Conformity Magazine - December 2008 - (Page 27)

scope of the EIP list must be subject to hazardous substances declaration requirements. Since the EU’s and China’s lists were different, we have seen some approach towards consolidation. The EU is publicly reviewing their exemption categories and asking if these exemptions should be maintained. If products in the categories are made RoHS-compliant for China, shouldn’t they be found to be within the scope of the EU’s RoHS requirements as well? The Impact on Manufacturers From a manufacturer’s perspective, a company making a product for China is probably selling the same product into the EU. Therefore, other countries are benefiting from the China requirements and stating they should enact similar product in-scope inclusions. During the EU’s review, regulators there are looking toward the next three years as product exemptions expire and are not renewed. All of these green initiatives have led manufacturers to pass global material declaration compliance strategies down through their supply chains. They are requiring deeper understanding of the complete chemical composition of all parts, components, and materials in an effort to comply with RoHS and prepare for future SVHC requirements. Suppliers have been required to provide not only certificates of compliance but also supporting evidence like test reports to prove that their products meet RoHS requirements. Yet, there are no assurances from the supply chain. From the time raw materials are received until the time final products are distributed, both procurement and manufacturing has shown the potential to introduce non-compliances, and a balanced process of monitoring and control should be implemented to control such risk. One-time compliance is not the panacea for brand protection. RoHS compliance must be continually validated. The expanding legislation also shows a continuing trend by the world’s governments to “go green.” As a result, more manufacturers should continue to expand their compliance solutions. Every company that sells its electronic products not just in China but globally must therefore find out which specific standards apply to its offerings, and what it must do to ensure that its products are fully compliant with the various green laws. There is no shortcut, and the specifications of each product must be matched carefully to the requirements. That said, there are some general-purpose preparations that companies can make: • Create a compliance plan and a strategy for implementation; • Educate and manage the supply chain; • Collect information from the supply chain; • Verify and validate collected information, and fill in compliance gaps by testing and monitoring; • Store information and frequently audit and update the information from the supply chain; • Execute risk-based assessments to ensure compliance as far as possible. Based on these strategies, companies will meet global compliance requirements, including China’s RoHS. But, returning to the original question, has China’s RoHS been successful and effective? Based on companies meeting its requirements and its impact on other expanding global legislation, we would say yes. As always, there is room for the law, its enforcement, and compliance to continue. But, if even a percentage of products are now compliant, the world is becoming a safer and greener place. Joel Pekay is Intertek’s Global Marketing and Business Development Director for Health and Environmental Services, and can be reached at joel.pekay@intertek.com. FAST Link www.conformity.com/2440 DeCember 2008 Conformity 27 http://www.conformity.com/2440 http://www.citelprotection.com http://www.citelprotection.com

Table of Contents Feed for the Digital Edition of Conformity Magazine - December 2008

Conformity Magazine - December 2008 Contents Editor's Note FCC Warns Regulatory Fee Payers About Potential "Phishing" Commission Prowls the Web to Enforce Its Regulations First DTV Rollout Initiated in Wilmington, NC New Standards List Released for the EU's Directive on the Safety of Toys ESD Association Call for Papers ESDA. JEDEC Announce Standards Development Cooperation Commission Releases Data on Local Telephone Competition The Future of ESD Testing ESD Open Forum Emerging Issues in Standards: China RoHS: One Year and Counting Challenges in Testing: Revisiting 10-Meter and 3-Meter Radiated Emission Measurements Design Fundamentals: Meeting the Shielding Challenges of Injection-Molded Plastics Focus On...Microwave Absorbers Buyer's Guide FDA Recalls Automated External Defibrillators FDA Revises Guidance on Medical Device Tracking Guidance Document Safety of Passive Implants Released FDA Offers Guidance on Marketing Diagnostic Ultrasound Systems EU Commission Issues Correction on Machinery Directive Standards Other CPSC Actions in the News Product Reviews IEC Standards Update UL Standards Update Looking Back: Items from Past Issues of Conformity Advertisers

Conformity Magazine - December 2008

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