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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.

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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

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