What should electronics companies be doing to keep up with the fast-moving regulatory landscape?
Q&A with Randy Flinders, GreenSoft Technology
This year’s Chemicals Management for Electronics and Electricals USA conference is fast approaching. Taking place in Boston, USA, on 16-17 September, it will bring together some of the industry’s top representatives to speak about the biggest developments affecting chemicals management professionals working in electronics and electricals.
We took the opportunity to catch up with Randy Flinders, Senior Manager, Product Support at GreenSoft Technology, who will be speaking at the event. He shared his thoughts on a range of issues, including the biggest challenges facing the electronics sector and the evolution of RoHS-like regulations around the world.
Q) Can you set out the three biggest chemical management challenges the electronics sector is facing today?
While each company and its market position is unique, there are a few major challenges which are universal to almost all producers:
• Electronics producers and compliance solution providers will need to finally deal with the ‘Once an Article’ issue. In September of 2015, the EU Court of Justice turned the industry upside down with its “Once an Article, Always an Article” ruling. The industry has largely ignored this ‘Once an Article’ SVHC reporting mandate. However, with the updated Waste Framework Directive requiring that producers start loading this information into a new Echa database as of January 2021, the industry will no longer be able to avoid applying the principles to SVHC calculations and reporting.
• Electronics producers are facing exposure-based requirements. Producers are accustomed to complying with content-based restrictions such as EU RoHS and EU REACH SVHC, where the amount of certain substances are limited or prohibited. But once we move into exposure-based requirements, the waters get murky. California Proposition 65, for example, requires a warning be provided if an unsafe exposure to one of over 800 substances is provided to anyone within California. However, what constitutes unsafe exposure, in many cases, is not defined by the regulation. Electronics producers are finding it very difficult to comply with these subjective requirements.
• The global ‘green’ trend is resulting in an increase of new regulations and requirements. Over the past few years we have seen an increase in global chemicals and substance management requirements. It is clear that emerging and changing requirements are coming at us faster than ever, and this will only increase.
Q) What specific chemical-related issues do you see coming down the road for electronics companies? What should they be considering and how can they prepare for and address these issues?
Simply stated, “How do I get the data my customers need from me?” The days of collecting RoHS declarations and claiming compliance are over. There are hundreds of substances on the California Proposition 65 substance list. There are 197+ SVHCs on the EU REACH candidate list. The AD-DSL and IEC 62474 DSL lists get updated regularly. Companies no longer want compliance statements, they want substance data.
There is a tendency to view substance data collection as secondary to other product design and production efforts but companies are best served by ensuring they direct adequate resources to this effort.
Q) Outside of those adopting RoHS-like regulations, do you see any other countries or regions taking action on hazardous chemicals in electronics and electrical products? Where is this becoming more of a focus?
For the most part, new chemical regulations facing electronics companies are RoHS- or REACH-centric. I don’t see a lot of non-RoHS chemical regulations directly targeting electronics. We have seen an expansion of China RoHS, a proposed Brazil RoHS/ELV regulation, and new RoHS requirements in the UAE. The trend is clearly to target electronics producers with RoHS-style regulations. However, electronics producers should avoid having RoHS tunnel-vision. Other long standing regulations should always be considered, such as EU POPs, California Proposition 65, Canadian Environmental Protection Act and US TSCA.
Q) RoHS-like regulations are being adopted in more and more countries. How do you see RoHS evolving in terms of its scope and geographical reach?
Luckily, so far we have seen that most RoHS-centric regulations are somewhat consistent in their scope. For example, China RoHS and UAE RoHS both restrict the same substances at the same thresholds as EU RoHS. Overall there has been an effort to harmonise RoHS regulations globally. As such, I don’t expect to see much regional divergence in RoHS scope and applicability.
Q) Electronics are becoming more present in a much wider range of products – cars, planes, toys, even furniture. Electronics companies are therefore having to keep up to date with and comply with more sector-specific regulations on chemicals. How can they keep on top of this and ensure compliance?
As the world becomes more connected, electronics suppliers who have historically supported requirements from IT and consumer electronics customers now find they are supporting customers in aerospace, automotive, home appliances, and even furniture and clothing industries. This sometimes can create a problem. For example, processes which have been put in place to address EU RoHS and REACH reporting needs are not adequate to address the AD-DSL reporting requirements from aerospace customers. As producers see their products infiltrate new industries, new compliance processes and resources will need to be brought to bear, bringing a great deal more complexity and cost to compliance efforts.
Q) Why are you looking forward to Chemicals Management for Electronics and Electricals USA 2019?
The opportunity to interact with some of the top individuals in the industry makes this event one of my favourites to participate in. There is no other event bringing representatives from the United Nations Environment Program (UNEP), European Chemicals Agency, and the Responsible Materials Initiative, together with top industry consultants and environmental professionals for the benefit of the electronics industry. The amount of information and expertise present at this event will be astounding!
As for the presentation, I am most looking forward to, like many other attendees, I am anxious to hear Bo Balduyck of Echa [video presentation] update us on the status of the new Waste Framework SVHC database. The database is like the next Star Wars movie – we have seen the promotions, and now we can’t wait to see what it has in store for us! These are exciting days!
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The views expressed in this interview are those of the interviewee and are not necessarily shared by Chemical Watch.