RoHS Compliance FAQs

What is RoHS?

What type of products are effected by EU RohS? Will it be illegal in EU to sell new items that aren't EU RoHS compliant? RoHS applies to these products in the EU whether made within the EU or imported. Certain exemptions apply, and these are updated on occasion by the EU.RoHS only applies to 10 categories of electrical products sold or produced in Europe and China. RoHS takes effect on July 1, 2006. Which companies are affected by the RoHS Directive? The directive applies to all products sold in Europe. My products are not currently within the scope of RoHS, will this change? When do products have to be RoHS compliant? Does RoHS apply to prototypes Is there a difference between 'lead-free', 'green' and 'RoHS compliant'? Does the RoHS directive apply to batteries? lead is still allowed in products covered by the directive as long as its concentration is below 0.1%,

RoHS is the acronym for Restriction of Hazardous Substances. RoHS, also known as Directive 2002/95/EC, originated in the European Union and restricts the use of specific hazardous materials found in electrical and electronic products. All applicable products in the EU market after July 1, 2006 must pass RoHS compliance.

What are the restricted materials mandated under RoHS?

The substances banned under RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).

Why is RoHS compliance important?

The restricted materials are hazardous to the environment and pollute landfills, and are dangerous in terms of occupational exposure during manufacturing and recycling.

How are products tested for RoHS compliance?

Portable RoHS analyzers, also known as X-ray fluorescence or XRF metal analyzers, are used for screening and verification of RoHS compliance.

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 restricted materials.

What about RoHS 2?

The proposed changes to the original RoHS Directive in RoHS2 are minor. No additional substances have been added to the six currently restricted. Inclusion of RoHS categories 8 (medical devices) and 9 (control and monitoring instruments) products in RoHS is now proposed, with the proposed dates for inclusion being 2012 or later.

What is WEEE?

WEEE is the acronym for Waste from Electrical and Electronic Equipment. WEEE, also known as Directive 2002/96/EC, mandates the treatment, recovery and recycling of electric and electronic equipment. All applicable products in the EU market after August 13, 2006 must pass WEEE compliance and carry the "Wheelie Bin" sticker. For the complete directive, see Directive 2002/96/EC of the European Parliament.

How are RoHS and WEE related?

WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS compliance dovetails into WEEE by reducing the amount of hazardous chemicals used in electronic manufacture. Put another way, RoHS regulates the hazardous substances used in electrical and electronic equipment, while WEEE regulates the disposal of this same equipment.

I have heard that cutting and welding materials containing Chromium can create Hexavalent Chromium. Is this a problem?

It appears that welding stainless steel or chromium plated steel produces toxic fumes which contain chromium trioxide. This is possible as chromium metal will oxidise if heated and at welding temperature may make a small amount of CrVI. This must form as minute dust particles to exist in the hexavalent state because the oxide (CrO3) is unstable above its melting point, which is 197 deg C, decomposing to trivalent chromium oxide. There will not be Cr6 on the welded stainless steel surface because the steel will be too hot and any CrO3 that is present will decompose to CrIII.

What are the maximum permitted concentrations of the restricted substances?

The maximum concentrations by weight permitted in an homogeneous material are 0.1% for Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr [VI]) and the 2 brominated flame-retardants (PBB & PBDE), and 0.01% for Cadmium (Cd).

How does RoHS affect maintenance and repair?

Non-compliant components can be used to maintain or repair Electrical and Electronic Equipment (see 'What is the definition of EEE?') which was put on the market before 1st July 2006.
Many components will not be available indefinitely in a non-compliant form. It is possible to make an acceptable tin/lead solder joint onto a "lead-free" component. Consequently repair of non-compliant EEE with compliant components should not normally cause any problems.
The repair of non-compliant equipment with lead-free solders should be avoided if possible. Lead-free solders melt at higher temperatures than leaded solders and this may cause problems with existing solder joints and components.
N.B. EEE put on the market after 1st July 2006 should only be repaired using compliant components and lead-free solder if possible.

What types of equipment (EEE) are affected by RoHS?

The RoHS Directive takes its scope from Annex 2 of the WEEE Directive, but excludes 2 categories (Monitoring & Control and Medical devices). The indicative range of affected products is listed below, further guidance has been issued by national bodies responsible for implementing and enforcing the directives on a country by country basis (e.g. BERR and the National Weights and Measures Laboratory in the UK).

Large Household appliances:

Small household appliances:

IT and telecommunications equipment:

Electrical and electronic tools (with the exception of large-scale stationary industrial tools):

Lighting equipment:

Consumer equipment:

Toys, leisure and sports equipment:

How have RoHS & WEEE been implemented?

There is a key difference between the WEEE and RoHS Directives. WEEE specifies minimum standards that each member state must implement but may exceed. RoHS is a single market Directive, which means it must be implemented identically by each member state.

What is the reason for implementing the RoHS Directive?

RoHS should be considered in association with the WEEE Directive. Their objectives are jointly to improve environmental performance at all stages in a product's life cycle. Some of the materials used in electronics can present environmental and health hazards during manufacturing or at 'end of life' disposal. The EU has therefore taken steps to restrict the use of these materials (RoHS) and encourage the safe disposal or re-use of electrical equipment (WEEE).

Who is affected by RoHS?

The effects of RoHS are widespread. Legally it affects anyone who:

Does the RoHS Directive specify how compliant products should be marked?

Unlike the WEEE Directive, RoHS does not specify a 'compliance mark'. A number of manufacturers now indicate compliance on product packaging by using symbols or a suffix to their part number (e.g. PBF, LF, or G).

Which countries are affected by RoHS? Where does the RoHS Directive apply legally?

RoHS is an EU Directive and therefore only legally applies within the EU member states. However RoHS has a wider impact for 2 main reasons:

Consequently RoHS is almost becoming a global "standard" even though it is not a legal requirement outside of the EU.

What is the definition of an 'Homogeneous Material'?

An homogeneous material has been defined as a material which can be mechanically separated from another material (e.g. through scraping or abrasion), without chemical separation. The "tinning" on a component lead is therefore an homogeneous material as it can be separated from the copper wire, whereas the Lead (Pb) contained in a ceramic cannot be separated from the ceramic by mechanical means. Another example of an homogeneous material is the plastic sheath on a cable.

Will I still be able to buy and use non-compliant components??

Non-compliant components may still be used for the repair of 'historic' electrical equipment (i.e. put on the market before 1st July 2006). They may also be used in the manufacture and repair of products outside the scope of RoHS.

The availability of non-compliant components will be dictated by the demand for them. For economic reasons component manufacturers will generally only produce one version of a component. If a significant proportion is used in the manufacture of new electrical equipment then the component is likely to be available only as 'RoHS compliant'. Certain components are only manufactured as spare parts for existing equipment and will therefore never be made compliant.

Distributors may stock supplies of non-compliant components to support applications outside the scope of RoHS. This is likely to be a short-term situation as supplies will generally be limited.

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