Restriction of Hazardous Substances (RoHS)

What is RoHS?

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.

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 takes 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

Which companies are affected by the RoHS Directive?

Any business that sells applicable electronic products, sub-assemblies or components directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilize any of the banned materials.

RoHS Steps to Certification

The following steps are involved for RoHS certification.

1. Testing: Either on-site or XRF testing and/or lab phthalate solvent extraction testing is done to determine values of the ten restricted RoHS substances.

2. Process Audit: Inspect all applicable manufacturing processes used towards RoHS compliance on-site.

3. Documentation Review: Review the Bill of Materials, Technical File, assembly drawings, materials declarations, test reports, and conformance/compliance certificates from all suppliers.

  • The Technical File must contain the following:
  • General product description and design structure information
  • Risk assessment of materials, parts and subassemblies
  • Conformity information on materials, parts, and subassemblies
  • Manufacturing documentation and records
  • Harmonized standards, specifications, and conformity procedures

4. Certification Statement: After a successful audit, a RoHS Certificate of Compliance (also known as a Certificate of Conformity or Declaration of Conformity) is issued.

Are RoHS and WEEE related?

Yes. RoHS is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE). WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS compliance is meant to reduce the amount of hazardous chemicals used in electronic manufacturing.

Put another way, RoHS regulates the hazardous substances used in electrical and electronic equipment, while WEEE regulates the disposal of this same equipment.



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