The DTI has published revised Regulations on the Restriction of Hazardous Substances in Electrical and Electronic Equipment ("RoHS"). These Regulations will implement the EU RoHS Directive (2002/95/EC) and will come into force on 1 July 2006. It is expected that most other EU Member States will also bring corresponding legislation into force by this date.
The RoHS Regulations prohibit the use of lead, mercury, cadmium, hexavalent chromium and certain types of brominated flame retardant in new electrical and electronic equipment ("EEE"), subject to certain exemptions. The UK previously published "final" RoHS Regulations in late 2005 but the DTI has recently issued a revised version (SI 2006 No. 1463). No significant changes have been made to the substance of the Regulations but further specific exemptions have been included to reflect those recently agreed at EU level.
All relevant EEE placed on the market from 1 July 2006 will need to be compliant with the new Regulations. Failure to comply will be a criminal offence. The main responsibility for achieving compliance lies with "producers" of EEE (i.e. manufacturers, importers and own-labellers), however the RoHS Regulations will also have significant impacts on component suppliers and, potentially, end users. Whilst many businesses have made the required material substitutions in their products in good time, it is likely that significant quantities of products entering the EU market will be neither compliant nor exempt on 1st July. Great care must therefore be taken across the whole supply chain to ensure compliance of products and materials. Consideration must also be given to potentially differing interpretations of the Directive across the EU, particularly in relation to the scope of relevant products.
The wider implications of the Regulations must also be considered throughout the life-cycle of a product, from initial design through to sales and end of life. Issues that could arise include differing performance characteristics of substituted materials; requirements in supply contracts to verify compliance, and; availability and/or cost of spare parts for existing equipment.
Click here to view the revised RoHS Regulations.
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The original publication date for this article was 27/06/2006.