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RoHS | July 24, 2007

Norwegian RoHS, 18 substances banned

Norway has notified the WTO of its intention to prohibit 18 substances from consumer goods in Norway - with a few exceptions.
Called the Prohibition on Certain Hazardous Substances in Consumer Products, the name bears more than a passing resemblance to the EU RoHS Directive, Restriction on use of certain Hazardous Substances, and no doubt will be referred to by the acronym PoHS.

Although the legislation will apply only to Norway this is likely to become the new defacto RoHS standard for Electrical and Electronic companies exporting to Europe as few companies will make a
variant of a product solely for one market. The alternative is always there - don't ship to Norway.
The scope is much wider than RoHS. It covers all consumer goods - with a few exceptions. Consumer goods are defined in the draft regulations as “by consumer product what is meant is any product that is intended for consumers or that can reasonably be expected to be used by consumers". This includes item groups such as clothing, bags, construction, toys etc. The regulation does not apply to food products, food packaging, fertilizers, medical equipment and tobacco, as well as means of transport, permanently mounted equipment for means of transport and tyres and similar accessories for means of transport.

The regulation proposes to restrict 18 substances, with only 2 (lead and cadmium) being in common with the generic EU RoHS. The ones that are of relevance to the Electrical and Electronic Industry are:

1.Arsenic (Gallium Arsenide devices),
2. Non reacted TBBPA, (Flame retardant as used in FR4 PCB Substrate)
3. HBCD (flame retardant)
4. DEHP (PVC Plasticiser)
5. Bisphenol A. (monomer used for polycarbonate)
6. Lead (any consumer product not covered by RoHS excluding medical devices)
7. Cadmium (any consumer product not covered by RoHS excluding medical devices)

PoHS will be subservient to most pre-existing regulations including EU RoHS, Batteries and Accumulators Directive and the Packaging Directive. This means that Electrical and Electronic products that fall within scope of EU RoHS do not have to meet the more stringent requirements for lead, but they do need to meet the restrictions of the 16 substances that are not in RoHS. The implication of this is all companies selling into Norway will have to re-source many, if not all Certificates of Compliance. The exception to this is if a company implemented an IPC1752 compliant database in the first place (and was able to source the data).

The limit values, some as low as 25ppm, are applied at homogenous level, in a similar manner to EU RoHS.

The overall comparison to EU RoHS is that:

1. It is much broader, not confined to Electrical and Electronic Equipment
2. More stringent - MCVs as low as 25ppm
3. More elements and substances - 18 compared to 6

The Norwegian proposal is scheduled to be adopted on the 15 December and come into force on January 1 2008. It is presently in the throes of public consultation which comes to an end 1st September 2007. A report then needs to be written and recommendations made to the legislators. Even though the time-line looks short, this is just one country not the whole EU and therefore the legislative wheels can move much faster. It is intended to be implemented as an additional chapter in the Norwegian “Product Regulations" legislation.

Further detailed information, including technical notes and typical applications of the 18 banned substances is available in the PoHS Informational Guidance Notes available from RoHS-International at www.rohs-international.com.

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