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RoHS Compliance

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Welcome to RoHS Guide

RoHS stands for Restriction of Hazardous Substances, and impacts the entire electronics industry and many electrical products as well. The original RoHS, also known as Directive 2002/95/EC, originated in the European Union in 2002 and restricts the use of six hazardous materials found in electrical and electronic products. All applicable products in the EU market since July 1, 2006 must pass RoHS compliance.

Directive 2011/65/EU was published in 2011 by the EU, which is known as RoHS-Recast or RoHS 2. RoHS 2 includes a CE-marking directive, with RoHS compliance now being required for CE marking of products. RoHS 2 also added Categories 8 and 9, and has additional compliance recordkeeping requirements.

Directive 2015/863 is known as RoHS 3. RoHS 3 adds four additional restricted substances (phthalates) to the list of six.

Is Your Organization RoHS Compliant for 2021?

Any business that sells applicable electrical or electronic products, equipment, sub-assemblies, cables, components, or spare parts directly to RoHS-directed countries, or sells to resellers, distributors or integrators that in turn sell products to these countries, is impacted if they utilize any of the restricted 10 substances.

With the rapid spread of digitization, the world's production of electrical and electronic devices is exploding. Besides mobile devices, think about the coming wave of IoT, smart home assistants, robots, drones, 3D printers, and home medical devices to all corners of the planet....they are all regulated under RoHS.

EU RoHS specifies maximum levels for the following 10 restricted substances. The first six applied to the original RoHS while the last four were added under RoHS 3, which took effect July 22, 2019.

  • Cadmium (Cd): < 100 ppm
  • Lead (Pb): < 1000 ppm
  • Mercury (Hg): < 1000 ppm
  • Hexavalent Chromium: (Cr VI) < 1000 ppm
  • Polybrominated Biphenyls (PBB): < 1000 ppm
  • Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm
  • Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
  • Benzyl butyl phthalate (BBP): < 1000 ppm
  • Dibutyl phthalate (DBP): < 1000 ppm
  • Diisobutyl phthalate (DIBP): < 1000 ppm

Related to RoHS is WEEE, which stands for Waste from Electrical and Electronic Equipment. WEEE Directive 2002/96/EC mandates the treatment, recovery and recycling of electric and electronic equipment (90% ends up in landfills). All applicable products in the EU market must pass WEEE compliance and carry the 'Wheelie Bin' sticker.

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It’s incredible to realize that many of the household electric and electronic items that we took for granted in the 20th century – such as refrigerators, light bulbs, and electronic children’s toys – contained unacceptably high levels of hazardous substances including lead, mercury, and flame retardants. Occupational exposure was widespread, along with potentially significant harm to the environment when such items ended up in landfills.

While the problem of e-waste shows no signs of abating, many countries have created legislation or issued directives that restrict hazardous substances in electrical and electronic equipment.

One such directive is RoHS (Directive 2002/95/EC), or the directive on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment. Adopted in February 2003 by the European Union, the directive came into effect on July 1, 2006. The scope of the original directive has been updated with additions to the list of restricted substances and electronic equipment that must comply, referred to as RoHS 2 and RoHS 3.

RoHS is also referred to as the 'lead-free directive,' although it restricts nine other substances besides lead in the manufacture of electronic and electrical equipment.

Who Does RoHS Apply To?

RoHS applies to any business selling or distributing electrical and electronic products, sub-assemblies, components or cables to EU countries, or to third parties that in turn sell that businesses’ products to EU countries.


Why is RoHS Important?

By removing or restricting the amount of hazardous substances in electric and electronic equipment, RoHS protects:

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  • The environment and ensuring the substances do not pollute the air, landfills, or waterways
  • Workers from occupational exposure during manufacturing, disposal, and recycling processes

Up to 50 million tons of e-waste is dumped each year in developing countries, exposing workers and the environment to toxic substances such as flame retardants, lead, and mercury.

What Items Does RoHS Apply To?

RoHs applies to:

  • Small household items such as vacuum cleaners
  • Computing and communications equipment including smartphones
  • Consumer electronics
  • Lighting
  • Power tools
  • Toys
  • Sports equipment such as videogames and electric trains
  • Automatic dispensers such as vending machines and ATMs.

What Substances are Restricted by RoHS?

RoHS restricts the use of:

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent chromium (Cr6+))
  • Polybrominated biphenyls (PBB)
  • Polybrominated diphenyl ether (PBDE)
  • Bis(20thylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Seven new substances are currently being considered for future restriction in RoHS 4: Beryllium, Cobalt (dichloride and sulfate), Diantimony trioxide, Indium phosphide, Medium-Chain Chlorinated Paraffins (MCCPs), Nickel (sulfate and sulfamate), and Tetrabromobisphenol A (TBBP-A).

Are Any Substances Exempt from RoHS?


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Select materials are exempt from RoHS restrictions “if it is technically or scientifically impracticable to prohibit the use of certain hazardous substances at present.” This includes applications such as some medical devices, solar panels, and wind turbines. Manufacturers should regularly review the list of exemptions for updates as it is gradually being narrowed by the EU.


How Do Manufacturers Adhere to RoHS?

Letter of RoHS compliance: Organizations can prove their RoHS compliance by issuing a letter of compliance. Third-party testing services are available to test an organization’s products for the presence of restricted materials, or (if present) to test the level of restricted materials. This is known as a Declaration of Conformity for the product; all parties involved in the supply chain are responsible for checking this document.

Labeling: The RoHS 2 directive means manufacturers must display:

  • The CE mark
  • The manufacturer’s name and address
  • A serial or batch number

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Some manufacturers have chosen to adopt labels such as “RoHS compliant,” or green leaves and checkmarks, but RoHS 2 states that the CE mark is the only permitted indication of RoHS compliance. The CE mark is often accompanied by the Waste Electrical and Electronic Equipment Directive (WEEE) mark, which looks like a garbage bin on wheels with a cross through it. WEEE (2002/96/EC) sets recycling and recovery targets for electrical goods.

Record-keeping: Manufacturers must keep formal documentation, including technical records, to demonstrate conformity, such as test data that follows a testing standard. Regulators can request to see information from this file.

Image Credit: Olivier Le Moal / Shutterstock

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