Assent Compliance Inc.

How to plan your new RoHS program


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The Directive 2015/863' has amended Annex II of the European Union's RoHS Directive (2011/65/EU)2 to restrict an additional four substances in electronics. Lessons learned from the first RoHS Directive (2002/95/EC)5 strengthen the need to understand when an electronics company needs to start their supply chain communication program. This paper will discuss some of the important decisions to be made when developing a plan.

Introduction to  Directive 2015/863

Approximately thirteen years after the first RoHS Directive was published, we have an amendment to its recast which adds four more substances under Annex II (2015/863).This brings the total number of restricted substances to ten. The four substances are DEHP, DBP, BBP and DIBP and are all categorized as phthalates.

Electronic products cannot be placed on the EU market after July 22, 2019 if they contain these substances above the allowable level Medical and Monitor and Control Equipment have until July 22, 2021. The Directive includes details about scope, exemptions and other technical requirements for compliance but this paper will focus on helping companies create their plan for their data gathering program covering these four new substances. If you require further information on the RoHS Directive, it can be found on Assent Compliance's blog4.

When do you start?

The year 2019 (or even 2021) seems like a long time from now but a lesson from the first RoHS Directive is that customer demand may dramatically change those dates. The Consumer Electronics Association (CEA) contracted a study* to determine the costs of RoHS compliance and found that, other than internal human resource costs, extra inventory and written-off inventory were the highest cost impacts to a business with respect to RoHS Compliance.

If these companies had a time machine, they would go back and start their RoHS compliance program much earlier. A customer who ended up with an

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