not be easy, given the lack of EU guidance on what products are covered and what actions will be accepted by EU member states as evidence of compliance. Furthermore, product producers cannot test every product for RoHS compliance, given the cost and destructive nature of testing.

Recently, the European Information & Communications Technology Industry Association (EICTA) proposed a "RoHS Compliance Process" to a number of EU government representatives. This proposal sets forth a system-based approach for demonstrating RoHS Directive compliance and includes three key elements: (1) a producer self-declaration of conformance, (2) implementation of a documented system that demonstrates producer actions to restrict banned substances from the manufacturing process, and (3) limited EU testing in cases where the system-based approach appears insufficient.

This proposal was well-received by EU member representatives and, if accepted, may constitute a cost-effective and reasonable approach for demonstrating RoHS Directive compliance in the future.

Key words: RoHS compliance, lead-free electronics, RoHS Directive, due diligence.



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