China RoHS and beyond – interview with Underwriters Laboratories executive David C. Haataja caught up with Underwriters Laboratories’ David Haataja. Mr. Haataja is vice president and general manager for the company’s restricted substances compliance solutions. He is also vice president for the company’s North American consumer and medical operations. Below are transcripts from that discussion.

VO: What are your thoughts on China RoHS (Restriction of Hazardous Substances) as it compares to EU RoHS?

Haataja: These are just two of the many pieces of legislation enacted globally to curb the use of hazardous substances. China RoHS is more encompassing since virtually all electronic products sold in China must adhere to China RoHS. This includes companies with products that currently have exemptions in the EU such as medical equipment.

China RoHS regulation addresses the same substances; however, what constitutes compliance is quite different. Whereas EU RoHS follows a self-declaration approach, China is clearly going to a compulsory certification requirement. More, all indications so far are that testing and certification must be done by a Chinese operated lab and certifier. There is no clear indication of whether China will accept testing that has already been performed outside of China.

 David C. Haataja
Vice President & General Manager
Restricted Substances Compliance Solutions

Underwriters Laboratories

Standards for testing remain an issue as the international community has yet to publish a standard that is globally accepted. China appears to have adopted, with some changes, the recent work drafted by the Technical Committee of the International Electrotechnical Commission – IEC TC 111, on environmental standardization for electrical and electronic products and systems. We’ll have to wait and see how this turns out once the IEC is done with their standard.

VO: What do you feel are the top five concerns of North American executives regarding European Union (EU) RoHS, today?

Haataja: First and foremost is what constitutes compliance or, put another way, how much due diligence is enough? There are a multitude of the things you can due to satisfy yourself the restricted substances have been controlled, but since there is no definitive document or standard to follow, the question is left open as to how much is enough.

Second is the potential damage to the brand. For example, reliance on an attestation from suppliers that all components are compliant without providing data to support the attestation places a company on dangerous ground. One front-page news story could be devastating.

Third is trepidation about receiving a notice from an enforcement agency requesting technical documentation showing that the producer’s RoHS compliance assurance system is functioning and is effective. What will you send and how fast can you send it?

Fourth is cost and a level playing field. The cost of procuring compliant parts and maintaining that compliance is significant. For products where margins are thin this is especially important. If all producers are doing the same thing there isn’t a competitive edge, which brings us back to the first concern, how much is enough?

And lastly, what’s next in terms of environmental regulations? Designing for the environment is an imperative all executives should be concerned about. This involves so much more than electrical or electronic products and so much more than six substances. Various states in the US, along with developed and developing countries across the globe, are either actively pursuing regulations or enacting regulations. It is only a matter of time until all products and producers will be scrutinized for the impact they have on the environment.

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