rohs2 and reach: the good, the bad and the ugly of product substance restrictions

Copyright © 2012 Rockwell Automation, Inc. All rights reserved.

RoHS2 & REACHThe good, the bad and the ugly of product substance restrictions

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Cally S. EdgrenProgram Manager, Product Environmental ComplianceRockwell Automation


What are product environmental substance restrictions?

There are many different regulations that restrict hazardous substances from products To date, there are more regulations on

hazardous substances than any other type of product environmental requirement

Some regulations apply to items in “chemical” form, some to articles, some to both (REACH)

Regulations may apply to importation activities, procurement, labeling, transportation, use in facilities, sale to customers, end-of-life, etc.

Regulations are not harmonized between countries, states, regions

Not just a European issue anymore!

Carbon Footprint

Hazardous Materials

E-WasteEnergy Use

REACH

RoHS

WEEE

KyotoTargets

ProductStewardship

PackagingBatteries

Mercury

BPA

PVC

Halogens

Phthalates

Ozone Depleting

Substances

POPS

DMF

CLP

TSCA

China Energy

Efficiency

EU Ecodesign

ELVGreenhouse

Gases

Over 300 new product regulations around the world in 2011 → 46% increase in two years

Latin America and North America have the highest number of proposed laws, the majority dealing with

hazardous substances

PFOS GreenPassport


The good news about substance regulations

What good can come from these restrictions on products? Regulations… Drive companies to eliminate hazardous

substances from their products, resulting in safer products for people and the environment

Provide leverage to collect detailed information from vendors

Level the playing field between companies Provide consistency among data requested by

customers Streamline portfolios by motivating customers

to upgrade to newer technologies as old products become obsolete

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The bad news about substance regulations

To a manufacturer, it may seem that the “bad” side of the regulations outweighs the good

Various RoHS Directives are somewhat harmonized from a design standpoint, but differ greatly from an administrative standpoint

Substance restrictions are driving changes in the supply chain and obsoleting older components, forcing product redesigns

Significant data collection, tracking, and project management activities requires investment by companies and cooperation of suppliers

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Some aspects of product substance restrictions are downright ugly, due to cost and complexity, among other things… Substance restrictions usually apply to an individually-marked product. Therefore

there is no “grandfathering” of existing designs since laws apply to content and not function. This drives redesign or obsolescence of products earlier than originally planned

Regulations are increasing at a faster pace than companies can respond The frequent changes to REACH – every 6 months - makes data collection

difficult and expensive as it forces companies to collect full composition information to be able to react quickly

Conflicting regulations make it difficult to design a single product for sale around the world. Offering different versions of the same product will increase the number of SKUs when we’re trying to reduce

The ugly aspects of substance regulations

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Summary

Regardless of the reasons for substance regulations, the responsibility of manufacturers to understand and provide the content of their products is increasing

Manufacturers who sell product internationally must be willing to make the investment in Product Stewardship functions to meet their legal requirements

The only guarantee in the world of Product Environmental Compliance is that the regulations will continue to grow

Sustainability efforts Pollution control E-waste problems Energy efficiency Carbon & water footprint

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Cally S. [email protected]

rohs2 and reach: the good, the bad and the ugly of product substance restrictions

Engineering