Is Flat the Next Big Thing?

The Human Media Lab at Queen’s University, Canada and Arizona State University’s Motivational Environments Research group have teamed up to create what’s been dubbed the “PaperPhone.”  The phone was created with the same e-ink technology found in the Kindle e-book reader and in flexible printed circuits featuring an array of bend sensors.

E-history: the world is flat, but bendy. The first electronic paper, developed in the 1970s in Palo Alto, was called Gyricon and consisted of polyethylene spheres between 75 and 106 micrometers across. In the 1990s another type of electronic paper was invented by Joseph Jacobson, who later co-founded the E Ink Corporation.

In an electrophoretic display, particles with a diameter of one micrometer are dispersed in a hydrocarbon oil with a dark-colored dye with surfactants and charging agents. This mixture is placed between two parallel, conductive plates. With applied voltage, the particles will migrate electrophoretically to the plate bearing its opposite charge.  Arranging this movement into patterns — in this case pixels — is the basis for a paper thin display.

Although called the “PaperPhone”, the name doesn’t quite do the prototype justice. “SmartPaperPhone” may be more fitting. The device can perform several tasks, depending on what shape you form it into.  Want to make a phone call? Bend the paper into a concave shape. Have a favorite e-book? Bend the page corner to turn to the next page. You’ll even have an mp3 player that’s much thinner than your current iPod.

E-regulatory compliance. As far as regulating something like this is concerned “the electronic components and lithium batteries are not regulated as hazardous waste. The entire electronics assembly is RoHS (Restriction of Hazardous Substances) compliant and marked as such on the printed circuit board in the cover. All of it can be recycled through your local municipal waste program in the same manner as you dispose of household batteries. (Check local regulations for any further restrictions.) The paper can go in your paper recycling, and the protective foam in your plastic recycling.”

E-exciting or e-issues? While exciting, there are some issues with the PaperPhone. Batteries are still fairly clunky and won’t easily bend. The memory has to be kept somewhere as well. What good is a flexible electronic paper phone if most of is has to stay stationary to accommodate the required working innards?

It could be that buying a ream of cellphones at your local big-box retailer may not be that far off.

Learn more about the technology below:

Adam Baer (guest-blogger for Kal Kawar) manages materials regulation data and reports at Actio Corp.  He holds a B.A. in Journalism from the University of Maine.

RoHS Recast — Regulatory Update Made Official

The Council of the European Union (“the Council“) officially revised the RoHS directive on hazardous substances in electrical and electronic equipment.  The chemical restrictions will now apply to all electrical and electronic equipment, as well as to cables and spare parts, and to medical devices, medical equipment, control and monitoring equipment – which were previously exempt from RoHS compliance but are not exempt now.

Further, this recast will harmonize the directive across the European Union.

The product categories affected by RoHS include large household appliances, computer equipment, TVs, lighting, toys and video games, and vending and ATM machines – as well as the categories listed at the top of this article.  You can imagine then that almost all discrete manufacturing sectors are affected – as most use computer equipment in parts, components or assemblies.  RoHS creates a notable data management challenge in terms of supplied parts and compliance certification.

RoHS Recast provisions. Provisions are included in the recast to allow time for the market to adjust.

A three-year transitional period is allowed for some devices:

  • monitoring
  • control
  • medical

A five-year transitional period is allowed for:

  • in vitro medical devices

A six-year transitional period is allowed for:

  • industrial control appliances

Nanomaterials under RoHS. Everyone wants to know how nanomaterials will be regulated.  It’s a grey area.  Rightly, the European Commission says that work towards a common definition of nanomaterials is necessary (yes!) and ongoing. The EC intends to adopt a Commission Recommendation on a common definition “in the near future.”

The Commission considers that the RoHS provisions cover different forms (including nanoforms) of the substances which are currently banned. The Commission also considers that these RoHS provisions cover forms subject to a priority review under RoHS in the future.

RoHS Recast next steps. Next steps include:

  • Signatures and Journal publication
  • Transposition into EU member state laws
  • Industry implementation

There are a few good resources for more information. Design Chain Associates (DCA) has a good article and some (reasonably priced) on-demand webinars for more in depth review.

Would you accept this RoHS? It may be a good idea to review why we are gathered here today. While the ins and outs of regulations can be like jungle hacking – a look from the air is a good idea from time to time.

There are measurable environmental benefits to a well-executed and enforced RoHS program. Reported environmental benefits include:
•    reduction of lead (Pb) use in products by 82,700 tons in the EU
•    reduction of cadmium (Cd) use in products by 14,200 tons
•    reduction of mercury (Hg) use in products by 9,500 tons due to changes in copiers and fluorescent light bulbs
•    reduction of mercury in waste streams by 6,900 tons

RoHS restricted substances. RoHS focuses on six hazardous substances: lead, mercury, cadmium, hexavalent chromium and two types of flame retardants in plastics (PBB and PBDE). The restrictions have not changed since last November, but additional hazardous substances are now expected, whereas the list of substances of concern under the previous version of RoHS was considered more stable. Click here for the current list/threshold amounts.

To wit, RoHS is a directive, not a regulation. The difference is that a directive cares only about the result. With RoHS, for example, the required result is the restricted use of certain toxic metals in electronics manufacturing. A regulation, on the other hand, delineates to each entity under the umbrella of the regulation how to get the result.  A good example is the REACH regulation, which has a detailed process for substance registration, use, and data sharing.

Bismuth: Behind the Numbers

Based on a recent post I published regarding the use of bismuth in solder alloys, John writes:

If Bismuth comes from the production of Pb, and if the use of Pb is being reduced, won’t the availability of Bi be reduced…and the price would increase?”

Just thinking…

Dr. Ron responds:

Lead has been banned from many of its original uses, paints, solders, water pipes, gasoline, etc. However, its increased use in batteries has actually caused lead consumption to rise. The USGS estimates that 88% of lead produced is used for lead-acid batteries.

Many of us in electronics assembly have been focused on the 2006 RoHS lead ban. This may have caused us to believe that lead use in electronics was significant. About 9 million metric tons (MT) of lead are consumed each year, only about 20,000 metric tons were used for solders prior to July 2006, this amount is only about 0.22% of the total. Electronics lead use being so small is likely why the lead industry had little visibility in fighting RoHS. Their important customers were making batteries.

Lead is quite effectively recycled, as about 60% of the 9 million MTs/yr. are from recycling and 40% from mining.

Over 100 million lead-acid auto batteries are sold each year in the US alone. In addition, the use of lead-acid batteries in forklifts, electronic vehicles, and golf carts has increased demand for lead. So, the bottom line is that lead use is expected to grow at about 2% per year.

Considering that we calculated that bismuth use in solders would be at most 5% of total bismuth production, it is unlikely that this use, or lead production reduction, would affect bismuth supplies.

Best Wishes,

Dr. Ron

Top 5 Questions About RoHS in 2011

Here are the top 5 things businesses need to know about RoHS in 2011.  And first, an overview of the RoHS directive.

RoHS overview

As of July 1, 2006, producers and importers of electrical and electronic equipment (EEE) in the European Union (EU) must adhere to the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations (RoHS).

RoHS is a directive, not a regulation.  The difference is that a directive cares only about the result.  With RoHS, for example, the required result is the restricted use of certain toxic chemicals in electronics manufacturing.  How businesses achieve that result, or how member states handle governing that process, is up to each.

A regulation, on the other hand, delineates to each affected entity how to manage compliance with the law.  A good example of a regulation is the REACH regulation, which has a detailed process for substance registration, use, and data sharing.

RoHS restricts — and in some cases bans — the use of certain hazardous substances above a specified amount in the manufacture of electronics.  The key hazardous substances under RoHS are lead, cadmium, mercury, hexavalent chromium, as well as polybrominated biphenyl (PBB) and  polybrominated  diphenyl ether (PBDE) flame retardants.  Part of the RoHS objective is to prevent thousands of tons of banned substances from being improperly disposed of, thus protecting human health as well as the environment.

As of November of 2010, there was an update to RoHS called the 2010 RoHS Recast.  The restriction updates are best depicted in a table:

The product categories effected by RoHS include large household appliances, computer equipment, TVs, lighting, toys and video games, and vending and ATM machines. Two categories – medical devices and equipment and control and monitoring equipment – are currently exempt from RoHS compliance.  More details about effected and RoHS exemptions and categories can be found on the UK RoHS website.

Producers must now prepare documentation to show that their products are compliant before placing them on the market, and, if requested, provide the documentation to the RoHS Enforcement Authority within 28 days. Also, this documentation must be maintained for four years after the product is no longer made available on the market.

The effect of RoHS has extended well beyond the EU. Major electronics manufacturers have adopted changes on a global scale in order to comply with RoHS, regardless of where their products are sold. As a result, companies that supply parts to these manufacturers must also track and maintain accurate information about these components.

1. What is the RoHS – REACH Connection? REACH regulations restrict the use of Substances of Very High Concern (SVHCs) in Europe and the importation of articles containing these substances from outside of Europe. RoHS complements REACH by limiting the amount of hazardous substances that can be used to produce EEE in Europe and defines the proper disposal of EEE waste.

2. Who is exempt from RoHS regulations? Private individuals making purchases from outside the European market are not required to comply with RoHS. Because the first importer of a product to the European market is responsible for complying with the regulations, businesses acquiring products from within Europe are also not required to comply.  Again, specifics about effected and exempt categories can be found on the RoHS website or in last year’s RoHS articles on the Actio Blog.

3. What are the costs and benefits of RoHS? According to the March, 2008 Final Report of the “Study of the RoHS and WEE Directives”, published by the environmental consulting firm Ecolas for the European Commission, RoHS has resulted in a major reduction of hazardous substances found in various products, reaping both environmental and economic benefits. You can view the report here.

Although RoHS presents many benefits, some of the costs associated with RoHS compliance have included R&D and capital costs, averaging 1.9% of annual revenues. For small and medium companies (SMEs), a consultancy called RSJ crunched the data and found the average cost of compliance for SMEs was as high as 5.2% of annual revenues.  That’s quite high.

Future and ongoing costs are estimated to the European Commission to average 0.4% of annual revenues.  These costs are due, in part, to increased administration and testing for compliance, the use of more expensive lead-free solder, the higher cost to manufacture lead-free components, and the lengthy exemption process.

4. Are there environmental benefits to RoHS? There are measurable environmental benefits to a well-executed and enforced RoHS program. Such environmental benefits include:

•    reduction of lead (Pb) use in products by 82,700 tons in the EU
•    reduction of cadmium (Cd) use in products by 14,200 tons
•    reduction of mercury (Hg) use in products by 9,500 tons due to changes in copiers and fluorescent light bulbs
•    reduction of mercury in waste streams by 6,900 tons

5. What are the big-picture benefits? Much analysis has been done leading to projections on the potential benefits of RoHS on a global scale.  Reports seems to show that primary benefits include:

•    increase of communication across the supply chain serves as a platform for the implementation of REACH and other initiatives
•    less leaching in landfills because WEEE contains less hazardous material
•    the use of lead-free solder increases the incentive to recycle because it contains silver and gold
•    the push for other countries and industries, such as aerospace and IT, to move to cleaner processes and reduced use of hazardous materials.

Which Surface is Best?

RoHS has been in effect since, when, 2006? Pretty close to five years now. It’s been around long enough that there’s even talk of follow-on legislation. All of the PCB fabricators have pretty much figured out how to deal with RoHS. There are Pb-free versions of every PCB finish at this point. But, we still get questions about the best choice of PCB finish.

I don’t think industry has selected one PCB finish as the “standard” preferred choice. A lot depends on the application and the componentry being used. For large parts, HASL, leaded or lead-free, is a good choice. It’s inexpensive and works well. For leaded work, HASL still seems to be the most common finish. We don’t see quite so much Pb -free HASL, though.

If you’re working with small geometry parts, then you really need to go to immersion silver or ENIG. The consistently flat surface of those finishes will help keep the small parts on the pads where they belong. The disadvantage of silver is that it requires a little more care in handling and storage. It can oxidize which will make soldering more difficult. ENIG is more expensive, but it tends to work real well and is easier to store. Fingerprints can be a problem though. We’ve seen the oils from a fingerprint essentially etch the gold surface off. Weird.

OSP becomes a viable choice with high-volume, cost critical applications. It used to be very sensitive to storage and handling, but has gotten a lot better over the last few years. We don’t see immersion tin much at all. It apparently is harsher on the environment to produce than other finishes.

All that makes it more understandable that we don’t have one preferred finish. It seems confusing, but really it’s not that different than any other product. There certainly isn’t just one preferred style of tire for all motor vehicles.

Duane Benson
Gotta have those monster truck tires if you live in Kelso

Tin Din


Many people responded to my recent post on tin whiskers. A few pointed out that the recent NASA report on the Toyota Unintended Acceleration Issue discussed numerous tin whiskers that were found, one implicated in a failure. The tin whiskers were emanating from tin plating.

We don’t know, however, if tin whisker mitigation techniques were used. In a mission-critical application, such as this, it would appear unwise to use RoHS-compliant electronics, especially since they are not required for automobiles. In other words, autos are exempt from RoHS. Let me be very clear: from a tin whisker perspective, I am uncomfortable with RoHS-compliant tin plating in mission-critical applications. Much more work needs to be done before such tin plating should be used in mission critical applications. In applications where RoHS-compliant electronics cannot be avoided, all tin whisker mitigation techniques should be employed, including conformal coatings.

In addition, in response to my post, a number of people pointed out the difficulty of proving a tin whisker fail and the reluctance of any manufacturer to admit that their products had them.

But my quest remains unfulfilled; the question remains:

“[W]ho knows of any verified tin whisker fails when tin whisker mitigation techniques where used? Tin whisker mitigation techniques typically use 2% bismuth or antimony in the tin, assure that the tin has a matte finish and use a nickel strike plating between the copper and the tin to minimize copper diffusion into the tin.”

Restated, here is my point.  Since RoHS, quite a few people take a position something like this: With RoHS-compliant assembly, even the world of non-mission critical electronics is at considerable risk of numerous catastrophic failures, due to tin whiskers, that will cost hundreds of billions of dollars.

I still maintain, that with mitigation techniques, such as recommended by iNEMI, tin whisker control, for non-critical electronics, can be manageable. Non mission critical electronics is about 80% of the $1.5 trillion of the electronics industry.

As I pack up to leave my office today at Thayer Engineering School at Dartmouth, I am across the aisle from the chaps that provide our computers and IT support.  They buy millions of dollars of electronics a year.  In chatting with them they state two things:

1. They have noted no difference in electronics reliability since RoHS implementation, nearly five years ago.
2. On the very rare occasion that they get an electronics failure, it is almost always a hard drive.

Bottom line: Except for hard drives, modern electronics are very reliable for their use life.

I expect my quest will uncover some tin whisker fails, even with mitigation, but the fails will most likely be isolated and not a significant threat to the industry at large.


Dr. Ron

P.S. The image is from Dr. Henning Leidecker of NASA, one of the world’s leading tin whisker experts.

Questions on Tin Whiskers


In a recent post, I shared my perspective on the pluses, minuses and neutral aspects of lead-free solder assembly. In the minus category, I listed tin whiskers. A few people commented that tin whiskers were the biggest concern in lead-free assembly. I have trouble understanding this perspective. I’m not saying these folks are wrong, just that I don’t understand their viewpoint.

First, let me say that I appreciate the concern for tin whiskers in mission critical electronics such as military, aerospace and medical. I am also sympathetic to the fact that, even though these types of electronics are exempt from RoHS, they may have to use RoHS compliant products because non-RoHS compliant products may not be available.

When I discuss the topic of tin whiskers, people will point me to NASA’s tin whisker failures website . However, when one goes to the site, there are only about twenty tin whisker fails referenced, many due to bright tin plate. Bright tin plate should never be used in mission critical electronics as it is virtually assured of producing tin whiskers. In addition, many of the articles referenced do not talk about tin whisker fails. Few if any fails are discussed relevant to RoHS (i.e. almost all fails discussed are prior to July 2006.)

I do not want to minimize the significance of tin whisker fails, some of them cost 100s of millions of dollars (e.g., satellite failures). In addition, there have been a few papers that have discussed the formation of tin whiskers even if mitigation techniques are used. Tin whiskers clearly can cause problems, but do not appear to be common, especially if mitigation techniques are used.

So here is my question, who knows of any verified tin whisker fails when tin whisker mitigation techniques were used? Tin whisker mitigation techniques typically use 2% bismuth or antimony in the tin, assure that the tin has a matte finish and use a nickel strike plating between the copper and the tin to minimize copper diffusion into the tin.

Surely if tin whiskers are a major concern, there should be many fails in the over $3 trillion worth of RoHS compliant electronics manufactured since July 2006.


Dr. Ron

European Agencies Ban Six Chemicals

In REACH and chemicals news, it was announced in Europe that six dangerous substances are to be phased out. This means that manufacturers who use these chemicals in their products — or have absorbed them somewhere in their supply chain — will have to:

a) know about those offending product ingredients, and

b) find replacement raw materials if the company is to conduct business in Europe legally.

The Commission decision follows the successful first phase of REACH’s registration and notification of chemicals. It’s all a part of REACH, Europe’s initiative to make the use of chemicals safer.

European Commission Vice President Antonio Tajani said, “Today’s decision is an example of the successful implementation of REACH and of how sustainability can be combined with competitiveness. It will encourage industry to develop alternatives and foster innovation.”

What it means is that six substances of very high concern — also known as SVHCs — have been moved from the candidate list to the authorization list, known as Annex XIV, under the EU’s REACH regulation. Annex XIV is like chemical-Alcatraz, substances there cannot be placed on the market or used unless they get a special clearance from the Agency and authorisation is granted for a specific use. All SVHC listings, selections and classifications are based on recommendations made by the European Chemicals Agency (ECHA).

The following six chemical substances of very high concern are the first entrants in the Annex XIV:

1. 5-ter-butyl-2,4,6-trinito-m-xylene (musk xylene)

2. 4,4′-diaminodiphenylmethane (MDA)

3. hexabromocyclododecane (HBCDD)

4. bis(2-ethylexyl) phthalate (DEHP)

5. benzyl butyl phthalate (BBP)

6. dibutyl phthalate (DBP)

If your company uses any of these substances – even in tiny quanitites – or if these substances appear magically in your product from a mysterious supply chain source – a timetable for substitution will have to be submitted. These six substances have been determined to be either carcinogenic, toxic for reproduction or persistent in the environment and to accumulate in living organisms, and will be banned within the next three to five years.

Environment Commissioner Janez Potonik said: “Chemicals are everywhere in the modern world and some of them can be very dangerous. Today’s decision is an important step towards better protecting our health and the environment.”

Additional substances will be added to Annex XIV in the future.

The Commission also says it will put forth a greater number of known substances of very high concern for inclusion in the candidate list. The Commission and the European Chemicals Agency say they are fully committed to achieve this goal, and are expecting the “active engagement of the Member States.”

SVHC background. As we’ve reported previously in this blog, the SVHC list is simply a list of Substances of Very High Concern. “Only the European community could come up with such a tactful term for ‘highly toxic stuff,'” as a recent article in Environmental Leader put it.

By 2012, over 165 substances are expected to be listed on the SVHC candidate list. The list includes substances which are:

* Carcinogenic, Mutagenic or toxic to Reproduction

* Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB) (defined by REACH criteria), and/or

* Identified as causing probable serious effects to humans or the environment of an equivalent level of concern as those above, e.g. endocrine disrupters — for reference, in the US there are 134 suspected endocrine disruptors.

The latest SVHC candidate list is online here at the ECHA site, and if that site is down — as it often seems to be — go to the June 2010 SVHC candidate list hosted by Actio.

RoHS Recast of November 2010

The consolidated text of the Restriction of Hazardous Substances (RoHS) Recast has been adopted by the European Commission.  On Nov. 24, the European Parliament’s environment committee adopted a compromise deal on updating existing legislation on the Restriction of Hazardous Substances (RoHS) in electronic and electrical equipment.  In an overwhelming margin, 640 votes were in favor, three against and 12 abstained.

The RoHS Directive will apply to more types of electronic and electrical equipment, including mechanized toys and lab equipment. This update to EU legislation notes a likely forthcoming review that would consider adding new substances to the current blacklist.

The current RoHS blacklist is as follows:

The RoHS Recast is still subject to further processes prior to final publication in the OJEC, the Official Journal of the European Community.  One aspect of that is confirmation by the European Parliament.

The National Measurement Office of the U.K. is responsible for enforcing the implemented RoHS Regulations only and is not directly involved in this process. They are providing advice and guidance on the future implementation in the meantime until the final version is published.  Advice and guidance is based on the most up to date information available at the time it is given.

Policy questions should be directed to BIS / the European Commission.Commission Decision 2010/571/EU

Exemptions under RoHS recast

Here is what you need to know about exemptions so far.

1.There are no exemptions from RoHS Regulations for products containing either PBB or PBDE.
2.There is one exemption for products containing hexavalent chromium.
3.There are six exemptions for products containing cadmium.
4.There are about 35 exemptions for products containing either mercury or lead.

For a full list of exemptions, click here to go straight to the official site.

Here is some extra help in the form of Guidance from the RoHS site in the UK.  We’ll be sure to post breaking news on this subject as events warrant.

China RoHS Regulation Overview

China RoHS phase I entered into force in 2007.  Phase II hasn’t really fired up yet.  MIIT – which is China’s Ministry of Industry and Information Technology — has indicated that RoHS 2 will be notified to the World Trade Organization (WTO) Technical Barriers to Trade (TBT) Committee following the current public comment period, as reported by Holland & Knight; that period ended without ado in August 2010.  The stated MIIT goal is to finalize RoHS 2 by the end of 2010. It is possible, per recent MIIT feedback, that MIIT will endeavor to have RoHS 2 enter into effect within one year of promulgation.

This means that if RoHS 2 were finalized by the end of 2010, we could possibly see RoHS 2 in effect – with labeling and information disclosure requirements applicable to the new scope of products – by the end of 2011 or early 2012.  Interestingly, Taiwan put up a new web site earlier this year to present an English-speaking version of its toxic substances control initiatives and laws.  And China released an updated version of its REACH-like chemical law earlier this year.
One requirement of China RoHS Phase I was that companies indicate on product labels whether a product contain specific restricted materials. The second phase will restrict specific substances in products.  In fact, according to China RoHS, all items shipped to China must be marked to indicate whether items contained therein are compliant or noncompliant with China RoHS.  No small order.

The Electronic Information Products (EIP) logo or other label is used to mark parts and assemblies that do not contain unacceptable amounts of substances identified by the regulations, and that are environmentally safe. (Units that do contain hazardous substances are marked with the EIP logo including an Environment Friendly Use Period [EFUP] value in years.)

There are six substances now considered environmentally hazardous by China RoHS:

* Lead
* Mercury
* Cadmium
* Hexavalent Chromium
* Polybrominated Biphenyls
* Polybrominated Diphenyl Ethers

EU RoHS vs. China RoHS. In 2006, the China’s Ministry of Industry and Information Technology or MIIT circulated the long-awaited “Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation” (usually called “China RoHS”). China RoHS was developed separately from the EU regulations and is, as written, more strict in many ways. Manufacturers, importers, and some retailers fall under its scope.

China RoHS is similar to EU RoHS in that it restricts certain hazardous substances in consumer products and in packaging materials. However, the China RoHS is different from its EU counterpart in a few significant ways.

China RoHS takes on:

  1. automotive medical devices
  2. manufacturing equipment
  3. components
  4. electronics
  5. radar equipment
  6. certain raw materials
  7. packaging materials

However, China RoHS doesn’t take on home appliances and toys (although components of these products often have to comply).
China RoHS labels. However, the exact time-frame for this second phase has not yet been revealed. So far, there are four types of marks or labels required on products:

  1. A label indicating whether any of the six hazardous substances – lead, mercury, cadmium, hexavalent chromium, PBB, or PBDE – are present in the product. If they are present, another label is needed that indicates the “Environment-Friendly Use Period” (EFUP) – the date until which the hazardous substances will not leak or cause environmental pollution.
  2. A table in the manual, packaging, or documentation of the product that shows which hazardous materials are in the product and which components contain the materials. This is a much stricter requirement than the EU RoHS and may require additional testing and product research to determine.
  3. The type of packaging material used needs to be described on the outside packaging.
  4. If a EFUP label is needed, a date of manufacture must be clearly marked on the product.

There are differences between the EU and China RoHS regulations. The China regulations make everyone in the supply chain responsible for noncompliance, while only importers, manufacturers and some retailers are subject to penalties in the EU version. The China RoHS also requires more disclosure – the Certificates of Compliance from suppliers adequate under EU regulations may not be enough. If you ship affected products into China, the product will need to be tested by one of the approved labs in China and will need CCC accreditation (China Compulsory Certification). Testing for compliance might be very extensive, too; you may need to test not only every component of your product, but also the materials in every component.

Some companies are wondering if China RoHS will really be enforced. China’s record of enforcing anti-counterfeiting and intellectual property laws, for instance, isn’t the highest rated in the global landscape. And yet, it’s risky to assume that China RoHS won’t be enforced. China RoHS is written as more strict than its EU counterpart — and enforcement is random — but how thoroughly it is thus far being enforced is difficult to assess.

Timing of China RoHS Phase II. The first phase of China RoHS compliance – a phase which involves “mark and disclosure” processes for products – was implemented in February 2007. China’s Ministry of Information Industry (MII) is defining RoHS compliance in that country and may head the RoHS compliance testing. So far, the MII has not mentioned any exemptions for RoHS compliance, which means that medical and military equipment may also be tested and forced to comply with RoHS definitions.

It looks as though China will define RoHS compliance differently than the EU.  China requires all components and products that meet RoHS compliance regulations to carry a logo – a green “e” in a circle. Products and components which fail to meet RoHS compliance regulations will carry a different logo and are required to clearly list all the hazardous substances in the product. Each product not meeting RoHS compliance definitions also needs to list its Environmental Protection Use Period (EPUP), or the number of years that the hazardous substances will not leak or cause any damage or injury (under normal use of the product).

The sheer size of the Chinese tech market will make training, compliance testing, and enforcement challenging.