What's the impact of legislation on LEDs?

There is a lot of interest in Europe around the impact of legislation on LEDs. Here's a guest post by Gary Nevison, Head of Legislation, Farnell, A trading division of Premier Farnell UK Ltd.

LEDs background
Light emitting diodes or LEDs are increasingly used for lighting applications and in displays. This trend is due to research into brighter and more energy efficient devices that are able to compete with fluorescent lamps that contain small amounts of mercury.

LED lighting is often used in homes, offices and also in vehicles. Several computer manufacturers now offer laptops with LED displays instead of the standard liquid crystal displays (LCDs). A few LED televisions have also been launched recently.

LED displays are more energy efficient than LCDs in laptop PCs because they do not require the conversion of the standard laptop battery voltages to the high voltages required by LCD backlights. LED lighting is still not as energy efficient as fluorescent lighting but researchers expect to be able to attain higher efficiency in the near future.

The development of LED lighting will affect EU legislation in the future in a variety of ways:

RoHS directive
The RoHS directive has three exemptions for mercury in fluorescent lighting: One for compact fluorescent lamps, one for linear lamps and one for special lamps that are used as LCD backlights.

These exemptions are justified because LED lighting is not yet as energy efficient as fluorescent lighting and the availability of LED displays is very limited at present.

RoHS bans mercury because it is very toxic but infrared and red LEDs contain very small amounts of arsenic which is also very toxic and is a carcinogen. Green and yellow LEDs contain phosphides which are also hazardous substances.

The quantities of arsenic or phosphide used are however very much smaller than the amount of mercury in equivalent light output fluorescent lighting. Another issue is that LED lamp production is an energy intensive process that uses very toxic chemicals and so, ideally, a full life cycle assessment of LED lighting compared with fluorescent lighting should be carried out before changes are made to legislation.

It is clear however that in the future, all three of these RoHS exemptions could be repealed when viable mercury-free alternatives are available.

Energy using Products (EuP) directive
The EuP Directive aims to reduce the amount of energy used by electrical equipment and two EU regulations have been adopted that will restrict the supply of less energy efficient lamps.

Tighter restrictions will be imposed at specific dates in the future (1, 3 and 8 years after entry into force) and LEDs will inevitably be one of the alternative options available, especially when their energy efficiency improves.

REACH regulations
REACH imposes a variety of obligations on manufacturers of electrical equipment, particularly on the use of hazardous substances. Some LEDs contain arsenic and this is likely to be classified as a substance of very high concern (SVHC) and included in the Candidate List. Authorisation may also be a requirement for use of arsenic chemicals in the EU and restrictions are also possible, but unlikely.

Is US RoHS the same as EU RoHS?

This is a guest post by Gary Nevison, Head of Legislation, Farnell, A trading division of Premier Farnell UK Ltd.

Firstly, as this new legislation is clearly not “RoHS”, it would be misleading to talk about the US RoHS compliance.

The proposed HR2420 is very different to EU RoHS and although it is claimed to be legislation designed to control hazardous substances, its main aim appears to be preventing US States imposing substance restrictions on product within scope of this legislation. It would introduce some very limited restrictions but the exemptions list is so comprehensive that these would be very few.

So, is this to be the US RoHS that we have been waiting for?

Initially, this might appear to be so, however closer scrutiny of the scope and structure of HR2420 reveals that it is better understood as an effort to limit uncoordinated piecemeal legislation on this issue by individual states.

At present, there is no federal US equivalent to EU RoHS although some states have introduced limited RoHS-like laws.

Many manufacturers would welcome a single, uniform US RoHS law as this would remove the need to meet multiple, changing requirements across US states although others, who predominantly sell internally, may be concerned about this extra restriction.

The main implications of HR2420 are for new chemicals, or major new uses of existing ones, for example products containing substances that are not included in the Toxic Substances Control Act register require certification before they can be imported.

TSCA currently imposes very few restrictions on substances, but it does affect lead-based paints, asbestos and polychlorinated biphenyls.

While the Bill proposes to restrict the same six substances as EU RoHS at the same concentration values in homogeneous materials, there are no apparent equivalents to 17 EU RoHS exemptions, and there is no use of the EU RoHS product categories.

The product scope appears quite different to EU RoHS as it seems to exclude household or consumer products and include products not covered by EU RoHS like electricity distribution equipment.

Another significant difference is that EU RoHS excludes products designed for use with voltages above 1000V AC or 1500V DC, whereas HR2420 has a limit of 300V.

The restrictions would apply to products in scope manufactured after 1 July 2010.

In summary, the scope of the Bill is quite limited, is clearly different to the EU RoHS, and mainly consists of a detailed list of exclusions and exemptions.

As the scope includes many items currently excluded from EU RoHS, the HR2420 does not appear to be a federal RoHS Bill, but more of an attempt to avoid disjointed RoHS requirements emerging for products currently outside, or on the fringe of the scope of EU RoHS.