Declarable Substance Testing & Requirements
This began a worldwide trend in many countries, as well as some states in the US, to adopt similar legislation controlling hazardous substances in electrical and electronic goods. Examples include China RoHS, Japan Green, Korea RoHS, and California Prop 65. Due to the many different requirements of such laws, many large companies have created their own Declarable Substance requirements and passed them down to their suppliers. These RoHS testing requirements attempt to be all-encompassing in order to assure that purchased materials and products will meet any requirements in any market around the world. In addition, some industry groups and trade associations have created their own declarable substance testing guidelines and procedures in an attempt to provide some harmonized framework for collecting and managing this information.
However, the many versions of these requirements have created a logistical nightmare for companies trying to prove they sell compliant products. Many of the RoHS testing requirements were established without thought to the technical and analytical issues at hand. In fact, it may not be possible to prove or disprove the presence of many of the substances found on these lists. The absence of approved test methods and lack of certified reference materials makes the reliable analysis of many of these substances in finished goods extremely difficult.
Compounding this problem are new RoHS testing laws on the horizon that will cover even more products. Once again initiating in Europe, laws such as EuP and REACH will require extensive testing of all materials put on the market, regardless of their end use.
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Chemistry Supervisor Jamie Wech, using one of IMR's Ion Chromatographs
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