RoHS - a moving target

The RoHS Directive came and went on July 1st with none of the predicted dramas or fireworks. These look likely to follow later in the year as the various enforcement agencies across Europe shift from their current educational and supportive role, to one of less tolerant policing. However, although the responsibilities and structures of the various agencies responsible for enforcing RoHS across the EU are largely complete, the actual implementation of RoHS compliant manufacturing across a wide spectrum of industries is far from finalised.

This summer's electronics press has seen a scattering of articles from electronics producers proudly boasting their achievements.

The press has also published comparable column inches from the anti-RoHS movement, who have been equally vocal about the injustice of what they consider to be flawed legislation.

However, there would appear to be a mass of SMEs that are absent from the debate, noticeable only by their deafening silence.

These companies, who haven't yet achieved full compliance, are understandably keeping very quiet about their progress, suffering painfully long lead times for compliant components to complete the last pieces of their RoHS jigsaw.

Yet a jigsaw isn't a very accurate analogy for RoHS, as the legislation was never intended to be absolute.

RoHS is essentially a framework directive, which allows for other restricted substances to be added (under Article 4.3), much in the same way that additional exemptions are inserted.

When this happens, the anti-RoHS faction will undoubtedly claim that the goalposts have been moved; although in reality the goalposts were never fixed.

Looking at the component manufacturers' historical transition plans may support this argument.

Getting the lead (Pb) out was the most obvious challenge.

Products that complied fully with the requirements of the RoHS Directive often followed this initial conversion, although the ultimate goal for many was the voluntary introduction of 'green' products.

Green products went beyond the requirements of the RoHS Directive and typically included the removal of all halogens.

It is not clear if this was driven by an environmental conscience, or a recognition that the directive will change, perhaps providing clues as to which parts of the periodic table may join the initial RoHS six.

What we do know is RoHS will evolve - we simply don't know when and how.