The European Commission has now published ERA’s report concerning the possible inclusion of Categories 8 and 9 (medical and monitoring/control equipment) within the scope of the RoHS Directive. At present RoHS applies to mostly consumer and IT equipment but Categories 8 and 9 were explicitly excluded from scope but with the intention of including them at some point. ERA’s report marks the first point in this process.

The markets for medical and monitoring/control instruments are quite distinct from consumer electrical and electronic products. They are frequently characterised by small numbers of units sold (sometimes only 1 or 2 a year), long product design lifetimes (over 15 years is not uncommon), exacting technical specifications and protracted and expensive qualification. All these parameters have a critical effect on how, if and when they can be included in the scope of RoHS without exacting a heavy toll on industry or affecting the availability of equipment to end users.

ERA’s report considers the rationale and effects of three possible options:
	To continue to exclude Categories 8 and 9 and carry out another review in several years time.
	To continue to exclude Categories 8 and 9 but encourage eco-design.
	To include Category 8 and 9 products within the scope of RoHS while allowing a number of exemptions either:
	-	from a single specified date; or
	-	from a number of different specified dates depending on the type of equipment.

The report concludes that it is possible to include these categories in the scope of RoHS provided that producers are allowed sufficient time for product and component redesign and to obtain approvals. It recommends that these categories should be brought in scope from 2012 except for in-vitro diagnostic equipment (include from 2016), industrial test and measurement instruments (include from 2016 or possibly 2018) and active implanted medical devices (exclude permanently or delay inclusion until 2020). The report also makes recommendations on clarification of the scope of Categories 8 and 9, the validity of over 35 exemptions and many other matters of critical interest to the electrical products supply chain.

ERA’s report provides the input to the next part of the process, an impact assessment to be carried out by the EC. Following this the EC will make proposals regarding revision of the RoHS Directive. There is no established timetable but it is thought that the earliest date by which the Directive can be amended is 2010.

For more information please contact chris.robertson@era.co.uk or
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About ERA Technology
ERA Technology works at the leading edge of many advanced technologies. The business was founded in 1920 and today provides specialist, high value-added, technology-based services including design and development, testing, assessment and expert advice.

The company has built an international reputation for technical expertise through constant innovation at the leading edge of technology. ERA's services reduce technical and commercial risk, improve the operational performance of engineering infrastructure assets, and enhance the competitiveness of products and systems.

ERA Technology is a Cobham plc company.