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issue: May 2006 APPLIANCE Magazine

Guest Editorial
Another Perspective on RoHS

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by Richard Topping, RFTopping Consultants LLC

One cannot pick up a trade publication or surf an industry Web site these days without seeing something (and often quite a bit) about RoHS.

The European Union clearly has everyone’s attention with this regulation limiting hazardous substances in many consumer products, including appliances. Speculation abounds by experts far more knowledgeable than I about the expected impact of RoHS on the availability of products, particularly U.S. exports, for the EU market come July 1, 2006.
I’m a latecomer to RoHS preparedness, and unfortunately, it appears that I am not the only one. Many companies apparently hoped that by wishing RoHS could go away, it would. At a minimum, they were confident of a delay. It did not happen. Amazingly, some of these companies already had RoHS compliant operations in Europe. Now they are spending vast resources, energy and manpower to understand the complexities of the regulation and its enforcement, as well as to implement necessary material and component changes in time for compliant products to be shipped to Europe, ready to be “placed on the market” by July 1, 2006. Unfortunately, some companies will probably not make it in time.
Admittedly, the EU has not been particularly helpful or clear about how RoHS would be implemented, or how each individual European country might add its own twist as it adopts the regulation within its own borders—not to mention situations where products are shipped into one country and sold into another. Adding to the confusion, in the case of imports, it is the local distributor (or “producer”) who is ultimately responsible for administration (and incurs the liability). Companies in our industry hate uncertainty and this has not been a clear process. Also, for many U.S. companies, exports may not be a large part of their business, so knowledge and contacts are limited.
But I still wonder why this caught so many of us by surprise. Is it that we still do not really view the appliance business as a truly global enterprise? For most U.S.-based companies, domestic sales are the “bread and butter” of the business and therefore get the most attention. As engineers, living and working in North America, we are busy enough already and are fully occupied with local issues, regulations, markets, etc. Maybe, in a moment of truth, we will even admit we are just a little parochial.
To be honest, however, let us all realize that at present it is a European regulation that is turning our industry upside down, and many of us did not even anticipate it or adequately respond until almost too late. Why is something of supposedly limited importance taking so much time and effort? Why is it that RoHS and expected legislation like it will probably transform all our products in 2 to 3 years? There is something perhaps profound here for the future—and an important lesson. The appliance industry of tomorrow will be driven more and more by new forces coming from unfamiliar places. Today it is a regulation, next it could be a technology or even a totally new product concept.
In this rapidly developing global marketplace, it seems that the challenge for us all will be to develop the insight and open-mindedness to see important change wherever it arises, and put aside the status quo just enough to display the flexibility we need to quickly and successfully respond.

About the Author

Dick Topping has more than 25 years experience in the appliance industry. He has a Master of Science in Mechanical Engineering from MIT and is the former director of Appliance Research for TIAX LLC. Topping recently launched RFTopping Consultants LLC to provide consulting services in technology strategy, new product planning and regulatory issues for the appliance industry. If you would like to contact Topping, please e-mail editor@appliance.com


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