EU RoHS Recast

We previously discussed EU RoHS, which was the primary legislative driver for Molex to cease using tin-lead platings in many of its terminals.  Some thought that after the conversion to pure tin, no other changes would be necessary.  It turns out that’s not the case at all – legislation continues to change, including EU RoHS, which means Molex must continually be aware of the legislative requirements and how to meet them.

Over the past few years, the EU legislators have been working on a recast – basically, they’re re-writing the RoHS legislation.  Why do this?  After implementing and enforcing RoHS for a few years, items needing clarity were identified.  There have been many proposals by different legislators and committees, and the text has not yet been finalized, but we can expect a number of significant changes to the legislation.

One significant change is to the scope.  Previously, EU RoHS only applied to a list of categories of electrical and electronic equipment (for example, toys, consumer equipment and telecommunications equipment); end products that fall outside these categories are not in scope of RoHS.  With the recast, we expect medical devices to be included; the EU may also move to an open scope – instead of listing categories, all electrical and electronic equipment may be covered by RoHS.  Medical devices have a long design cycle (e.g. they must be tested thoroughly, which can take years), so they are not expected to be in scope of RoHS for a number of years.

The EU legislators are also attempting to clarify the exemption process.  Molex takes advantage of a few of the exemptions, as alternatives are not always available.  A clear exemption process will allow Molex to have a better understanding of when exemptions will no longer be permitted (i.e. when they expire).

The most significant potential change to EU RoHS is to the list of prohibited substances.  As discussed previously, six groups of substances are covered by RoHS.  A number of different parties have been lobbying for additional substances to be added to RoHS, or at the very least, identified as ‘priority’ substances that warrant greater scrutiny to determine if they should be included.  These substances range from bis (2-ethyl(hexyl)phthalate), a plasticizer used in PVC, to carbon nanotubes.  The addition of substances, and even the proposal for a list of priority substances, has been contentious, and no final decision has been made.

Whatever decisions are made by the EU legislators, Molex, its customers, and its suppliers can continue to expect RoHS and other legislation to continue changing as substances are identified as being environmentally hazardous.