Navigating California's Environmental Regulations: A Deep Dive into California RoHS

The California Restriction of Hazardous Substances (RoHS) regulation came into effect on January 1, 2007, renowned for its progressive environmental policies, and has instituted rigorous regulations to tackle electronic waste and hazardous substances. Among these regulations is the California Restriction of Hazardous Substances (RoHS).

California RoHS Overview:

• Objective: California’s RoHS Law limits the amount of certain hazardous heavy metals in specific waste electronic devices. The California Law prohibits covered electronic devices from being sold in California if the covered electronic device is prohibited for sale under the EU RoHS regulations.

• Applicability: The regulation covers devices featuring a video display larger than four inches diagonally. The EU Directive applies to “electrical and electronic equipment”, whereas California’s RoHS Law only applies to “covered electronic devices”.

California RoHS: Restricted Substance:

• Lead: 0.1% by weight
• Mercury: 0.1% by weight
• Cadmium: 0.01% by weight
• Hexavalent Chromium: 0.1% by weight

California does not restrict PBB and PBDE.

The presence of restricted substances is measured for each homogeneous material contained within the device, not for the device as a whole.

Documentation and Lab Testing Requirements:

• Manufacturers are required to submit annual reports to the California Integrated Waste Management Board (CIWMB) if their covered devices contain restricted substances.
• Lab testing plays a crucial role in identifying the presence of excessive amounts of restricted heavy metals and other substances in electronic products.

California Lighting Efficiency and Toxics Reduction Act Overview:

• Enacted in Addition to RoHS: The Lighting Efficiency and Toxics Reduction Act prohibits the sale and manufacturing of general-purpose lights that contain hazardous substances
• Hazardous Substance Target: The act specifically addresses hazardous substances present in certain general-purpose lights, demonstrating California's commitment to environmental safety.
• Focus on Energy Efficiency: A key emphasis of the act is the promotion of energy-efficient lighting solutions, aligning with broader sustainability goals and efforts to reduce energy consumption.
• Phase-out of Inefficient Alternatives: The legislative intent includes a phased approach to eliminate energy-inefficient alternatives, fostering the adoption of more sustainable lighting technologies.

Covered Electronic Devices under California’s RoHS:

A covered electronic device, as defined by the Department of Toxic Substances Control (DTSC), is identified as hazardous when discarded. Specifically, these devices encompass displays (video) with screens measuring greater than 4 inches diagonally. This includes devices integral to the display and not easily removable.

Categories of Covered Electronic Devices Under RoHS:

• Devices containing Cathode Ray Tubes (CRT devices)
• CRTs (Cathode Ray Tubes)
• Computer monitors equipped with CRTs
• Laptops featuring Liquid Crystal Display (LCD)
• Desktop monitors with Liquid Crystal Display (LCD)
• Televisions with CRTs
• Televisions with Liquid Crystal Display (LCD)
• Plasma televisions
• Portable DVD players with Liquid Crystal Display (LCD)

California RoHS Exemptions:

The California RoHS regulations exempt certain devices from compliance.

The following Product categories are excluded:

• Video Displays in Motor Vehicles:

Includes those incorporated into motor vehicles, along with any parts assembled for or by a vehicle manufacturer (or franchiser).

Replacement parts for video displays in motor vehicles are also exempt.

• Video Displays in Monitoring or Control Devices:

Applies to video displays incorporated in industrial, commercial, or medical monitoring or control devices.

• Video Displays in Household Equipment:

Includes video displays incorporated in household appliances such as washing machines, dryers, refrigerators, microwaves, ovens, dishwashers, and portable air conditioning, dehumidifying, or purifying equipment.

• Devices Ceasing to be Covered:

Exempt any device on or after the date it ceases to be covered by the California RoHS regulations.

Comparison: California RoHS vs. EU RoHS:

Similarities:

• California’s RoHS is closely modeled after the EU Directive 2002/95/EC (RoHS).
• Initial obligations in California RoHS align with the first version of Europe RoHS.

Product Restrictions:

• California prevents the DTSC from restricting products not restricted by the EU.
• Conversely, a product restricted in the EU but not covered by California’s definition of a covered electronic device cannot be prohibited from sale in California.

Exemptions:

• Products exempt from the first EU Directive are also exempt from California’s RoHS, irrespective of substance concentration limits.

Differences:

• California restricts only "covered electronic devices," while EU RoHS covers a broader category of electrical and electronic equipment.
• Polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs), and certain phthalates restricted by EU RoHS are not yet restricted by California’s RoHS.
• In the EU, devices are subject to RoHS regardless of their manufacturing date relative to the Directive's start, whereas in California, covered electronic devices are subject to RoHS only if manufactured on or after the date of issue.

Conclusion

California RoHS stands as a pivotal force in addressing electronic waste and promoting environmental sustainability. It places a responsibility on manufacturers, distributors, retailers, and wholesalers to stay abreast of these regulations, fostering compliance with environmental standards. By adhering to the intricacies of California RoHS, stakeholders contribute to sustainable practices within the state, recognizing the importance of navigating the intricate landscape of environmental regulations governing electronic devices.