RoHS on categories 8 and 9

BANGALORE, INDIA: This article looks at how categories 8 and 9 of the WEEE can be included within the scope of RoHS. Farnell's components are RoHS, REACH and WEEE compliant.

Article 6 of 2002/95/EC RoHS (Restriction of Hazardous Substances) Directive requires the European Commission (EC) to carry out a review of the directive within four years of its adoption. The main issues include:

* The possibility of including categories 8 (medical devices) and 9 (monitoring and control instruments) of the WEEE (Waste Electrical and Electronic Equipment) Directive within the scope of RoHS.

* The possibility of restricting more substances that are hazardous, are used in significant quantities and where there are suitable substitutes.

* All of the existing exemptions to be reviewed and may be either modified, be more restrictive or removed completely.

* Other aspects such as where definitions and scope are unclear, as well as the subject of enforcement.

ERA Technology, based in the UK, investigated on behalf of the European Commission, whether or not it would be possible to include categories 8 and 9 within scope. Their conclusion was yes but with several observations:

* There would be a need for many more exemptions.

* There was a danger of stifling innovation if it was done wrong (e.g. inhibiting the development of novel sensors using restricted substances, the use of which far outweighs the small amounts used).

* These are relatively slow moving industries in terms of design cycles. If a restriction was brought in too early it could force products off the market early, damaging industry and affecting users such as hospitals, patients, etc.

* The rapid introduction of a restriction would put an enormous strain on a finite resource (the design team) in industries where there are many diverse designs sold in relatively low volume.

* ERA advised that it would be feasible to bring most products within scope from 2012 except for

- In vitro diagnostics (IVD) where 2016 was proposed.

- Industrial test and measurement instruments in 2016-2018.

- Active implanted devices such as pacemakers where 2020 was recommended or indefinitely excluded if reliability cannot be assured.

The ERA study provided an input to the RoHS review which, at the time of writing, is still on-going. Any change in scope with regard to categories 8 and 9 will only happen with a revision of the directive itself. The EC intends to table a new RoHS draft by around November 2008. It is unlikely that categories 8 and 9 will be brought within scope, if that is what they decide to do, until 2012 at the earliest.

It is possible even then that they may exclude part or all of these categories due to health and safety fears or the fact that categories 8 and 9 represent only 1 percent, or thereabouts, of all electrical equipment put on the market, and that most producers are going compliant anyway. To that extent, RoHS has pretty much done its job already in Europe.

Either way, both categories would remain within the WEEE Directive and would need to be efficiently, and safely recycled at end of life.

Typical products that would fall with categories 8 and 9

Category 8: Radiotherapy equipment, cardiology, pulmonary ventilators, nuclear medicine, laboratory equipment for in-vitro diagnosis, analysers, freezers, fertilisation tests and other appliances for detecting, preventing, monitoring, treating, alleviating illness, injury or disability.

Category 9: Smoke detectors, heating regulators, thermostats, measuring, weighing or adjusting appliances for household or as laboratory equipment and other monitoring and control instruments used in industrial installations such as in control panels.

Obviously, such equipment would need to be totally reliable and these two categories were originally excluded because of concerns over the use of lead-free solders.

Today, there is more confidence in the solder and it is felt that this can no longer be a reason for medical devices, and monitoring and control instruments to remain outside the scope of the RoHS directive.

The author is Customer Support Manager, Legislation and Environmental Affairs, Premier Farnell.