The RoHS directive came into effect on 1st July 2006. Four months since the deadline, InAVate asks how the AV industry has responded and how it has been affected.
The RoHS (Regulation of Hazardous Substances) regulations have been the topic of hot debate, and the cause of sleepless nights amongst manufacturers and distributors alike since they were first announced in 2003.
Overnight the EU turned the world of electronics on its head by announcing, amongst other things, that solders used in the manufacture of electronics would not longer be allowed to contain lead, and that components would have to contain restricted amounts of various heavy metals.
Of course this is a vast over simplification of a situation that will probably keep lawyers and other experts in work for the next fifty years. There are countless exemptions, exceptions, and clauses to be scrutinised to make sure that every product available for sale in the European Union is compliant with the regulations.
The basic premise is simple, electronic products that do not fall into one of the exemption brackets, such as military applications, must not contain the listed hazardous substances above the prescribed levels. The accompanying process of ensuring that this is the case, and then proving it, is not so simple, as many have discovered at great expense.
RoHS finally became law on 1st July 2006. Four months on, what’s actually happening? Have the prophets of doom been proven correct or has the AV industry taken things in its stride? A stroll down the value chain reveals a mixed bag of reactions ranging from despair to optimism.
“RoHS has forced us to bring in a new dynamic to our manufacturing, to redesign all of our products, and to renew our ranges,†comments Analog Way’s Paul Schoukroun, VP Sales & Marketing. “The re-examination of our production processes has allowed us to find better subcontractors. By working with companies closer to home we’ve achieved better quality, faster response times and reduced costs.â€
Nick Owen is director of sales for EMEA for Crown International, another company which has had a generally positive experience.
“By the time RoHS kicked in we were already well prepared and ready to go. When we were bought by the Harman group we invested about $7,000,000, this was in the last six years, in modernising the plant. And during this period of modernising the plant we also modernised our product range. Because RoHS was already being discussed at this point, and as we were involved in redesign and redevelopment at the time we were able to build it into our thinking.â€
Kramer’s VP marketing, Ram Nahum stated: “Reorganizing our manufacturing of over 500 products to meet RoHS requirements was a major, major investment of expense, time and talent. Certainly the biggest externally caused upheaval in the history of the company.â€
One concern in all this was that the price of final product would rise and ultimately the end user would pay, however this does not always appear to be the case. Paul Shoukroun stated that efficiencies realised during the redesign of Analog Way’s range have actually led to reduced prices, whilst Rane’s director of marketing Dean Standing commented: “Whilst we haven’t yet increased any prices, in view of the increased costs we’re incurring that’s something that’s likely in the future.â€
TV One’s general manager Steven Mattingly also states that they have so far managed to absorb the cost. This is despite his company’s £350,000 investment in a new, RoHS compliant production line. His biggest concern has been in sourcing components and in supply chain management. However, having been forced into buying an advanced accounting package he feels that the company is far better prepared to deal with similar legislation in the future.
Precisely how much the increases will be if they do emerge is also up for debate. The CIE group’s marketing manager Chris Edwards talks of figures around 6-7% whilst Uwe Röddinger, who is director of sales for German based distributor Comm-Tec mentioned a figure of around 8%.
Uwe also highlights another area of concern - the absence of information from government agencies about precisely how to comply:
“We are suffering from both differences in interpretation and in enforcement in different countries. Even in Germany, nobody really can tell you anything. Very often we have to go to forums and discuss with people who have the same problem, how to do it. There is no official place where you can go and ask ‘here is the problem, tell me what to do’. We are living in a grey area. We try hard to do everything that the directive requires of us, but we are not sure, and there is nobody who can tell me if we are right or wrong.â€
Edwards adds that he’s suffered some appreciable gaps in supply of product. “We’ve had to give up product from certain lines, mainly American manufactured ones. These we’ve been able to replace from European manufacturers. The real challenge has been the Asian suppliers who’ve been very slow to react. I’d say we probably missed out on two-and-a-half month’s supply. RoHS has cost us an appreciable amount of money.â€
The environmentally based legislation will always be seen in some quarters as an unnecessary burden on the free market. The tin-foil hat brigade is out in force, as with any such regulation. Manufacturers in the far east express the opinion that this is a European conspiracy to protect their own market - clearly not the case since it’s been causing European manufacturers and resellers just as much of a head-ache.
Manufacturers and distributors alike are also concerned about enforcement. The general feeling is that our industry has done remarkably well in responding to the demands of governments, in many cases with very little assistance. What they are now concerned about is that those that haven’t been as diligent in their compliance are caught and punished.
For every couple of people prepared to go on the record and state that their products are compliant, there are however a few who will state off the record that they aren’t. Most of those fully intend to become so eventually but are simply not prepared to shut down product supply without appropriate replacement.
There is also credible evidence that the new materials are less reliable, a tacit admission of this by the EU is the exemption of military equipment from the regulations. Anecdotal evidence from distributors also points towards more returns of various product types, although it is likely that these kind of problems will be ironed out as manufacturers perfect their new working practices.
More grievous to the credibility of the whole process, is the accusation that the RoHS directive actually does nothing to better the impact on the environment. Lead-free soldering must be performed at higher temperatures, leading potentially to greater failure rates, and also increasing the energy cost of the process.
A final thought goes to RoHS’s sister directive, the WEEE Directive (Waste Electrical & Electronic Equipment). A large part of the point of the RoHS directive was to make equipment safer to dispose of and assist compliance with WEEE. However, in several countries across the EU, confusion still reigns surrounding WEEE. Notably in the UK there is still little actual infrastructure in place for the disposal of waste equipment. As distributor RW Salt’s MD Craig Buckley put it, “I could have five wireless microphone systems returned to me next week and I’d have no where to dispose of them. Who cares then if they are RoHS compliant or not!â€