Posted on 23 Aug, 2018 by Neil Sharp
A responsible Electronics Manufacturing Services (EMS) provider will always make it a priority to keep customers abreast of any industry regulation that could have an impact on the manufacture of their product.
Changes and updates to existing legislation is an ongoing process, and the introduction of new rules is inevitable.
So it’s vital that your assembly partner is committed to staying up to date and to keeping you informed of how these changes may impact on the manufacturing supply chain.
Within Europe, the production of electronic equipment is governed by several key European Union (EU) directives which are designed to regulate the use of chemical substances and the handling of waste products:
- The Restriction of Hazardous Substance Directive (RoHS)
- The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
- The Waste Electrical and Electronic Equipment (WEEE) Directive
Recent developments within Conflict Minerals Legislation, which will come into force in 2021, are also likely to impact on how manufacturers source, and import, certain minerals and metals.
The RoHS Directive
The RoHS Directive covers the manufacture, import and distribution of most electrical and electronic equipment (EEE) and is primarily aimed at regulating levels of hazardous substances such as mercury, lead, cadmium and hexavalent chromium and flame retardants.
Any component or sub-assembly that falls within the scope of the Directive is required to have a Declaration of Conformity, must be accompanied by a supporting technical file that demonstrates compliance, must be appropriately marked (including type, batch, serial number and manufacturer details) and must display the European Conformity (CE) label.
If a product is suspected to be non-compliant then the onus is on your assembly partner to notify the Market Surveillance Authorities (MSAs) and to inform the supply chain. They’re also required to maintain a register of any identified non-conformities, which must be kept for 10 years.
(REACH) is a European Union regulation which came into force in 2007. Its role is to provide a high level of protection for individuals and the environment from the use of chemicals, to educate manufacturers and importers of chemicals in understanding how to manage risks and to allow the free movement of chemicals within the EU market.
By 1 June 2018, any substance that has been pre-registered will need to be registered if its manufacture or import will be in quantities of 1 ton per annum or more.
For assembly providers this means probing their supply chain to ensure that all substances that are key to their business meet the REACH requirements.
Any manufacturer of electrical and electronic equipment responsible for placing products onto the market must abide by the Waste Electrical and Electronic Equipment (WEEE) Regulations, which came into force in 2003.
The regulations aim to increase the treatment and recovery of waste products and to reduce the amount of waste that goes to landfill by setting collection, recycling and recovery targets.
Any company that produces WEEE is required to join an approved producers compliance scheme (PCS) which then acts as a link between producers and environment agencies. Producers are responsible for labelling all products accordingly to allow for correct disposal - and for meeting the cost of the collection and processing of their waste materials.
Conflict Minerals Legislation
Since 2010, American companies have been required to audit their supply chains to ensure that they are not using any conflict minerals – particularly tantalum, gold, tin and tungsten – which originate from the eastern provinces of the Democratic Republic of Congo (DRC) and surrounding areas.
The Organisation for Economic Cooperation and Development (OECD) has written extensively on the subject.
In May 2017 the European Union passed a new regulation (which will come into effect in January 2021) which will stop the export of conflict minerals and metals into the EU and that will require EU companies to demonstrate that they import metals and minerals from responsible sources only.
How your EMS partner can help
A responsible assembly partner, and its procurement team, understands the importance of keeping track of regulations and of having processes in place to take appropriate action when it’s needed.
Before production gets underway, it will scrutinise your bill of materials, to ensure that all of the parts are compliant with the latest regulations. And it will offer guidance (and viable alternatives) if it believes that any item may need to be modified or replaced.
Finally too, if a regulatory change is about to come into effect, your EMS provider will take all necessary measures to keep you informed so that production continues unimpeded and to-plan.
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