Compliant or not Compliant? That is the Question

When it comes to being RoHS2 compliant (also known as RoHS Recast) many people want to know if their company is compliant. The question is do we really know what “compliant” means? When RoHS was first introduced to the electronics industry back in 2003 there were exemptions that could be used and certain applications didn’t have to comply with RoHS directives set by the EU. If you don’t know RoHS currently, you will be surprised to learn things have certainly changed. Whether we agree or disagree on being compliant, it’s time to confirm our compliance status.

What are you getting at?

Since 2010 several changes have been made to RoHS. We all know this now as RoHS2 or RoHS Recast. When RoHS2 went into effect, certain applications that were exempt by RoHS regulations and directives in 2003 are now required to comply with the 2010 directives. That meant a lot of part number changes for OEMs and CM’s. Not to mention electronic component manufactures had to change certain exemptions. For example: For lead in the ceramic of the resistive element in 2003 we used exemption No. 5. The new exemption is 7c-I per the Directive 2011/65/EU of the European Parliament. This too will change very soon if extensions are not filed for the use of lead in electronic components. The exemption is currently set to expire in July, 2016.

We have started to see an increase in requests from manufactures requesting a plan of action for fully compliant parts.

Fully compliant?

I will take a little time to help clarify what the difference between being “fully compliant” and “compliant” with RoHS is.

Venkel is currently compliant with RoHS directives. We do however; claim an exemption for our Thick Film Resistor products. Our other products such as Capacitors, Inductors, Ferrite Beads and Thin Film Resistor products are fully compliant.

Fully compliant means products do not need an exemption in order to comply with RoHS directives and regulations.

So when you’re asked if your company is fully compliant with RoHS or if you have a timeline for full compliance, what they are really asking is when will you not need to claim an exemption for your parts that currently claim an exemption. In most cases it’s the use of lead in products that’s the issue, specifically lead found in the ceramic glass of the resistive layer. If lead is still needed you can still comply by being under the allowable threshold of 1000pm or 0.1%.

What this means for the industry

Currently we are in the early stages of knowing if extensions will be granted or if we will have to be fully compliant. With this uncertainty, manufacturers are preparing for having to be fully compliant. This means cost will go up, lead times may increase and part number changes will be inevitable. This is going to be a nightmare for those that are not getting a head start and requesting information on fully compliant products. You might be telling yourself that going to fully complaint parts will not happen in 2016, and while that may be true, it doesn’t mean it won’t happen eventually.

There is one thing that we have to keep in mind. These regulations were put in place to create a safer and healthier environment. Just because it doesn’t get passed in 2016, just means people need a little more time to make the transition. Some factors might be cost, as well as other changes that are going to come with this transition.

What is Venkel doing?

Venkel is in the final stages of having a fully compliant Thick Film Resistor that is equivalent to our General Purpose Thick Film Resistors. Our official target date for our data sheets to be ready is September 1, 2014. At that time you will also be able to get samples. Production quantities will be available starting October 1, 2014.

If you’re in the process of becoming fully RoHS compliant I wish you the best in the endeavor, we’re here to help in any way we can. Rest assured, we are all in the same boat. The cause is a good one though: trying to make the world a safer and healthier place to live for the next generation.

(Stay tuned for RoHS 2 resources, including an infographic and cheat sheet coming soon.)

RoHS Infographic: “RoHS: Past, Present, Future”

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