This month we provide the basics for compliance with the European Union’s Directive 2002/95/EC—“On the restriction of the use of certain hazardous substances in electrical and electronic equipment.” This directive is commonly referred to as “RoHS,” for Reduction of Hazardous Substances, or EU RoHS, now that other countries have introduced their own RoHS-like directives.

When RoHS was first announced, most of us in the electronics and electrical goods sectors paid primary attention to its inclusion of lead (Pb) in the restrictions. Most early compliance efforts were aimed at testing and measuring for lead content, so much so that the RoHS directive was often called the “lead-free” directive.

Looking back, that was a rather myopic perception. With time, the significance of the other hazardous substances in our products and production processes became more apparent. You will likely be surprised, as many were and still are, at the list below of where some of these substances can be found.

What are the six hazardous substances identified for restriction in RoHS?

They’re lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers/oxides (PBDEs).

In what are these substances commonly found?

These RoHS-restricted substances can potentially be found in any product material including metal, plastics, coatings, components, subassemblies and even the packaging in which the products are sold (which is also covered by the RoHS directive). Perhaps the greatest challenge for any consumer-products company whose products use electric current is knowing what substances are in each component received from its suppliers.

Here are some common places to look for each of the RoHS-restricted substances:

Lead: solders, leads, coatings, paints, pigments, platings, chassis, PVC stabilizers, internal/external interconnects, washers, glass, lubricants, detectors, fuses, photoconductors, metal parts

Mercury fluorescent lamps, bulbs, lighting (displays, scanners, projectors), sensors, relays, switches, pigments, paints, polyurethane materials (high gloss PU widows), PVC and rubber additives

Cadmium: coatings, solders, semiconductors, contacts, PVC cables, PVC stabilizer, pigments (yellow), paints, metal finishing/plating (connector/switch/relay contacts and fasteners), phosphorescent coatings, CdS, CdTe detectors/devices/LEDs, recycled plastic materials

Hexavalent chromium:  coatings to prevent corrosion (e.g. yellow chromate), chassis, fasteners, alloys, metalized plastics, pigments, paints

PBB/PBDE:  flame retardant in polymers, coatings, plastics, housings, PWB, cables, paints, PCBs, connectors, fans, various components

Are there any exemptions from restriction in RoHS for these substances?

Yes. There are certain uses that are exempt from the RoHS requirements. Whether they remain exempt is a subject for speculation, but the odds favor those exemptions falling away in time. As they become aware of the exemptions, the public is likely to disagree over whether they serve the public good, especially when alternatives to the offending substances become available.

How would you know if these substances are part of your product?

There are a variety of test methods to determine the content levels of restricted substances in products. Some are simple. Others are more challenging because of what’s required to accurately determine the sum of the parts in a finished product.

Of course, requiring your suppliers to disclose what’s in the parts they provide to you is an elemental step in managing what’s built into yours. However, your confidence in the legitimacy of what you’re told should hinge on the effectiveness of the processes each of your suppliers uses to determine the substance levels in what’s supplied. “Show me!”

Will more substances be subjected to RoHS-like restrictions?

Yes. RoHS triggered a global awakening to the deadly consequences we face from exposure to lead and other hazardous substances built into many of the products that we use. There’s a significant shift in our value system underway. The more we learn about the effects of these substances, the more we recognize the need to take action. The reasoning behind the restriction accountabilities written into RoHS applies wherever we endanger ourselves. Action to be taken will likely reach well beyond the electrical and electronic product populations. For instance, what about that fire retardant woven into the mattress you slept on last night; who knows exactly what effect that had on your dreams?

A substance and product focus is very limiting and can trap one into a knee-jerk, reactive response. A comprehensive process management approach is robust and will prove to be the most effective and efficient means to accommodate all newly emerging substance restriction requirements.