Jun 19, 2008 23:05
RoHS legislation provides some reprieve for cadmium and lead in two types of electrical equipment.
On 24 May 2008, the Official Journal published Commission Decision 2008/385/EC amending the restrictions laid out in the law being applied EU-wide, famously referred to simply as the RoHS Directive. Hong Kong's electronics businesses selling their appliances in the EU-27 will already be sufficiently familiar with the stringencies of this demanding legislation (also referenced as Directive 2002/95/EC), which forbids the placing on the market of virtually all electronic and electrical goods if they contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) in greater amounts than those allowed for by the Directive.
It may, nonetheless, come as a relief to Hong Kong's sellers that the Directive does allow for a list of exemptions which, moreover, can be added to, as and when the industry is able to prove to the EU's lawmakers that no viable substitutes exist, or are simply not feasible.
Commission Decision 2008/385/EC acknowledges that certain materials and components containing lead and cadmium should be exempted from the prohibition, since the use of these hazardous substances in those specific materials and components is still unavoidable. Moreover, the substitution for transducers is not yet feasible, and mercury-free flat panel lamps without lead are not available yet, and no viable substitutes for lead oxide are available for two types of tube used in such lamps.
The RoHS Directive is therefore amended, in particular for application of the above-named banned substances in certain HiFi equipment (loudspeakers) and lamps, as follows:
In the Annex to the RoHS Directive (i.e., the Annex which lists the permitted exemptions), the following points 30, 31 and 32 are added:
"30. Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the voice coil in transducers used in high-powered loudspeakers with sound pressure levels of 100 dB (A) and more.
31. Lead in soldering materials in mercury free flat fluorescent lamps (which e.g. are used for liquid crystal displays, design or industrial lighting).
32. Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes."
As for other developments which will eventually have an impact on Hong Kong's exports of electrical and electronic items to the EU, traders should be alerted to a Commission study, initiated at the end of last year, with the objective of giving a thorough analysis of the impacts of the RoHS Directive on the economy and the environment, and to compare the RoHS approach with other approaches used outside of the EU, highlighting advantages and disadvantages.
The aim of the study is also to formulate proposals to revise the Directive. While the ostensible reason provided on the Commission's website is for "improving its cost-effectiveness", it is not far-fetched to assume that pursuant to any future revision, more stringencies may be added. Weight is lent to such a view from a concurrent study, initiated in October last year, entitled "Study on hazardous substances in electrical and electronic equipment, not regulated by the RoHS Directive."
According to the Commission, this latter study is intended to investigate other hazardous substances or materials used in electrical and electronic equipment, how they are managed currently, as well as possible substitutes and the sustainability (environmental, economic, social) characteristics of these other hazardous substances and possible substitutes. Hong Kong's sellers of such equipment may therefore see a catalogue of even more "hazardous substances" added to the already-banned list.
Font: HKTDC
