By Jeff Shafer
Hundreds, if not thousands of electronic components and products are set to become obsolete when the European Union’s RoHS (Restriction of Hazardous Substances) directive takes effect this July.
Along with its ‘sister’ legislation, Waste Electrical and Electronic Equipment (WEEE), RoHS will be a key driver in changing the way electronic products will be designed, manufactured, and recycled all over the world.
While hundreds of new compliant electronic products are being introduced to the market every month, almost as many are being discontinued. RoHS is providing suppliers with an opportunity to streamline their portfolio of products, but that’s creating numerous new potential problems across the supply chain, such as penalty charges, redesign costs, and lapsed distributor agreements-all of which could cause havoc.
Chain reactions
In short, the RoHS directive will affect suppliers, distributors, and customers alike, and it is important that the entire supply chain is ready for the looming deadline.
Initially, RoHS presents an opportunity for suppliers to decommission slow moving products, and many are taking the chance to streamline their portfolios by discontinuing some of the less popular lines. During this slimming down process some products will inevitably become obsolete as manufacturers choose not to upgrade slower moving products to RoHS compliancy. This could cause confusion among design engineers in terms of sourcing alternative components-a burning issue that will require a thorough strategy to overcome this obstacle.
At the other end of the supply chain, electronic design engineers are managing their inventory much more tightly. Everyone wants to avoid the situation of being left with a storeroom full of non-compliant products come July 1. To this end, some design engineers are temporarily slowing down the design cycle and waiting for compliant components to become available.
Those companies with non-compliant products on their hands after the deadline will be looking to pass them back along the supply chain. This could create a situation of non-compliant products being passed from customer to distributor, and from distributor to supplier-which obviously is what everyone, especially the smaller companies with fewer resources, would like to avoid.
Another hurdle
One big complication with RoHS is that there is no common approach among the E.U. countries as to what constitutes an offense under the legislation. And there never may be one, since that is left up to the individual member states.
Some countries have deemed the very act of putting non-compliant products on the market as a strict liability offense, while others require that some element of negligence must be shown. In spite of these differing views, all agree that it is the producers of finished goods that have to demonstrate compliance to European governmental bodies.
Currently, the United Kingdom (U.K.) is the only E.U. country to include a “due diligence” defense in its local legislation. Due diligence requires that a producer has taken “all reasonable steps” to assure compliance.
While “reasonable steps” will only be clear once actual cases have been tried, the National Weight and Measures Laboratory (NWML)-the RoHS enforcement body in the U.K.-interprets that phrase to mean more than simply accepting certificates of compliance at face value. They have stated that there needs to be a risk assessment of the quality of that information.
Whether the rest of the E.U. countries will follow the U.K.’s lead is debatable, although the European Information Communications Technology Association, (a trade association similar to the Electronics Industry Association in the U.S.), recently proposed a “due diligence approach” toward the enforcement of RoHS.
Supply chain support
Given this challenge, it is vital that suppliers work together with distributors to clearly and accurately communicate transition dates and compliance data to their mutual customers: design engineers and buyers.
Newark InOne has been working closely with our suppliers to continuously collect part-level compliance information. Concurrently, we have worked with our sister distributor in Europe, Farnell InOne, to develop a stringent 10-step process to evaluate and validate that data. Steps include segregating compliant and non-compliant parts in our warehouse, inspecting parts against collected data specs, resolving discrepancies with manufacturers, and notifying customers of status changes.
Additionally, some distributors have implemented a number of tools and services to help engineers and buyers with the entire compliance journey. For example, the content on the dedicated RoHS Express site, www.newarkinone.com/rohs, is organized around the four compliance steps that a company generally follows: Understanding the legislation; identifying RoHS products on their parts lists or bills of material (BOMs); purchasing RoHS products; and then assuring the accuracy of their inventory. Also on this site, users can download a 22-page RoHS legislation and technical manual, securely submit parts lists or BOMs for identification and matching of non-compliant parts to compliant substitutes at no charge, view webinars on lead-free soldering, and link to manufacturers’ RoHS policies.
Online catalogs, such as that available at www.newarkinone.com, are also great resources, offering detailed, up-to-date product information on tens of thousands of available RoHS-compliant parts. On this site, for example, a RoHS filter can be employed to quickly sort through search results, flagging compliant parts with a green spirograph symbol for quick identification. When available, compliant substitutes for non-compliant parts are shown.
To help engineers and buyers keep track of the massive number of products becoming obsolete, distributors can help by notifying customers periodically when a product they purchase is to become obsolete. Customers need to know the number of parts still available for purchase, as well as details about substitute products.
While some aspects of RoHS still remain muddy, it is clear that each link of the supply chain needs to share the responsibility for this directive.
 |
JEFF SHAFER is senior vice president, product, at Newark InOne, 4801 N. Ravenswood, Chicago, IL 60640. Tel: (773) 784-5100; Email: jshafer@newarkinone.com
