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Mike Kirschner is president of Design Chain Associates, LLC, a consulting firm that offers services designed to help electronics OEMs comply with environmental regulations such as the European Union’s (EU’s) Restriction of Hazardous Substances directive (RoHS).
Q: Now that RoHS has gone into effect in the EU, how are companies handling it?
I’d say that little has really changed. We’re not seeing major enforcement enactions that are public anyway. I think most companies did a good job of complying with the requirement and getting non-compliant product through to the channel because as we see, companies did stuff the channel with non-compliant product prior to July 1. A lot of RoHS-compliant product is on the market — there’s even a lot of it on the market here in the U.S. So I think it’s mostly the smaller companies that are still challenged.
Q: Do you think there’s something positive about the way RoHS is forcing companies to gather all this information about their products? Is there a bright side?
I think the bright side is that the industry has been made aware—albeit in a very clumsy manner—that there’s another attribute of their products and the components they use to build those products that is critical to be considered during the product lifecycle. Generally, as an industry we have never considered environment as an attribute and environmental impact as an attribute. When you design a product, you pick suppliers and components based on functional properties, cost, appearance, and other technical and business attributes. You don’t really care how those attributes are achieved, you just care that they are achieved.
I think the industry next has to grapple with how to better integrate environmental requirements and responsibility for the entire lifecycle of the product into the product development process. I think that’s the real critical next step that companies need to take. RoHS is just a single step. The first step.
Q: So it’s a starting point for incorporating environmental attributes in the design process?
Yes. There are a lot of them that need to be considered across the entire product lifecycle when you’re defining and designing an electronic product. You have to consider the types of materials you’re using, you have to consider whether they’re recyclable or not, you have to consider the amount of material you’re using, you have to consider the amount of energy that it takes to build both the components and the products as well as the energy the product is using throughout its entire lifecycle. Those last two or three points are part of a directive coming out of Europe called Energy-using Products, or EuP. It passed last summer.
REACH [Registration, Evaluation, and Authorization of Chemicals] is another regulation that will impact the industry. How it will impact it is not really well understood at this point. It’s still in the legislative process, but we expect that it’ll pass by the end of the year and become law next year throughout Europe. There certainly are people who understand what they have to do, but as you get further away from the chemical industry it becomes less and less clear because it’s really focused on chemical substances.
Q: What about other countries’ regulations, such as China’s? Doesn’t it go in effect next year?
March 1. It’s quite different. The only real similarity it has with RoHS is that it targets the same six classes of substances as RoHS. The scope overlaps with Europe’s scope, and it’s been detailed in excruciating detail, 35 pages of detail. It’s amazing in its breadth.
Q: Does it give limits on those six hazardous substances?
There are no limits yet—that’s one of the key differences. Right now, for March 1 it’s just a disclosure requirement. You have to mark your product and say whether or not it contains any of these six hazardous substances. If it does contain them, you have to say which components contain them. So you have to disclose in a huge long laundry list any of the components that contain any of these six materials. So it’s not good enough to know that a component is RoHS compliant, because that RoHS-compliant component may be compliant because of an exemption.
Next they will be coming up with a material restriction phase of this law, but we don’t know what it will cover or when it will it go into force. They’re going to issue a catalog, probably later this year, that says here are the products that are going to be subject to material restrictions and here is the scope of the restrictions. We expect those to be consistent with Europe’s exemptions, and that the catalog is going to include a timeline for when the restriction goes into force.
Q: Does South Korea also have environmental regulations?
Yes. Their RoHS-like legislation is more like Europe’s. Although again it doesn’t contain a lot of the information needed to actually implement it. It has a narrower scope than Europe’s right now. It goes into effect July 1, 2007. I don’t know yet if the legislation has become law.
Q: Does California have a RoHS-type law?
It’s part of the Electronic Waste Recycling Act, and it goes into effect January 1, 2007.
Q: With all these different laws, what’s your advice to companies selling in a number of countries?
I think the best thing that companies can do is work closely with their sources of supply and their supply chains to understand what the components they use are made of. It takes a lot of effort. We’ve been doing that for about two-and-a-half years, and believe me, it’s not easy work, because there are a lot of companies in the supply chain that won’t give you full information, don’t have the information, or don’t know what they’re talking about. And as you get further down the supply chain, there’s less and less knowledge about what those components should be composed of. We see a lot of disclosures that come down the supply chain that are not accurate.
I think it’s important to emphasize that no matter what part of the electronics industry a company is in, and no matter what types of products it builds, this requirement is not going away. I think it’s really critical for companies to understand and take a strategic approach to environmental compliance. It can be done, and at this point, few enough companies are doing it in enough markets that it can be a competitive advantage.
Q: By being the first to take the environment into consideration during the design process?
Right. There are more and more governments that have green procurement requirements, including our military, so it’s not just the consumer product market that’s interested in green products, it’s businesses and governments as well.