|
Norwegian
“Super”RoHS - 18 substances banned
By
Roland Sommer MD RoHS-International
On
the 8th
of June Norway notified the WTO of its intention to prohibit 18
substances from consumer goods in Norway - with a few exceptions.
Called the Prohibition on Certain Hazardous Substances in Consumer
Products, the name bears more than a passing resemblance to the EU
RoHS Directive, Restriction on use of certain Hazardous Substances,
and no doubt will be referred to by the acronym PoHS.
Although
the legislation will apply only to Norway this is likely to become
the new defacto RoHS standard for Electrical and Electronic companies
exporting to Europe as few companies will make a variant of a product
solely for one market. The alternative is always there - don’t
ship to Norway.
The
scope is much wider than RoHS. It covers all consumer goods - with a
few exceptions. Consumer goods are defined in the draft regulations
as “by consumer
product what is meant is any product that is intended for consumers
or that can reasonably be expected to be used by consumers”.
This includes item groups such as clothing, bags, construction, toys
etc. The regulation does not apply to food products, food packaging,
fertilizers, medical equipment and tobacco, as well as means of
transport, permanently mounted equipment for means of transport and
tyres and similar accessories for means of transport.
The
regulation proposes to restrict 18 substances, with only 2 (lead
and cadmium) being in common with the generic EU RoHS. The ones that
are of relevance to the Electrical and Electronic Industry are:
Arsenic
(Gallium Arsenide devices),
Non
reacted TBBPA, (Flame retardant as used in FR4 PCB Substrate)
HBCD
(flame retardant)
DEHP
(PVC Plasticiser)
Bisphenol
A. (monomer used for polycarbonate)
Lead
(any consumer product not covered by RoHS excluding medical devices)
Cadmium
(any consumer product not covered by RoHS excluding medical devices)
PoHS
will be subservient to most pre-existing regulations including EU
RoHS, Batteries and Accumulators Directive and the Packaging
Directive. This means that Electrical and Electronic products that
fall within scope of EU RoHS do not have to meet the more stringent
requirements for lead, but they do need to meet the restrictions of
the 16 substances that are not in RoHS. The implication of this is
all companies selling into Norway will have to re-source many, if not
all Certificates of Compliance. The exception to this is if a company
implemented an IPC1752 compliant database in the first place (and was
able to source the data).
The
limit values, some as low as 25ppm, are applied at homogenous level,
in a similar manner to EU RoHS.
The
overall comparison to EU RoHS is that:
It is much broader, not confined to
Electrical and Electronic Equipment
More
stringent - MCVs as low as 25ppm
More
elements and substances - 18 compared to 6
The
Norwegian proposal is scheduled to be adopted on the 15 December and
come into force on January 1 2008. It is presently in the throes of
public consultation which comes to an end 1st September 2007. A
report then needs to be written and recommendations made to the
legislators. Even though the time-line looks short, this is just one
country not the whole EU and therefore the legislative wheels can
move much faster. It is intended to be implemented as an additional
chapter in the Norwegian “Product Regulations”
legislation.
Further
detailed information, including technical notes and typical
applications of the 18 banned substances is available in the PoHS
Informational Guidance Notes available from RoHS-International at
www.rohs-international.com
Notes
on the Author
Roland
Sommer is Managing Director of RoHS-International and has been
supporting the Industry with the EU and China RoHS legislations since
2003. He has 20 years experience in the electronics industry, and is
ably supported by staff with expertise in chemistry and biology. He
is the author of the highly acclaimed China RoHS Informational
Guidance Notes. Roland can be contacted on
rsommer@rohs-international.com.
| 
