1. RoHS Showing Relentless Growth
The pace of growth of RoHS (Restriction of Hazardous Substances) regulation in 2017 was unabated, and looks set to continue for 2018 as many countries implement RoHS-like regulation.
Indications are that 2018 will be the year of Brazil RoHS - in a press release dated 26 December, Brazil's Ministry of Environment (MMA) revealed that RoHS legislation is in the preparation phase and a proposal is expected to be released this year.
In the United Arab Emirates, from 1 January restrictions on electrical and electronic equipment (EEE) commenced for lead, mercury, cadmium, hexavalent chromium, PBB and PBDE, other than equipment listed in Category 11 (Other EEE), including cables or spare parts for the repair, the reuse, the updating of functionalities or upgrading of capacity of EEE.
This came as part of a global spurt of RoHS regulations spanning from the Ukraine to Taiwan and China, and Bangladesh to the Eurasian Economic Union (EEU).
With respect to EU RoHS, following the much-anticipated publication by the EU Commission in September of eight draft delegated directives recommending the renewal of exemptions, industry can expect these to be finalized in 2018. According to the Commission, additional drafts for Pack 11 renewal are scheduled to be released in the first months of the year.
EU RoHS will continue to mature and remains as the standard for the restriction of hazardous substances worldwide. As the belief in the power of a true Circular Economy grows for both governments and industry, be ready for more changes by the EU Commission to reflect this powerful strategy.
For more details on these changes and their effects on business this year, check out the ‘RoHS Compliance in 2017’ white paper.
2. Expansion of REACH
EU REACH is more of a fact of life for electronics manufacturers than ever with greater clarity around ‘What is an article?’.
The first half of 2018 will be the last phase of the data gathering process on existing substances on the European market, resulting in the most comprehensive chemicals database in the world. This however, will not bring to end the requirements of the REACH regulation.
The registration of substances which are newly imported or produced that are greater than 1 tonne per year, prior to being imported or placed on the market, will continue to apply.
Lead registrants’ will continue to be obliged to update their registration when new information becomes available.
The European Chemicals Agency’s (ECHA) compliance dossier check and substance evaluation coordination will remain, as well as proposals for substance harmonized classification, authorization and restriction activities.
In Turkey, companies will be busy complying with their new REACH regulations, which harmonizes the country’s national legislation on chemicals with that of the EU. The Regulation entered into force on the 23 December 2017, with a number of exceptions and closely reflects the EU model in both form and content.
Asia is also showing its strength in relation to REACH-type regulations with China, Japan and South Korea all making amendments to chemicals and substances legislation.
3. Energy Efficiency, Ecodesign and EcoLabeling Stays Firmly on the Agenda
The topics of energy efficiency, ecodesign and ecolabeling will be keeping many global compliance departments busy for 2018 as these ‘hot areas’ continue to catch the eye of regulators. There is a massive 249 proposed regulations across the globe on these topics and one businesses must keep an eye on (Source: C2P: compliance knowledge management platform).
Those in force and needing immediate response by businesses include the amendment (Resolution No. 450/2017) to Russia’s Energy Efficiency Labelling and Technical Documentation, Government Resolution No. 1222/2009 that came into effect on 1 January 2018. The list of products requiring necessary information on energy efficiency classes contained on energy efficiency labels changed. In addition, extra energy efficiency classes ("A +", "A ++", "A +++") were established to designate the goods with the highest energy efficiency which is significantly higher than that established for class "A".
In addition, the EU’s new Framework for Energy Efficiency Labelling, Regulation (EU) No 2017/1369 is now in force with requirements for EEE manufacturers on marking and labeling, providing product information and registration. With a more robust and enhanced framework, the Regulation has put significant and demanding obligations on suppliers, as well as the abolition of the “+” labeling classes.
4. Growth of Regulations Will Not Slow Down
As countries struggle to deal with challenges such as the effects of increased consumerism, advancing technologies, and climate change there is one certainty for 2018. The regulatory burden on business will continue to increase (see graph below).
Source: C2P, the compliance knowledge management platform. Note: some regulatory topics may be counted in more than one subject area.
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