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RoHS

RoHS 2002/95/EC

The Restriction of the use of certain Hazardous Substances specifies maximum levels for use of 6 restricted hazardous substances in the manufacture of various types of Electrical and Electronic Equipment (EEE). RoHS coincides with the WEEE Directive as part of a legislative initiative to solve the problems and risks associated with large amounts of electric waste.

Who does it apply to?

The RoHS Directive applies to those manufacturing, selling, distributing, importing or exporting Electrical and Electronic Equipment (EEE) in the European Union.

What is required of me?

The overall approach to compliance is simply Presumption of Conformity, meaning national authorities will require a self-declaration from producers demonstrating their approach to compliance and data quality systems. If evidence from producers does not assure compliance, a more detailed assessment may follow, including detailed sampling and testing. However, each Member State within the European Union, as well as the 4 EFTA Member States, has different requirements or interpretations of requirements for complying with RoHS which the producer is obliged to know and adhere to.

What does RoHS do?

RoHS specifies the maximum levels for 6 restricted hazardous substances:

  • Lead
  • Mercury
  • Cadmium
  • Hexavalant chromium
  • Polybrominated Biphenyls (PBBs)
  • Polybrominated Diphenyl Ethers (PBDEs)

RoHS also defines 32 Exemptions to Article 4(1). These exemptions apply to products which require amounts of the restricted substances that exceed the restrictions to function (i.e. florescent lamps require an amount of mercury that exceeds the maximum level put in place by RoHS).

EU Commission Decisions

  • 2005/717/EC
  • 2005/747/EC
  • 2006/310/EC
  • 2006/690/EC
  • 2006/691/EC
  • 2006/692/EC
  • 2008/385/EC

RoHS & WEEE

Annex 1 of the WEEE Directive lists 10 categories that define the different groups of Electronic Electric and Electronic Equipment (EEE). These categories are also the groups specified for the RoHS Directive. However, there are 3 categories in the WEEE section that are exempt from RoHS, specifically Category 8, which covers Medical Devices. These products remain exempt from the RoHS directive until 2012 or 2018, depending upon specific product sub-categories and applications. Since the EU has not yet adopted this recommendation, the exact timing of RoHS application to these products remains uncertain.

Category 1: Large and small household appliances

Category 2: IT equipment

Category 3: Telecommunications equipment (infrastructure equipment is exempt from RoHS in some countries)

Category 4: Consumer equipment

Category 5: Lighting equipment (including electric light bulbs and luminaries in households)

Category 6: Electronic and electrical tools

Category 7: Toys, leisure and sports equipment

Category 8: Medical Devices (EXEMPT FROM ROHS)

Category 9: Monitoring and control instruments (exempt from RoHS)

Category 10: Automatic dispensers

RoHS Compliance

  1. Introduce Product
  2. Determine if your product contains more than the specified levels of restricted substances
  3. Determine your compliance systems and data quality systems
  4. Self Declaration
  5. Identify EU Member states requirements for complying with RoHS
  6. Comply with individual members state requirements, including certificate of testing and Bill of Materials

European "Green" Directives and Regulation, like the RoHS, are becoming prevalent and crucial points of interest for anyone involved in placing products on the European market. A comprehensive Environmental Strategy is necessary to study and satisfy the requirements you are constrained to abide by.

Contact us for assistance with compliance.