PoHS Concentration Limits
New Norwegian environmental legislation is being called "Prohibition on Certain Hazardous Substances in Consumer Products." It has been dubbed PoHS by some. Even at this early stage, some ambiguity and contradictory information has emerged.
As with other national regulations, the only official sources are the original acts and regulations published in the native language: Norwegian. The regulating body is the Norwegian Pollution Control Authority. The web site is published in Norwegian with selected portions translated into English and Russian. Translations are provided by the Faculty of Law Library at the University at Oslo and are marked as unofficial.
Looking at the Norwegian Pollution Control Authority web site, we see the structure of the legislation. The foundation document is the Product Control Act. Under this act, is the Product Regulation. PoHS is expected to be a new chapter in the Product Regulation. The text of the new chapter has been published by RoHS International.
My primary concern is with the concentration limits. This was an area of difficulty when EU RoHS first emerged. The phrase "homogeneous materials" generated considerable discussion. The existing product regulation often refers to substances or preparations that contain a percent by weight of the banned substance. This could be interpreted to be the same as homogeneous materials, but some ambiguity remains.
According to RoHS International, the new legislation will be added to the Product Regulation as a new chapter. The text of that chapter uses the phrase "homogeneous materials." This removes most of the ambiguity built into the rest of the regulation, at least for the new chapter.
Some of you may remember the wide variety of interpretations that surrounded "homogeneous materials" in the months leading up to EU RoHS. The same is already happening around PoHS. Even though the new regulation chapter uses this now established definition of concentration limits, at least one article is calculating concentration limits based on finished product weight.
The article, published by Compound Semiconductor.Net, quotes one authority who calculates a concentration limit by dividing the weight of GaAs in a chip by the weight of a cell phone using the chip. The resulting number is below the limit of 0.01 percent, so the product is exempt.
I do not doubt that GaAs will be exempted before the legislation is in force. However, I suspect the decision will have nothing to do with concentration limits calculated from the total weight of a consumer product. This sort of thinking was not valid for EU RoHS, and it will not be valid for PoHS.
The best way to deal with this new legislation is to become informed. Visit the Norwegian Pollution Control Authority web site and RoHS International. Read articles about PoHS - just keep an eye out for misinformation.
For electronics manufacturers, this is a small variation from EU RoHS. It may represent an incremental increase in requirements, once the dust settles. Just build on your existing solutions and compliance will be a snap.
Additional Resources
RoHS International - PoHS info and guidance.
Norwegian Pollution Control Authority, Legislation page.
"Electronics to escape Norway's arsenic purge" - Compliance by miscalculation.
