United Arab Emirates (UAE) RoHS Redux

We now have a little more information on UAE RoHS, though it is still confusing and somewhat problematic. Please read my recent article on LinkedIn for more information.

Since that article was written the agency in charge of implementation, Emirates Authority for Standardization and Metrology (ESMA), issued a short “Implementation Guideline” that covers some information that is already clear (i.e. product scope, restricted substances), but also makes further clarifications. For instance,

  • The list of applicable standards has been updated and corrected
  • Implementation timeline is outlined clearly in a table
  • The format of the Declaration of Compliance is defined

However, they appear to have now changed the applicable Conformity Assessment requirements. It was “Form A”, which is similar to “Module A” in the EU 768/2008 Decision applicable to EU RoHS. But now there are two options (neither of which appear to be “Form A”!):

  1. Option 1:
    • Risk assessment to be submitted in case the full product assessment for RoHS is not completed.
    • Applicant submits a full RoHS test report of the complete product (if available). Otherwise three (3) test reports of the critical component to be submitted.
      • How one determines what is “critical” is unclear. And why three test reports?
    • ESMA will verify compliance and issue the certificate
    • Only valid for 1 year; annual renewal is required
  2. Option 2 (Form H/Module H):
    • Similar to EU risk-based requirements, the Applicant submits risk assessment documents based on IEC 63000 (the approved international standard equivalent to EN 50581:2012, the EU’s RoHS risk assessment harmonized standard for RoHS) and IEC 62476:2010, “Guidance for evaluation of product with respect to substance-use restrictions in electrical and electronic products”, a standard I believe few are familiar with.
    • Notified Bodies (those who certify products to meet EMC and Safety requirements) will do the assessment and certification
    • Must place Emirates Quality Mark on product
    • Valid for 3 years

“Notified Bodies” certify against standards and regulatory requirements based on defined and agreed certification protocols. There are no such protocols for IEC 63000 or EN 50581. These bodies, in my experience, are not expert in RoHS. Stay tuned.

New US Consumer Product Safety Commission Flame Retardant User Guideline

On September 28 the Consumer Products Safety Commission issued a guideline calling for manufacturers of electronic products (among others) to stop using additive (“non-polymeric”) organohalogen flame retardants in the enclosures and casings. At issue is the fact that these toxic substances demonstrably migrate from plastics and are detectable in household dust, which leads to exposure to humans and the environment.

These substances, primarily brominated flame retardants (but chlorinated flame retardants are also included in scope), should be replaced with either

  • polymeric (“reactive”) flame retardants
  • non-halogenated flame retardants, such as phosphorus-based (which, as I understand it, requires a change in tooling since the resins are incompatible)
  • metal fire enclosures or other non-flammable technologies
  • product redesign to eliminate the need for flame retardants in plastic enclosures
  • removal of the flame retardants in the cases where it is unnecessary

Review UL 62368-1 Clause 6, Electrically-Caused Fire, to assess.

Note that replacement with other flame retardants may not be a good long-term solution. Phosphorus-based flame retardants have their own set of toxicity issues and, as we learn more, these may become a target for restriction and replacement as well. Polymeric brominated flame retardants, while solving the migration issue, still have the same challenges with end-of-life recyclability and generation of toxic dioxins and furans during the sort of low-temperature incomplete combustion that occurs in illegal recycling activities in China, Africa, India and other places around the world.

Long term, the goal should be to design products without the need for flame-retarded plastics in enclosures (or anywhere, for that matter, but that’s what we get for using fossil-fuel-based materials in high-energy-density applications. To me, moving away from flammable polymerics is one of the Electronics Industry’s true Grand Challenges).

EU RoHS Delegated Directive Drafts

On September 19 the European Commission opened up a stakeholder consultation period on 8 RoHS Exemption Renewal applications. These were part of the Oko-Institut's "Pack 9"; there are still quite a few that are unresolved so expect action from the Commission to draft "Delegated" Directives to address those as well over the next few weeks and months. The exemptions address are listed in the table below along with the proposed replacement wording:

on 8 RoHS Exemption Renewal applications

Proposed expiration dates are listed in the individual Commission Delegated Directive Annexes. The consultation closes on October 17, 2017.

Contact

Visit DCA at www.DesignChainAssociates.com or email me with any questions or comments on this post.

Mike Kirschner


Mike Kirschner

Mike Kirschner is a product environmental compliance and performance expert who provides advice and expertise to manufacturers in a variety of industries. His primary areas of focus include EU RoHS, the impact of EU's REACH regulation on article manufacturers, California’s Safer Consumer Products regulation, and performance standards like IEEE-1680.x for electronics. Mike helps manufacturers define, implement and troubleshoot internal management systems that result in compliant products, and assesses and monitors environmental regulations around the world on their behalf.

He contributed two chapters to the Governance, Risk, and Compliance Handbook, published by Wiley in 2008, and is featured in the critically acclaimed book, Exposed: The Toxic Chemistry of Everyday Products and What's at Stake for American Power. In 2009 he was appointed to the California EPA Department of Toxic Substance Control's Green Ribbon Science Panel. Prior to joining ENVIRON, Mike founded product lifecycle and environmental consultancy Design Chain Associates, LLC (DCA), where he serves as president. Before founding DCA in 2001, Mike spent 20 years in engineering and engineering management roles within the electronics industry with manufacturers including Intel and Compaq. He holds a BS in electrical engineering from Worcester Polytechnic Institute.

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