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10 Steps Toward RoHS Directive Compliance published by EIATRACK author Holly Evans

15 February 2005

EIATRACK author Holly Evans and subscriber Joe Johnson, Microsoft regulatory manager have written a useful overview of compliance with RoHS for the February 2005 edition of Printed Circuit Design and Manufacture. The article notes 10 steps for compliance.

The EU’S ROHS Directive imposes unprecedented regulatory restrictions on substances used in electronics. The targeted substances are cadmium, mercury, lead and hexavalent chromium, along with polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants.

Manufacturers must comply with significant, and potentially costly, compliance requirements in order to meet the RoHS deadline of July 1, 2006. What is not provided, however, are clear requirements for implementation, specifically
what actions will constitute “compliance.” Concerns, then, center on the actions necessary to prove RoHS compliance to regulatory bodies – and customers.


In order to determine certain implementation details, the European Commission formed the Technical Adaptation Committee, comprised of representatives from EU member states. TAC’s role: establishing a process for ensuring that
the RoHS substance ban provisions are met. One area this group will address is a method for RoHS compliance and enforcement. Options being discussed include producer self declaration, supply-chain declarations and market surveillance/testing.

The UK has proposed a “due diligence” approach, which will likely be copied by other EU members. Rather than expecting manufacturers to prove that every part they buy is free of RoHS-defined substances, members will likely expect manufacturers to establish documented and auditable systems to prevent noncompliant products from entering the EU market. Assuming this approach wil be taken, development, implementation and proof of a corporate RoHS compliance strategy is essential.

Many RoHS implementation issues remain to be settled. The TAC has not given
clear direction, but deadlines are nearing and industry must move ahead. In the absence of well-defined statutory or regulatory guidance, implementation of a best management practice approach that incorporates the common compliance activities of industry leaders may prove a valuable corporate strategy. Here are
10 steps toward developing and implementing a strategy for compliance.

10 Steps Toward RoHS Directive Compliance

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