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issue: May 2005 APPLIANCE Magazine

The Open Door
Impact of RoHS on Materials and Parts Availability

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by Tim McGrady, principal scientist, IMR Test Labs

Recent regulations such as the European Union Directive 2002/95/EC on the Restriction of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) have increased the limitations on material use.

Tim McGrady is the principal scientist with IMR Test Labs, a materials testing facility located in Lansing, NY, U.S. He was recently elected chairman of ASTM International Committee F40 on Declarable Substances in Materials. If you wish to contact Mr. McGrady, please e-mail editor@appliance.com.

Per RoHS, the use of lead, cadmium, mercury, hexavalent chromium, PBBs, and PBDEs is restricted in most electrical and electronic devices to be put on the European market. Those restrictions are in addition to existing regulations, such as the 47 categories of dangerous substances restricted for use in nearly every product by EU Directive 76/769/EEC and its numerous amendments.

As substances become restricted, manufacturers have to consider whether to continue to offer materials with restricted substances for those markets where those substances are not regulated, or to just stop making materials or parts containing the restricted substances. This decision is most often based on cost and continued demand, but can be made solely on risk assessment. It can be difficult to control where materials might end up, and as such, they may be sold within a regulated product or in a market with substance restrictions.

One surprising impact of RoHS, in combination with other EU Directives, is that nearly all materials of construction for consumer goods are regulated by the EU. This means that the impact is global in scope, since the tendency is for companies to make wholesale changes to their products when large markets impose restrictions. Such legislation also tends to spread, as has been evidenced by potential new legislation in China and the U.S. For appliance manufacturers involved in global trade, this means that decisions will have to be made concerning whether to make market-compliant products tailored to each set of market restrictions or to just make one of each product type meeting all current restrictions. It is also important to note that parts once made with restricted substances, such as hexavalent chromium-coated fasteners, will eventually become more limited in availability and thus more expensive to procure. Product specifications will have to be adjusted once replacement materials and parts are found.

But what about procurement of RoHS-compliant materials, and how do you know if your current materials are RoHS-compliant? Unfortunately, there are currently no standards, the infrastructure by which industry transfers goods via contractual agreements. Standard material specifications allow buyers and sellers to easily communicate complex requirements; for example, if you buy 12G (40Z) electrolytic zinc-coated steel sheet per ASTM A 591, all you have to do is place that information on your purchase order, as opposed to stating all the requirements that the material must meet. In order to test whether the contract was properly fulfilled, the coating mass can be determined per Test Methods ASTM A 90, ASTM A 754, or ASTM B 504, and the results may then be assessed to the limits given in Table 1 of ASTM A 591. But because the proper standards are not in place for RoHS, this ability to make contracts and determine compliance is not yet available. Such standards would substantially reduce the amount of testing for RoHS compliance since material suppliers could have access to standard test methods in order to provide a certificate of analysis for each material batch.

There are currently two efforts related to the development of standards for RoHS testing. They include ASTM International Committee F40 on Declarable Substances in Materials and the International Electrotechnical Commission (IEC) TC 111. IEC TC 111 is governed primarily by computer and cell phone interests. A work group within TC 111 intends to publish one document containing all the necessary chemical analysis methods to determine RoHS substance concentrations in all material types. This document, if published as an international standard, will be incorporated into purchase orders all over the globe, thus gaining the legal force commonly associated with contracts. As a standards development professional and materials analyst, that potential outcome troubles me.

ASTM International Committee F40 was formed in order to help industry cope with issues such as RoHS-compliance. F40 will assist industry in the development of standard test methods for declarable substances, help make sense out of the myriad regulations and regulated substances, and in general, serve as a resource for any interested party to draw upon when material compliance issues arise. But F40 will not dictate test methods and material specifications to industry; rather, when industry asks for our help, we will assist them in standards development. The overall goal is to provide a framework in which true consensus standards may be developed in a timely manner such that industry will be able to easily respond to material regulations.


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