While this regulation arguably covers only manufacturers and importers in the EU, the fact of the matter is that our shops here in North America are producing components (articles) which are incorporated into products in the EU.
Our customers, who specify the use of leaded materials because of the economics of product provision (Leaded materials machine at much higher efficiency rates, lower costs , and seldom need post fabrication operations) are now asking their suppliers for a statement of compliance for the materials that THEY specify us to make THEIR components from. Leaded Steels, Brasses and Aluminums.
Our shops find themselves placed right in the center of a paradox- how can they certify that the material that their customer told them to use is compliant with this new REACH development?
PMPA has analyzed this and provided our members with a guidance document that
Recites the applicable facts and regulatory obligations
Describes where and where not the REACH and other EU regulations apply / might not aply;
Analyzes the duties to our customers
Describes ways to meet our obligations
Provides references for understanding this new development
The world of Precision Machining is characterized by Volatility (this regulation just Arrived), Uncertainty (does this apply to me, I’m an North American, not European manufacturer?) Complexity ( So I need to read the ECHA announcement, The ECHA Substance Support Document, the Annex that covers Lead, and then two more annexes that tell me what I need to do) before I can figure out what I need to do, and Ambiguity (Actually the annexes do not expressly state what the exact deliverable required is).
This VUCA world is made manageable by PMPA regulatory sensemaking to help our shops first recognize, then intelligently understand and manage their risk.
Who is helping you and your team recognize new regulatory risks?
Who is helping you to understand those risks?
Who is providing answers so that you can concentrate on making those critical parts that the world needs, instead of spending three or four man-Days trying to figure it out? (Presuming that you know the issue even exists!)
The current exemptions for Lead in work piece materials for our shops will remain in effect and will not expire until the EU Commission completes the current ongoing review of the applications.
According to Electronics Industry Portal I-Connect007, the EU is unlikely to publish the RoHS exemptions any time soon. Apparently the EU Commission only got around to reviewing the requests last month. December 15, 2016. December 2016!
And they are only now in the process of preparing draft legislation to be sent to the member states for consideration later this year. Later this year! Bottom Line for your precision machining shop and your customers:
A decision on the RoHS exemptions of interest to the precision machining industry is unlikely to be made until Fall of 2017.
The current exemptions for Lead as an alloying element in steel, Lead as an alloying element in aluminum, Lead as an alloying element in copper will remain in effect and will not expire until the EU Commission completes the current ongoing review of the applications.
Here’s the full statement from I-Connect007
“The EU Commission and Member States continue to meet to discuss the disposition of RoHS exemption renewal requests submitted by industry in January 2015. During their December 15, 2016 meeting in Brussels, the experts reviewed requests on: Lead as an alloying element in steel (Annex III exemption 6a); Lead as an alloying element in aluminum (Annex III exemption 6b); Lead as an alloying element in copper (Annex III exemption 6c); Lead in high melting temperature type solders (Annex III exemption 7a); Lead in a glass or ceramic other than dielectric ceramic in capacitors (Annex III exemption 7c-I), jointly with exemption request 2015-1; Lead as activator in the fluorescent powder (Annex III exemption 18b), jointly with exemption request 2015-3; Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors (Annex III exemption 24); and Lead in cermet-based trimmer potentiometer elements (Annex III exemption 34).
“The Commission is currently working on preparing the draft legislative proposals for these and other exemptions) which will be sent to Member States for written consultation. The drafts will likely be published in the spring; final legislative acts could be published in the Official Journal of the EU (OJEU) in the fall at the earliest. Under the EU RoHS2, all existing exemptions were set to expire by July 21, 2016. However, all exemptions for which industry submitted a renewal application will not expire until the EU Commission completes the current ongoing review of the applications.” I-Connect007
(PS. Interesting footnote, I searched for an image of the European Union Commission and found the one above-on a blog about the EU Commissions delay to decide on a VISA issue– last April. Not an isolated case of Bureaucratic delay!)
Photo credit: Pulse Blog
The EU decision on the RoHS 2011 recast appeals for exemptions for leaded materials for machining is almost a year late- the decisions were due from the commission January 21, 2016.
January 21, 2016!
PMPA has reviewed the findings of the study group assigned to review and report on the appeals regarding Lead for machining purposes in Steels, Aluminum, and Copper alloys. If you are a PMPA member, you can get our summary providing the latest status of the RoHS exemptions that affect our shops.The EU is almost a year late with their decision on the exemption appeals for leaded materials for machining under the latest (2011) RoHS recast.
PMPA has posted a summary of the consultants’ findings and their potential impacts on our machining companies for our members information on the PMPA website here.
We have really been challenged by the EU to stay up to date on these exemptions, being almost a year late with the decision certainly keeps the uncertainty high for manufacturers. I wonder if the European Commission is as lenient with the deadlines on the regulated communities as they are for their own?
If you are a PMPA member, you can get the latest Status of the RoHS exemptions that affect our shops here : January 2017 RoHS Exemption Summary Report If you are not a PMPA member, where do you go to stay up to date on regulatory issues that affect your business?