RoHS 2 is an update to the European Restrictions on Hazardous Substances (RoHS), which took effect in 2006. The new requirements are part of a revision to the original RoHS directive that began in 2010, also known as the RoHS recast. The original directive banned the use of six substances—lead (Pb), mercury (Hg), hexavalent chromium (Cr (VI)), cadmium (Cd), polybrominated biphenyl flame retardants (PBB), and polybrominated biphenyl ether flame retardants—in eight categories of electrical and electronic equipment. RoHS 2 broadens the scope of the directive to include additional products and product categories and makes RoHS compliance a CE directive, placing more data collection work on companies throughout the supply chain that sell products in Europe.
Large independent distributor N.F. Smith & Associates deals with RoHS restrictions and other regulations throughout the world as part of its growing international business. We asked company COO Matt Hartzell to talk about RoHS 2 and how it is being received in the electronics supply chain:
Global Purchasing: The RoHS recast compliance rules went into effect in January. What is your company doing differently today to accommodate these new rules?
Matt Hartzell: Very little actually. But only because we have not seen the demand yet … It has really been under the radar so far at this point. We are fortunate to have some critical certifications in place, like ISO 9001 and 17025, that hold our operations and procedures to rigorous standards and situate us well for the new requirements of RoHS recast. Also, we’re upgrading our equipment and we are looking at different reporting traceability requirements. But we are customer driven and because all of these types of requirements start with the user of the product, it has been almost radio silence out there. There just hasn’t been a groundswell of questions and concerns about this—especially compared to what preceded, RoHS 1.
Global Purchasing: How familiar do you think most distributors are with the new rules? Do you think most companies in the supply chain are prepared to meet the new requirements?
Hartzell: That’s hard to say. We are, but I would have thought I’d heard more if companies were prepared. I don’t know that they are.
That said, it’s important for any distributor to be aware that these are out there, that they have to have their inspection processes, their testing abilities and the ability to remodel and revise their shipping, printing and paperwork processing abilities. These things can change on a dime, so distributors have to be ready to make these things happen. I’m afraid some might get caught unawares with so little noise about it right now.
Global Purchasing: What are your main concerns regarding RoHS in general and the new rules in particular?
Hartzell: Well, it costs more. We have a few employees focused on it to meet the requirements. But whenever we do this it is a distraction, albeit a necessary one. Around the world we are filling landfills with metals that should not be there; with poisons that are going to affect the [environment]. But because it’s just another regulation people look at it with the view that “I’ll meet it when I absolutely have to.” Our customers have not said, “I need this RoHS 2 compliance.” There has been a lot more concern voiced to us in the last few months about conflict minerals. Part of that might be a function of Europe’s own economic woes.
From continent to continent, from state to state, we’re just going to have deal with a whole patchwork of laws that says this is good there, this is not good here. We will just have to be nimble enough and quick enough to put people on those particular regulations and make sure that we comply. Until our customers really need us to focus on it, we’re focusing on what our customers really need.
Global Purchasing: One of the biggest changes as a result of the new rules is the inclusion of RoHS as a CE Directive. How does this affect business—for the entire supply chain and for distributors in particular?
Hartzell: The actual marking has not reached the radar yet. Where we’ve seen it is not on components so much as on completed products. So far, it’s been more about specific restrictions, metals and traceablility requirements. So we’re working there more than we are on the CE mark. But again, there’s a record keeping, traceability component to this rule that the ISO certification process really supports. We feel well prepared to handle the new rule.
Global Purchasing: What other legislative issue are you watching—both abroad and here at home?
Hartzell: Here in this country there is the NDAA [National Defense Authorization Act] law put into place in late 2011 for purchasing electronic components into the defense supply chain. Those [anti-counterfeit] regulations are still being finalized. We’ve been paying a lot of attention to that. I think we’ll see flow-down of those requirements throughout the industry.
In addition, China had their environmental restrictions go into effect [recently] and that’s been fairly simple to deal with. We thought we were going to hear more regulations emanating from that, but we have not. If there is going to be any type of situation developing with any particular regulations, we’ll hear about it on the customer front first—especially when it comes to compliance issues with importing and exporting. So that’s one place we stay focused on.