In late June, IPC and the Information Technology Industry Council (ITI) hosted the annual Critical Environmental Regulations for Electronics conference. This conference is a great opportunity for those responsible for product environmental requirements of an electronics company to get the latest updates for several areas of activity. IPC is a global association delivering standards, certification, and thought leadership to drive quality, reliability, and innovation in the electronics industry. Their mission intersects with ITI, a global advocate for technology companies promoting public policies and standards.
Several key compliance topics were discussed during the conference. Read on for highlights on the following topics:
- EU RoHS Exemption Status
- UK REACH
- UK RoHS
- RoHS Non-Compliance
- US TSCA Updates
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EU RoHS Exemption Status |
| What: The EU RoHS (Restriction of Hazardous Substances) exemptions are the specific application instances where one of the restricted substances may be used within a product. Every exemption has a defined expiration and those are reviewed on a regular cycle, 5 years for Annex III exemptions and 7 years for Annex IV exemptions, as required by the RoHS Recast Directive 2011/65/EU.
Recent updates: The European Commission is exploring process improvements in the areas of efficiency, complexity, and administrative burden. Also, the Oko Institute is completing the first draft of recommendations for Pack 22 which will have a significant impact on industry as this contains many exemptions that are widely used today. |
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UK REACH |
| What: After BREXIT, the UK will stand up its own version o the EU REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation 1907/2006.
Recent updates: On January 1, 2021, UK Department for Environment Food & Rural Affairs (DEFRA) put in place s new chemicals regulation, UK REACH. The transition from EU REACH will continue to use the restrictions and SVHC list from EU REACH as of December 31, 2020. Priorities will be identified on an annual basis and lead the requirements to likely diverge from the European Chemical Agency (ECHA) in the future. Registration of substances/mixtures requirements will phase in over the next 6 years after initial information has been provided. |
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UK RoHS |
| What: After BREXIT, the UK will stand up its own version or the EU RoHS (Restriction of Hazardous Substances) Directive 2011/65/EU.
Recent updates: The previously used CE mark, will be replaced in the UK by a new UKCA mark. Initially the requirements to comply with the marking obligation will be aligned but will likely diverge over time, especially with a unique exemption process. |
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RoHS Non-Compliance |
| What: Monitoring and enforcement of the EU RoHS requirements continue to observe many instances of non-compliance even after being in existence for over 15 years.
Recent Updates: UK DEFRA are still seeing a high percentage of material failures leading with lead, particularly on PCB solder points. Manufactures and Importers need to ensure there’s a proper quality management process in place to support RoHS compliance and must incorporate it into the CE Technical File. |
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US TSCA Updates |
| What: US TSCA (Toxic Substances and Control Act) is managed by the EPA (Environmental Protection Agency) for assessing and managing chemical substances.
Recent updates: TSCA is currently undergoing a review of the risk evaluation process and risk management requirements. Recently, there were five PBTs (Persistent Bioaccumulative and Toxic Chemicals) added under Section 6(h) driving obligations for manufacturers to comply with new restrictions. The EPA Office of Pollution Prevention and Toxics also provided resources to support manufacturers with TSCA requirements. |
Supporting your Organisation across compliance topics
If you need any help understanding where your organisation stands and what your next steps could be, please don’t hesitate to reach out. Anthesis has the subject matter expertise to drive resolutions as well as a holistic approach to supplier engagement and data collection that will provide more flexibility and responsiveness to many of these new requirements as well as future obligations and initiatives.
Learn more about how Anthesis supports the tech sector and how we can provide support across a suite of product compliance issues.
