The RoHS Directives (acronym for Restriction of Hazardous Substances) impose restrictions on the use of given dangerous substances in the manufacture of various types of electrical and electronic equipment, with particular reference to heavy metals.
The legislation is closely linked to another European directive, the one concerning the disposal of EEE (Electrical and Electronic Equipment) waste, and in the same way it pays particular attention to the issue of health risks.
The history of RoHS Directives begins in 2002: the first, known as Directive 2002/95 / CE, referred only to 6 substances considered toxic and dangerous.
RoHS compliance became a mandatory requirement on 1 July 2006 for all electrical and electronic products placed on the market.
In 2011 the RoHS 2 directive was published, which imposes the obligation of the CE marking and the EU declaration of conformity for electrical and electronic equipment placed on the market.
The CE marking also implies passing some tests and therefore the presence of a third party, the certifying body, which must be an officially recognized and clearly identifiable subject by the CE certificate.
With Directive 2015/863 entered into force on 22 July 2019, known as RoHS 3, 4 other substances are added to the list of the previous 6.
Below is the list of substances that as of July 2019 are prohibited according to the provisions of RoHS 3 and the maximum concentrations foreseen for some of them:
- Hexavalent chromium (Chromium VI)
- Polybrominated Biphenyls (PBB)
- Polybrominated diphenyl ether (PBDE)
- Bis (2-ethylhexyl) phthalate (DEHP) (0.1%)
- Benzibutyl phthalate (BBP) (0.1%)
- Dibutylphthalate (DBP) (0.1%)
- Diisobutyl phthalate (DIBP) (0.1%)
The countless electrical and electronic devices that have invaded the world and are part of our daily lives, including cell phones, virtual assistants, drones, 3D printers, medical devices, all meet RoHS 3 compliance requirements, whether it is goods produced in EU and non-EU countries.
In particular, the following are subject to the directive:
- Large appliances
- Small appliances
- IT and telecommunications equipment
- Lighting equipment
- Electrical and electronic instruments
- Toys and devices for leisure and sport
- Vending machines
To these categories are added, starting from:
- July 22, 2014: Medical devices, control and monitoring tools
- July 22, 2016: In vitro diagnostic medical devices
- July 22, 2017: Industrial monitoring and control tools
- July 22, 2019: Other electrical and electronic equipment not included in the categories listed above
When it comes to imported products, the obligation to certify their compliance with the RoHS Directive and the CE marking is entirely the responsibility of the person who enters the goods in the European Economic Area, and therefore of the importer.
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But a question that is frequently asked is: how can you be sure that a non-EU supplier has RoHS certification, considering that this type of certification is only provided for the countries of the European Community? Often the foreign manufacturer has a certification relating to a previous production, but this does not guarantee that the products that are commissioned to him will adopt the same standards.
In these cases, but in general for all types of certifications, it is necessary to carry out a conformity test (preferably in the country of production, at an international body) on a sample taken from the production lot. This is the only way to eliminate any doubts about good faith and compliance with directives.
Furthermore, to protect the importer, it is advisable to establish a guaranteed payment method, with a clause that in some way, even only through a documentary check, clearly circumscribes the responsibilities of the foreign producer regarding the RoHS Directive, and does not expose the importer to the risk of paying a down payment without having absolute certainty of the good faith of the manufacturer.
So, as can be seen from these brief considerations on the RoHS Directive, importing some types of products requires a mix of assessments regarding regulations, prices, production quality, payment methods and many other aspects. The help of a consultant could therefore be a valid, if not even necessary, support.
RoHS DIRECTIVE: the harmonization of other similar regulations in the world.
The globalization and the trend to create an unique market in the world, push legislations of varied countries to try to harmonize the rules of security and the space’s safeguard of produced or commercialize products in each countries, this clearly permits to increase excessively necessities’interchangeability.
We have varied RoHS directives in varied countries of the world, later a fast list of countries that have legislated in the field, implementing similar directives to European RoHS directive:
ROHS Regulations – China
In the March 2007 also the China has applied a regulations that limits the use of dangerous material in electronics. The materials must be cointained within 0.1% and the cadmium within 0,01 % are 6:
Lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers (PBDE).
The products subjected to these restrictions are:
- Equipment radar for airs and ships;
- All equipments for communications and the television trasmissions;
- All types of computers;
- All types of electronic devices for domestic use;
- Instruments of electronic misuration;
- Electronic Instruments for professional use;
- Electronic component;
- Other applications in electronic products.
The tag to put is composed by 2 types of logos:
- A green logo that indicates there aren’t toxic materials or there are in the limit;
- A orange logo that indicates the product contains toxic materials and, in this case, it is necessary a table that indicates precisely which type of toxic materials are contained.
ROHS Regulations in the USA – State of California
Californian RoHS has been effective on 1 Jenuary of 2007. However, it imposes only 4 restrictions; lead, mercury, cadmium, hexavalent chromium.
Moreover, restrictions concern only electronic devices covered by screen over 10 centrimetres, as devices with plasma screen…Instead there aren’t other types of screen included in bigger devices.
It is important remember that other American State are implementing regulations similar to RoHS: New York, Minnesota, New Mexico, Indiana.
Many other countries in the world have adopted RoHS regulations to limit the use of the first six toxic materials included in the original European regulations, these are:
- Normativa RoHS – Singapore
- Normativa RoHS – Taiwan
- Normativa RoHS – Korea
- Normativa RoHS- India
- Normativa RoHS-Giappone
- Normativa RoHS- Emirati Arabi Uniti
- Normativa RoHS- Turchia
- Normativa RoHS- Ucraina
- Normativa RoHS- Russia
Other countries have started iter to equalize to other RoHS regulations in the world, as Brazil.
This article is only a short summary of RoHS regulations and its applications in varied economic areas in the world, but we can notice this is a complex topic and we postpone to laws and regulations in the field for potential detailed studies.
Exceptions in the regulations
In a previous article, we have explained what is RoHS 3 regulations, that is a supplementations ( the third) to preexisting regulations, come into effect on 22 July in the 2019. RoHS 3 has added other materials at previous regulations that we can summarise in six original materials, that are:
- Cadmium ( Cd);
- hexavalent chromium ( Cr VI);
- mercury ( Hg);
- polybrominated biphenyls (PBB);
- polybrominated diphenyl ethers (PBDE).
All these materials are lesser than 0,1%.
Limitation was applied at all those products:
- Big electrical appliances
- Small electrical appliances
- Technology devices and telecommunications
- Consumer equipments
- Illuminations equipments
- Electrical and electric equipments
- Toys and equipments for the free time (videogame…)
RoHS 2 ( 2011/65/EU)
It has extendend setting of applications to:
- Medical devices
- Control and monitoring instruments
In 2015 RoHS 2 introduced other 4 materials:
- Bis (2-ethylhexyl) phthalate DEHP: 0.1%
- Benzyl butyl phthalate (BBP): 0.1%
- Dibutylphthalate (DBP): 0.1%
- Diisobutyl phthalate (DIBP): 0.1%
The directive concerns the entire industry of electrical and electronic equipment: whichever company that manufactures or introduces finished products, sub-assemblies or components on the European market, must verify compliance at the RoHS directive. However, there are exceptions such as:
- for medical devices, including in vitro
- for monitoring and control instruments, including industrial for which the mandatory requirements will start from July 21, 2021.
- It is important remember that the RoHS regulation imposes the obligation of CE marking and the requirements for the declaration of conformity; infact, before placing electrical and electronic equipment (EEE) on the market, the manufacturer, the importer or the distributor must ensure that the appropriate conformity assessment procedure has been applied in compliance with the regulations. As already specified above, the restriction concerning DEHP, BBP, DBP and DIBP are applied to medical devices, including in vitro medical devices, and monitoring and control instruments, including industrial monitoring and control instruments from 22 July 2021. . Finally, at this point, it may be important to clarify the concept of placing a finished necessity in the European market.
In the case of production in the EU territory, the entry takes place when the necessity are sold to the distributor or the final recipient. Instead, if it is an import from a not EU country ( for example from China), the entry occurs when the product is cleared through customs within the European territory, or rather that the necessity is transferred to the importer’s, distrubutor’s warehouse, or, also, directly to the final recipient of the necessity (the person who will use it). We have tried to insert as much information as possible, but this article cannot be considered exhaustive about RoHS certification, indeed for all the details in the field, we postpone to the following link and its additions:
The text of the RoHS directive (PDF), on eur-lex.europa.eu.