Question 1

What are the key changes to RoHS lead exemptions?

Accepted Answer

The European Commission has adopted delegated directives to revoke and renew key RoHS lead exemptions, including those for lead as an alloying element in steel, aluminum, and copper, lead in high melting temperature solder, and lead in glass or ceramic components. Some exemptions have been revoked with a phase-out period of 12–18 months, while others have been renewed with a new expiry date of June 30, 2027, or December 31, 2027. These changes could significantly impact global manufacturing supply chains.

Question 2

Who is affected by these changes?

Accepted Answer

Any company placing electrical and electronic products, or their parts, on the market in the European Economic Area (EEA). Affected organizations, including suppliers, need to determine if lead is present in their products or parts and whether they will continue to need these exemptions. Time is limited to transition to lead-free parts or apply for the renewal of necessary exemptions.

Question 3

What actions should companies take to comply with these new regulations?

Accepted Answer

Collaborate with suppliers to gain transparency into the use of lead in partsIdentify which exemptions are used in your supply chain for the use of leadEvaluate whether it’s feasible to transition to lead-free alternativesJoin trade associations or working groups to coordinate exemption renewal applications, especially for those expiring on June 30, 2027. Applications for these must be submitted by December 31, 2025.

Question 4

Who is responsible for ensuring compliance with the EU RoHS Directive?

Accepted Answer

Compliance is the responsibility of manufacturers and importers of electrical and electronic equipment (EEE) into the EU. Manufacturers and importers must self-declare compliance and may face checks or market surveillance by EU member states. If found non-compliant, manufacturers and importers must demonstrate due diligence, including robust communication with suppliers and subcontractors to ensure compliance throughout the manufacturing process.

Question 5

How can Assent’s EU RoHS solution support your proactive compliance efforts?

Accepted Answer

Assent’s EU RoHS solution provides tools to manage compliance, such as:Proactive notifications for RoHS exemption expirationsAutomated product declarations and BOM (bill of material) roll-upsReal-time reporting to monitor compliance statusThese features streamline the compliance process and help producers maintain a strong due diligence record.

Question 6

What is the EU Deforestation Regulation (EUDR) and why does it matter?

Accepted Answer

The EU Deforestation Regulation (EUDR) is a landmark law that prohibits products linked to deforestation from being sold in the EU. It requires manufacturers to perform due diligence to ensure products are:Free from deforestationCompliant with production country lawsSupported by a due diligence statementNon-compliance can result in product bans, legal penalties, and reputational damage, making EUDR adherence critical for companies exporting to or operating within the EU.

Question 7

How does the EU Deforestation Regulation affect supply chain sustainability?

Accepted Answer

EUDR raises the bar on supply chain sustainability by mandating extensive data collection and annual risk assessments. Companies must analyze deforestation risk factors, such as land use, human rights concerns, and traceability to the origin plot. This marks a shift from basic compliance to ongoing, risk-informed due diligence, reshaping responsible sourcing standards.

Question 8

What is a Digital Product Passport (DPP) and how does it support EUDR compliance?

Accepted Answer

A Digital Product Passport (DPP) is a digital record that contains detailed product information, including origin, materials, carbon footprint, and supplier data. While not mandatory under the EUDR, EU digital product passports streamline compliance by:Centralizing traceability dataEnabling faster, more accurate risk assessmentsSupporting proactive regulatory readinessAdopting DPPs gives manufacturers a scalable way to meet today’s EUDR requirements and prepare for future EU sustainability laws.

Question 9

Which products are in scope under the EU Deforestation Regulation?

Accepted Answer

The EUDR applies to both raw commodities and derived goods, including:Commodities: Cattle, cocoa, coffee, oil palm, rubber, soy, woodProducts: Leather, chocolate, palm oil, glycerol, rubber items, pulp, paper goods

Question 10

Why should manufacturers adopt Digital Product Passports now?

Accepted Answer

Proactively integrating digital product passports into compliance programs helps manufacturers:Stay ahead of evolving EU regulations like EUDR and the Ecodesign for Sustainable Products Regulation (ESPR)Increase transparency and audit readinessReduce manual compliance burdens and future proof their operationsWith global regulations trending toward stricter responsible sourcing requirements, DPPs are a strategic investment for long-term compliance and competitive advantage.

Question 11

What is changing with REACH regulations regarding hexavalent chromium (CrVI)?

Accepted Answer

The European Chemicals Agency (ECHA) is expected to move multiple CrVI substances (already classified as REACH SVHCs) from the REACH Authorisation List to the REACH Restricted Substances List (Annex XVII). This means that substances like chromium trioxide, chromic acid, and 12 additional CrVI compounds will no longer require prior approval but will instead be banned from use in products and parts in the EU market. A restriction proposal is expected by April 11, 2025.

Question 12

Why is REACH moving CrVI from authorization to restriction?

Accepted Answer

The current REACH authorization process has failed to keep up with the high volume of industry requests. Instead of the required three-month review period, CrVI authorization requests have taken an average of 14.5 months, leading to annulled decisions, compliance uncertainty, and supply chain disruptions. An EU ombudsman audit found procedural issues and data quality concerns, prompting calls for a more efficient, transparent process. This led to a full restriction as the preferred solution.

Question 13

What will the new hexavalent chrome restriction cover?

Accepted Answer

The expected restriction will likely apply to articles containing CrVI compounds, especially those with components that may come into direct and prolonged contact with the skin. This would expand on the existing restriction under REACH Annex XVII, which currently prohibits leather articles containing CrVI at concentrations of 3 mg/kg (0.0003%) or higher. The new rule could significantly impact industries such as automotive, aerospace, and defense manufacturing.

Question 14

How can manufacturers prepare for the CrVI REACH restriction?

Accepted Answer

Manufacturers should take proactive steps to ensure compliance before the restriction is finalized. This includes:Engaging suppliers to identify any CrVI usage in the supply chainExploring alternative materials and coatings to replace CrVI substancesMonitoring ECHA updates to stay ahead of compliance deadlinesImplementing a REACH compliance strategy to prevent costly disruptions

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Tag: Supply Chain Sustainability Management