1-10. The EU RoHS Directive and Challenges for Japanese Exporting Companies

The EU RoHS (Restriction of Hazardous Substances) Directive restricts the use of certain hazardous substances in electrical and electronic equipment. Since its implementation in 2006, the scope of application has been expanded through repeated revisions. Currently, 10 substances are subject to restrictions, including lead, mercury, cadmium, hexavalent chromium, brominated flame retardants (PBB, PBDE), and phthalates, and their inclusion above a certain concentration is prohibited except for specific uses. RoHS compliance is a mandatory requirement for Japanese companies exporting products to the EU market, and non-compliance risks sales suspension, recalls, and fines.

The first challenge Japanese companies face is the complexity of supply chain management. Electrical and electronic products are composed of numerous parts and materials, and it is necessary to prove that all components comply with RoHS regulations. This requires retroactive verification of not only first-tier suppliers, but also second- and third-tier suppliers, and when procurement sources are overseas, differences in language and regulatory awareness become barriers. In many cases, information on chemical substance content from component manufacturers is insufficient, making it impossible to determine RoHS compliance based on the contents of SDSs (Safety Data Sheets) alone.

The second challenge is the preparation of proof of conformity and technical documentation. To comply with the RoHS Directive, a "Declaration of Conformity (DoC)" must be prepared for each product, and compliance with the regulation must be demonstrated along with the CE marking. Companies are also required to retain technical documentation supporting compliance within the company, and must submit it promptly when requested during audits or market surveillance. In Japanese companies, document management is often split between manufacturing sites and quality assurance departments, meaning the necessary evidence is not managed uniformly, which creates a risk of delayed response.

The third challenge is the ability to respond to regulatory changes. The RoHS Directive periodically reviews the substances covered and its scope, and additional restrictions are implemented. For example, four phthalate esters were added in 2019, leaving many Japanese companies scrambling to comply. New hazardous substances are still being considered as candidates, and if companies are unable to quickly keep up with legal changes, their export plans will be hindered. Small and medium-sized enterprises in particular face the challenge of being slow to respond to changes due to a lack of specialized personnel and information gathering systems.

Furthermore, a challenge unique to Japanese companies is the "gap between global procurement and domestic practices." While most transactions in Japan are based on voluntary green procurement guidelines, the EU requires legally binding certification of compliance. If companies do not understand this difference and respond based on traditional domestic standards, they risk encountering problems with customs clearance and sales due to insufficient certification of compliance at the time of export.

To resolve this issue, it is necessary to (1) establish a chemical substance management system that covers the entire supply chain, (2) introduce a centralized management system for documents and evidence, (3) establish a monitoring system for information on regulatory revisions, and (4) strengthen in-house education and information sharing with overseas business partners. RoHS compliance is not just about complying with the law; it is a key factor that determines product reliability and international competitiveness, and is the foundation for sustainable export business for Japanese companies.