Are you still clinging to wishful thinking? Perhaps you're unaware that EU countries have already launched investigations into products on the market that comply with the RoHS Directive. Previously, some in the industry believed the RoHS Directive would never be implemented. To date, the UK has conducted over 200 product investigations, and in September of this year, the first case of prosecution for violating the RoHS Directive occurred in the UK. It is understood that Denmark is collaborating with three other Nordic countries (Norway, Sweden, and Finland) on a monitoring operation of 25 consumer products (IT, telecommunications, audio equipment, and toys), with results expected in December 2007. Belgium has also conducted XRF on-site screening of 88 electronic products on the market. The RoHS (2002/95/EC) Directive aims to harmonize the laws of EU member states regarding the restriction of the use of hazardous substances in electronic and electrical equipment, protect human health, and promote the recycling and disposal of waste electronic and electrical equipment to meet environmental requirements.
In fact, EU member states have formed the RoHS Network to exchange experiences and exchange information on the implementation of the RoHS Directive. The current chairman of the RoHS Network is the UK representative. Common implementation practices in various countries include document review, customs inspection upon entry, market purchase or seizure, and even cross-border transfer. Currently, most EU member states have experience in testing low concentrations of heavy metals in packaging materials, but they lack experience with more complex electronic and electrical equipment. Therefore, recent market product testing investigations have tested the handling methods of the responsible agencies in each country. Indeed, the RoHS Directive does not prescribe a "correct method." Both industry and government agencies can only rely on the "RoHS Enforcement Guidance Document" published by the UK Department for Food and Drug Administration (DTI) in May 2006. The investigation process for product compliance with the RoHS Directive is very complex. Testing is an indispensable piece of evidence for product market research (whether XRF or wet chemical analysis). A single non-compliance item often leads to more complex investigations and may even trigger cross-border prosecutions. Choosing which products to investigate is also a skill. Rechargeable screwdrivers are representative of power tools, while inkjet printers, with their numerous mechanical components, are representative of IT equipment. Bright red or yellow remote-controlled cars are essential toys to be inspected. Competitor reports are also an unavoidable part of the investigation.
Establishing market surveillance mechanisms is also urgently needed by various countries. Common practices include on-site screening of products using portable XRF instruments; selecting key products and components (usually those failing XRF scans) for confirmatory analysis by accredited laboratories; and conducting a final evaluation of the results, supplemented by document review. Test reports are the most compelling proof of product compliance with directives. Although IEC 62321 is currently only in draft form, it is a widely recognized analytical standard. Test reports from ISO 17025 laboratories, which demonstrate the ability to analyze RoHS-restricted substances in different materials, are also more readily accepted. Current market research in the UK has identified the following common reasons for product non-compliance: manual welding or cross-contamination on the production line, falsified test reports, and misuse of exclusionary substances. Market surveillance operations in Belgium found that nearly 20% of products failed XRF scans (further investigation is needed to prove the presence of hazardous substances); 27 products were seized for further testing. Further investigation in Belgium revealed that most of the companies audited lacked a comprehensive description of their RoHS compliance systems, meaning they had not implemented a Compliance Assurance System (CAS). Documents useful to auditing agencies might be RoHS compliance certificates or valid test reports proving product conformity. Failure to provide valid and appropriate documentation is tantamount to product non-compliance with the RoHS Directive.
As concluded in this Belgian investigation, the RoHS Directive can be effectively enforced. SGS is one of the world's most experienced laboratories in inspecting electronic and electrical equipment, offering comprehensive services. Whether your product is raw material, electronic component, structural part, or even module or finished product, SGS possesses professional disassembly technology and analytical capabilities. Furthermore, SGS provides a complete suite of green product management consulting services, ensuring your product complies with the directive or the buyer's requirements from cradle to grave (materials, manufacturing, assembly, inspection, packaging, sales, use, collection to waste recycling). The EU will enforce the RoHS Directive more strictly in 2008; don't be complacent!
★ This information is sourced from
