RoHS & EOLV Compliance?
June 1, 2005
WINA considers it to be good business practice to proactively address issues with our partners. The purpose of this communication is to inquire if RoHS and EOLV compliance will be a requirement for your products. If so, WINA is committed to work together with you to establish both short term and long term plans to achieve compliance for the parts we supply to you. The first step is to respond to WINA and let us know whether or not compliance will be required.
What are RoHS and EOVL?
Restriction of Hazardous Substances (EU Directive 2002/95/EC) and End Of Life Vehicles (EU Directive 2000/53/EC) are European Directives aimed to control and eliminate the use of certain substances in Electrical and Electronic Equipment (EEE) and “Vehicle” manufacturing. (See EU Directives WEEE EU 2002/96/EC and EOVL 2000/53/EC). While RoHS/EOVL are European Union directives, other countries/US States are drafting similar legislature which parallels and/or exceeds these requirements. The present deadline for RoHS compliance is July 1, 2006, while the EOVL deadline for compliance is variable.
What are the Restricted Substances?
1.) Lead (Pb)
2.) Mercury (Hg)
3.) Hexavalent Chromium (Cr6)
4.) Cadmium (Cd),
5.) Poly Brominated Bipheynl flame retardants (PBB)
6.) Poly Brominated Dipheynl Ether flame retardants (PBDE).
Some exceptions have been made. See Annex A of EU 2002/95/EC RoHS Directive.
What is the Purpose of these Directives?
The scientific community has concluded that refuse that enters landfills containing these “hazardous substances” will result in long term negative effects to humans and the environment. Because EEE and “vehicles” have relatively short life cycles, these products enter landfills at a very high rate, and therefore have been specifically targeted.
Does your product require RoHS/EOVL Compliance?
It is not possible for WINA to determine whether your products require compliance. This determination needs to be made by our customers. Therefore we suggest that your company conduct a thorough review of these EU Directives and determine if compliance is required.
Are Fasteners affected by RoHS/EOVL?
Yes! If fasteners are specified with an electroplating of zinc, zinc &yellow or cadmium, these parts may not be in compliance. Cadmium is used on fasteners because of its conductivity and corrosion resistant properties and Hexavalant Chromium (Cr6) is used in electroplating zinc as a conversion coating that enhances corrosion resistance. There are alternate finishes and processes which are available but these must be reviewed by your engineering departments for performance and cost impacts. There are also machining steels and flame retardant plastics that must be reviewed for lead and PBB’s and PBDE’s, respectively.
How Should You React?
After you have determined that compliance will or will not be an issue, the most important action your company can take is to communicate, in writing, to your WINNA salesperson of your need for RoHS/EOVL compliance.
Our Action Plan
Once WINA has been informed of your need for RoHS/EOVL compliance, we can identify all compliant and non-compliant part numbers currently in use. Concurrently, we will work with your Engineering department to identify the most effective, feasible, and compliant alternatives. Once compliant alternatives have been decided upon, we must cooperatively develop a reporting and transition plan that may include rework of current inventories to meet your specific deadline for compliance. Our main goal is to keep your assembly lines moving and to avoid supply chain delays. In order to be successful, we need your input. Please respond in writing to your WINA sales representative. Being proactive today will save time and money tomorrow.