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VOLUME -22 NUMBER 5
Publication Date: 05/1/2007
May 2007 Issue
Special Feature: Components & Disty
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Dealing With RoHS - Globally
Firms selling into Europe or Asia must comply with Pb-free regulations, although some applications are exempt.
By Tom Adams
July 1, 2006, was a day of reckoning not just for European electronics manufacturers, but for any firm that sells its products in Europe. In the U.K., which probably makes public more information on its RoHS activities than other European country, it was clear that there would be a short grace period for assemblers who, for example, may have found it impossible to replace all 20 of the ICs on a given board with lead-free components.
The undefined grace period has long since expired, but there have been no reports from the U.K. of firms being fined for non- compliance with RoHS rules. Instead, the National Laboratory of Weights and Measures, which has the responsibility for administering RoHS, is working with "problem" manufacturers to speed up compliance. Legal prosecution, the National Laboratory has made clear, is still an option, but only as a last resort.
To gain a more global perspective on RoHS developments — and particularly with regard to China — we spoke with Steve Schultz, director of strategic planning at Avnet, the Phoenix-based distributor of electronics components, parts and systems. The initial implementation date for China RoHS passed on March 1 without much real activity, Schultz notes. This was the day that the requirements for the labeling of products went into effect. "It means that you have to label the product, but you don't have to comply with the restrictions," Schultz explains.
Actual compliance will come later, when China issues what is called "the catalog," he explains. "At some time in the future — no one knows when — China will issue the catalog," he says. "The catalog will identify for the first year what products are covered and have to comply to those chemical thresholds. . .the catalog was supposed to be published last year, and now people are speculating that it will come out at the end of this year."
How specific will the catalog be in identifying products that must comply with the legislation? No one knows yet, Schultz says. Computer displays might be covered by the first-year catalog, but speakers might be omitted. A second catalog will follow, covering even more products.
Products Sold in China
The China RoHS legislation covers products that are imported into China and sold there, Schultz explains. Suppose that a distributor sells components to an assembler who assembles a product and then ships it to China for sale. The assembler is the one responsible for RoHS compliance.
But suppose that the components are not being assembled, but are simply being shipped to China to be sold loose — a little plastic bag of ICs to be sold in an electronics hobby store, for example. It's not clear that these would have to comply with RoHS rules.
There are other details of the implementation of Chinese RoHS that are not clear yet. In Europe, for example, many parts being used in military hardware, or in critical medical equipment received exemptions from the RoHS rules. These parts were then legally labeled as RoHS-compliant, even though they were not lead-free. Some confusion resulted when users could not tell from the label that the parts still contained lead.
"But in China, they haven't issued any exemptions," Schultz adds. "That doesn't mean they won't. Their approach is that they will test everything. Once it's tested, they will announce that the product is approved, and issue a China compliance certificate. And the agencies that will administer this are the customs areas. So you will have to have that compliance certificate at some point in the future." The matter of testing differs greatly between the EU and China. A company selling electronics products in the EU operates under what is called a "declaration of compliance," Schultz notes. There is no paperwork. Simply by putting a product on the market in Europe, you are declaring that it is compliant with European RoHS regulations. Testing is carried out only when there is a question about compliance. In some cases, this might mean that a competing firm has reason to believe that some of the parts or components in your product are not RoHS-compliant. Testing in the EU is usually performed quickly and easily by an X-ray fluorescence (XRF) gun.
Testing in China
In China, Schultz says, it appears that the process of testing will be more complex and more elaborate. One difference is the cost to the company. In the EU, testing costs are presumably borne by the state. In China, Schultz explains, "you make the product, and you send it to a lab in China — and you have to pay for it to be tested."
Companies selling into the European Union operate under a "declaration of compliance."
The timing of testing is also different. In the EU, testing — if it is needed at all — comes after initial marketing of a product. "In China, before you can put it on the market, you have to have this testing done," Schultz says. How does the testing schedule fit in with the publication of the various catalogs that will tell which products are covered by RoHS legislation? It is hard to tell yet, but Schultz thinks the system may work like this:
Suppose the first catalog is published late in 2007. Since it is their first catalog, it doesn't cover a lot of products. Even if it does cover your product — computer speakers, for example — you will have a year before you will have to have the product tested and comply with the RoHS regulations. But Schultz notes that there is nothing that guarantees that the system will work this way. For U.S. companies, the future implementation of Chinese RoHS poses many questions. To clarify the issue, Schultz points out that the regulations apply only to finished products being sold in China; if your company is having products assembled in China for export and sale in other countries, the regulations do not apply. But Schultz expects few companies to avoid the regulations in this way. "You can't just say you're going to build the speakers in China and ship them to the Americas and to Europe, because China as a marketplace is growing like crazy," Schultz says. "You'd be cutting yourself out of that market."
And a maker of electronic products that will be sold in China doesn't know whether his product will be included in the catalog that will apparently be published later this year, or whether it will be included in some future catalog. So he has no idea how much time he has to become compliant. Furthermore, as Steve Shultz points out, he might want to have the finished product tested, or he might want to have the subassemblies tested separately.
So far, interest among U.S. companies to have their products tested to meet Chinese RoHS regulations seems to be limited. "Do you go to the effort of getting the thing tested at this point?" Schultz asks. "Do you send (your product) into China to one of the labs that has been approved to test it? Maybe you do, maybe you don't. I don't see a lot of companies talking about sending the product to China to be tested, although that's part of the requirement — it has to be tested in China."
For more information, contact: Avnet, 2211 S. 47 St., Phoenix, AZ 85034
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