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Expert Viewpoint: The RoHS Directive

What it means for the U.S. construction market.

Expert Viewpoint: The RoHS Directive

Jun 1, 2008 12:00 PM,
By Jon Melchin

What it means for the U.S. construction market.

IT and audiovisual products are found everywhere in buildings that strive to blend
cutting-edge technology and design. RoHS and similar regulations profoundly impact these products. Environmental issues in the audiovisual industry, for example, are particularly broad. In California, AA, AAA, and 9V batteries all need to be shipped to a state-licensed recycling center now—throwing them in the trash is not an option anymore.

The booming construction market in the United States has spawned an increased awareness of the environmental impact of today’s new builds. As a result of this surge in construction, there has been widespread adoption by the architectural community, building owners, and construction professionals of design initiatives that produce sustainable, high-performance structures to minimize the negative impact on public health and the environment. Savvy designers are always looking for products or technologies that can contribute to sustainable design when used effectively. Perhaps more significantly, there has been a tremendous amount of recent media attention drawn to environmental issues such as global warming and pollution, opening the eyes of the public and rippling across governmental entities.

The U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) program has given specification guidelines for designers to focus on to achieve green initiatives within the built environment. Reducing environmental impacts, maximizing energy efficiency, and conserving natural resources are all major aspects of LEED. LEED awards points toward multiple levels of green certification for designs that meet the LEED criteria. In one category — Materials and Resources (MR) Credit 4, Recycled Content — LEED allows points for products that are made with pre- and post-consumer materials. Recycling has been mainstream for decades, but a new development is making its way onto the environmentally conscious scene: RoHS (Restriction of Hazardous Substances), a directive established by the European Union that went into effect in July 2006. Although it is still even under the radar of many green specialists in North America, RoHS could soon have substantial impact on the way products are selected for sustainable projects.


RoHS traces its beginning back in 2003, when the European Union (EU) first adopted this directive. Research conducted by the EU’s environmental collaborative in the late 1990s revealed that large amounts of hazardous waste was being dumped into landfills across Western Europe. Shortly thereafter, the collaborative put the ball in motion that would lead to the current RoHS directive. It took effect on July 1, 2006, but it is not a law; it is simply a directive, but a popular one nonetheless. This directive drastically reduces the permitted amounts of six hazardous materials in the manufacture of various types of electronic and electrical equipment.

The WEEE man, which originated in London, is a 23ft.-tall figure composed of 3.3 tons of waste electrical and electronic equipment (WEEE)—the total amount an average person in the United Kingdom is likely to consume in his or her lifetime.

Another recent environmental initiative from the EU is WEEE (Waste Electrical and Electronic Equipment), which took effect in August 2005. It is designed to minimize the waste stream of electrical and electronic equipment, and it complements the EU measures on landfill and waste incineration. Trends in electronic waste generation suggest that increased technological change and decreasing chip costs are driving the development of new products and the obsolescence rates of older electronics. WEEE emphasizes the need for recycling these end-of-life cycle products. The directive imposes the responsibility for the ecological disposal or reuse/refurbishment of such equipment on the manufacturer. Some manufacturers offer leasing and free-of-charge take-back services. According to the EPA, most states in the United States and local municipalities participate in various ecycling programs.

The targeted substances of the EU’s RoHS include the restriction of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ether (PBDE). The maximum concentration levels cannot exceed 0.1 percent by weight per substance. Cadmium is found in certain types of batteries, and it is used in the production of electronic circuit boards. Hexavalent-chromium compounds exist in chromate pigments for dyes, paints, primers, and other decorative or protective coatings. PBB and PBDE are flame retardants used in some plastics, and lead and mercury are often found in electronic and electrical equipment. Trends suggested that the toxic waste stream would only escalate, creating a massive, growing source of contamination. This caused the EU to take measures to clamp down on these hazardous substances.

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Expert Viewpoint: The RoHS Directive

Jun 1, 2008 12:00 PM,
By Jon Melchin

What it means for the U.S. construction market.


At the end of February 2006, China instituted a law titled “Administration on the Control of Pollution Caused by Electronic Information Products.” This law has the same goal as the EU’s RoHS; in fact, it’s commonly referred to as “China RoHS.” One of the key similarities between the EU’s directive and China’s RoHS law is the list of substances that are restricted. Japan, South Korea, Taiwan, Australia, and Canada have adopted or are poised to adopt similar restrictions on electronic and electrical components. Closer to home, nearly 30 states — led by California — are considering RoHS-like restrictions. The California RoHS law, which went into effect in January 2007, prohibits an electronic device that does not minimize the restricted substances to acceptable levels from being sold or offered for sale in the state of California. The California law differs slightly from the EU directive; it applies to “covered electronic devices” (televisions, laptops, CRTs, plasma screens, and DVD players with LCD screens) and restricts only four out of the six substances from the EU: lead, mercury, cadmium, and hexavalent chromium.


Buildings are a significant source of air pollution, greenhouse gas emissions, and other environmental and public health, safety, and welfare issues. While striving for high-performance buildings that achieve sustainability and green initiatives throughout the buildings life cycle, designers have embraced the convergence of technology and design. Today’s new builds incorporate an ever-changing variety of technologically advanced products that facilitate green design efforts and sustainability. Information technology, audiovisual, security, and communication products and systems are prevalent in virtually every building, and they are often considered fundamental within the built environment. These various building components are selected and specified with occupational health, safety, welfare, and productivity in mind, and they are implemented into a design where people and productivity can thrive and building performance is achieved in the most environmentally friendly way possible.

As RoHS becomes more mainstream in the United States, the impact of this globally instituted directive can be of significant importance in our future. Technology products that are included in the RoHS directive include the following:

  • Large appliances (plasma screens, LCD panels, and CRT monitors)
  • Small appliances (DVD and VHS players)
  • IT and telecommunication equipment
  • Consumer equipment
  • Lighting and lighting equipment
  • Electrical and electronic tools
  • Electric light bulbs and luminaries.

Architects, engineers, and interior designers all routinely specify many of the above referenced products when designing a space, and these products are widely used anywhere people get together to learn, work, or meet. Personal, mainframe, and laptop computers; telephones; facsimiles; copying equipment; video cameras; and a wide variety of audiovisual and electronic signal processing equipment fall into categories targeted by RoHS. Now that California is paving the way for these initiatives here at home, the design community, building owners, developers, building product manufacturers, and government agencies are going to need to acknowledge the impact of this directive.


IT and audiovisual products are found everywhere in buildings that strive to blend cutting-edge technology and design. RoHS and similar regulations profoundly impact these products. Environmental issues in the audiovisual industry, for example, are particularly broad. Imagine the amount of electronic equipment that requires batteries — large and small — that can be impacted by RoHS. In California, AA, AAA, and 9V batteries need to be shipped to a state-licensed recycling center now — throwing them in the trash is not an option anymore. Lead solder is widely used in electronic circuitry, and today’s RoHS regulations restrict that process. This is a big concern for many electronics manufacturers because using a lead-free process requires the purchase and installation of new assembly lines, new equipment, and additional personnel and training. While some companies are holding off as long as possible to become compliant, others realize that sooner or later, RoHS is going to impact their business.

Some multidisciplinary architectural firms offer audiovisual and technology consultation in addition to planning, interiors, landscape, and other aspects of design. RTKL, a Baltimore-based architectural firm with locations across the country, is bracing itself for the RoHS impact. Tony Warner, who heads up RTKL’s technology division, is preparing for regulation enforcement. “While our involvement has been minimal on the audiovisual front overseas, where RoHS has had the biggest impact, we have not felt much of its influence here to date. However, given its recent adoption in California, we fully expect to be dealing with this domestically in the immediate future and have been watching developments with a critical eye,” Warner says.

Green initiatives in today’s new builds, and the environmental impact of the growing construction market, means a variety of ecological solutions should be embraced by construction professionals. Green is a red-hot trend, and manufacturers and resellers of audiovisual and electronic equipment need to be aware of the demand that is likely to grow from these sustainable initiatives.

Indeed, RoHS, in one form or another, will soon spread across our country. While some may be reluctant to accept this, the ecological implications of these regulations can only be positive and beneficial to our future and us.

Jon Melchin, CSI, is the director of architectural development for FSR. He works exclusively in support of architects, engineers, and interior designers nationally, facilitating the specification of FSR products, which are RoHS compliant. He is a frequent contributor to various trade publications and conducts a presentation that earns one AIA/CES learning unit. Reach him at [email protected].

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