Mission Critical for Manufacturers: RoHS & Reach Compliancy

Manufacturers of electronic equipment and components must adhere to what seems to be an ever-increasing number of industry and governmental regulations related to safety, materials and processes. For companies that create such products and market them internationally, two sets of regulations exist that govern the use of restricted materials—RoHS and REACH. Proof of compliancy for both the manufacturer of specific types of equipment and their vendors is now required by many countries—especially those in the European Union. Manufacturers, importers and also their customers are required to communicate information on chemicals throughout the supply chain in order to be aware of information relating to health and safety of the products supplied.

Years ago, some companies got away with skirting these regulations and regularly used non-RoHS parts; after all, they were cheaper. Well, once upon a time non-compliance was merely a matter of ethics, while today it’s about operating legally—your business must use RoHS parts for any product that will sell in the EU.

RoHS Overview

RoHS (Reduction of Hazardous Substances) was introduced by the EU in 2003. This piece of legislation’s primary purpose is to make electronics manufacturing safer at every stage of an electronic device's life cycle by reducing the harmful effects of certain restricted materials to people and the environment.

The substances banned under RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). As described in RoHS regulations, these restricted materials are not just a hazard to the environment but are dangerous to any worker involved in their manufacture or disposal. Additionally, RoHS also applies to the metal industry for any application of metal plating, anodizing, chromating or other finishes on EEE components, heatsinks, or connectors.

It’s important to note that RoHS restrictions have not remained static. Directive 2015/863 (often referred to RoHS 3), adds four additional chemicals as of March 31st, 2015. These substances are restricted in products entering the EU market after July 22nd, 2019. Those additions are…

• Bis (2-Ethylhexyl) phthalate (DEHP)
• Benzyl butyl phthalate (BBP)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP)

Any business that sells or distributes specific EEE products, sub-assemblies or components directly to EU countries, or sells to resellers or distributors that then sell products to EU countries, is affected if they include any of the restricted materials. RoHS regulations are no longer the exclusive domain of Europe; a number of other countries have adopted RoHS-style regulations.

REACH

Also a European Union regulation, REACH addresses the production and use of chemical substances and their potential impact on human health and the environment. The name is an acronym for Registration, Evaluation, Authorization and Restriction of Chemicals and is described as follows:

Registration: Chemical producers are required to register safety data for all chemicals produced.

Evaluation: Experts from member states and the European Agency evaluate safety data for higher volume chemicals and other chemicals of concern.

Authorization: “Very high concern” chemicals are to be phased out and replaced with safer alternative chemicals.

Restriction of Chemicals: Chemicals may be banned or some uses restricted.

REACH is monitored by the ECHA and deals with 197 Substances of Very High Concern (SVHC) currently. These substances include carcinogens, mutagens, reproduction toxins as well as persistent, bio-accumulative, and toxic chemicals.

The Symbiotic Relationship Between RoHS and REACH

RoHS restricts substances present in electrical/electronic equipment (wiring, components, circuit boards, displays, sub-assemblies, cabling), REACH controls all chemicals that might be used to manufacture the product, including enclosures, brackets, coatings, paints, solvents, and chemicals used during manufacture.

RoHS-restricted substances are also on the REACH restricted list. Substances on the list have been identified as being carcinogenic, mutagenic, reprotoxic, bio-accumulative and toxic, or as endocrine disruptors.

Assuring Compliance

Considering the requirements for strict adherence to EU regulations, manufacturers of parts and equipment for export must be able to provide proper documentation to their overseas customer proving their products are compliant.

One such company that has made RoHS compliancy a top priority is The Cubbison Company of Youngstown, Ohio. Through its specially trained staff and dedicated equipment and processes, the company maintains strict adherence to RoHS regulations, ensuring complete compliance throughout the manufacture of its core products—membrane switches, flexible electronics, touchscreens and name plates.

The company closely vets its vendors relative to RoHS compliance. After a recent audit of both RoHS and REACH certifications, Cubbison found only one supplier that would not certify their materials. Needless to say, that particular vendor is not on the company’s preferred vendor list. Nationwide, this business has earned the reputation as the go-to solution with customers who require these certifications.

To maintain its status as leader in restricted materials compliance, Cubbison has established four critical rules:

1. Materials added to end product must be certified materials;
2. Vendors are required to certify compliance when required;
3. No process that adds to the original materials is used;
4. When required, proper certification for all materials is maintained.

For additional information on Cubbison, it’s products and commitment to quality go to their website at Cubbison.com.