Develop a Future-Proofed Restricted Substances List

Regulations always lead to questions about what the regulations mean. It’s an inevitable part of the process. For instance, take the European Union’s ROHS directive, which restricts hazardous substances in electronic products. John Hayes, CTO of H2 Compliance, says there has been confusion about the legislation’s impact on consumable products.

At times, documentation clarifies which products are affected, such as print cartridges. “But if you read the documentation on drill bits, it would indicate that they're captured as well,” says Hayes. “However, I've been doing some work on this with the authorities, and we identified that it doesn't apply to drill bits or cutting wheels or angle grinder, discs and so on.”

So maybe you’re wondering, why does this happen? “When regulations are written, they're typically not written with any product in mind. They're written in a general sense, so interpreting or understanding that regulation is one thing. Applying it to specific product situations is another,” says Hayes.

Digging into regulations is one step on the path to understanding them. For that, it helps to know where to find the information that affects decision-making. It also helps to have a flexible framework for maintaining a restricted substances list. “Once you've developed as system, it should be adaptable to new regulations and change, so that if something comes out of left field, it’s flexible enough to deal with it,” says Hayes.

To help product stewards gather information and apply it to their own circumstances, Hayes will lead The Development of a Restricted Substance List for a Multinational-Multiproduct Organisation, an education session at Stewardship 2015.

Hayes will push for product stewards to think long-term. “If you start looking at the discussions taking place at the UN level, they might not have an impact on national legislations for five to 10 years, but ultimately could have a significant impact,” he says. “Companies need to be future-proofed against regulations to ensure future market access and to minimize rework.”


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