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Are Your Manufacturing Equipment RoHS and REACH Compliant?

To ensure worker, consumer, and environmental safety, the manufacturing industry is one of the most demanding when it comes to following and implementing rules and regulations. Moreover, these rules and regulations are often updated or changed completely, depending on existing scientific information at the time.

Among these sets of rules and regulations are the Restriction of Hazardous Substances Directive (RoHS) and the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) compliance requirements, which were both adoptedby the European Union. RoHS and REACH are easily misunderstood or confused for each other, especially since they both revolve around hazardous substances. Let’s take a look at their primary objectives and the differences between the two.

RoHS Directive

RoHSis an EU directive, which means that member states are required to achieve a result, without requiring a specific set of means to achieve that result. In this case, the expected output is the manufacturing of electronic and electrical equipment without using any of the following hazardous materials: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominateddiphenyl ether. RoHS restrictions may be imposed even if there is no evidence of actual risk of using these materials and even without a complete evaluation of the impacts of using alternatives; it is enough to show the potential risk of these six substances.

The RoHS directive applies to various kinds of equipment, including large and small household appliances; IT and telecommunications equipment like smartphones and similar gadgets; consumer equipment such as those used in the home or office; lighting equipment like lamps and bulbs; electronic and electrical tools; toys, leisure, and sports equipment; medical devices like implants; monitoringinstruments like smoke detectors;motion control systems with motorized linear stages; automatic dispensers; and semiconductor devices.

The covered products in the directive should contain only 1000 ppm of the restricted materials (cadmium and mercury are limited to 100 ppm) by weight. The limits apply to any component that can be separated from finished product, say, cable sheaths, miniature motors, or circuit boards which contain individual parts.

The responsibility of complying with the directive falls upon the company that puts the product in the market, regardless of whether the product is made in any of the EU member states or imported. Full compliance is therefore dependent on the company’s dissemination of the directive to their suppliers and subcontractors.

REACH Regulation

REACH, being a regulation, means it is enforceable as law in all EU member states. REACH focuses on the production and use of chemical substances and to protect both human health and the environment from the impact of such substances. This regulation requires companies that manufacture or import more than one ton of any kind of chemical substance into European Union per year to register the said substances with the European Chemical Agency or ECHA, no matter what kind of product they are manufacturing or importing—even cosmetics.

Similar to RoHS, all parties involved in the manufacturing or importing of products that contain hazardous substances should be aware of the terms of REACH. However, while RoHS specifies six substances, REACH pertains to all chemicals, both individual ingredients and finished products. These include cadmium, lead, mercury, nickel, arsenic, and their compounds; bisphenol A; and hazardous solvents like benzene, cyclohexane, and chloroform. Close to 143,000 chemical substances were pre-registered by December 2008; if a substance is not pre-registered by that period or continue to be unregistered thereafter, it will be marked as illegal.

Another primary difference between RoHS and REACH are their exemptions. RoHS has over 80 exempted applications of the restricted substances, like cadmium in solar panels, limited amounts of mercury in light bulbs that require this element to function, and lead as an alloying element in steel. These exemptions have to be renewed or they will automatically expire after 5 or 7 years. Meanwhile REACH has two categories of exemptions: total exemption, which are materials that are not covered by REACH (such as radioactive materials), and partial exemption, which are substances that don’t have to registered to REACH but may be subject to other obligations under the same.

No matter their differences, the RoHS and REACH have similar goals, which is to ensure that human lives and the environment are protected, even as we continue to pursue technological advancements.

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