In an effort to protect human health and the environment, governments around the world have implemented regulations to restrict the use of hazardous substances in electrical and electronic equipment. The Restriction of Hazardous Substances (RoHS) Directive is one such regulation that has significantly impacted the electrical & electronic product industry. Here, we will provide an overview of the RoHS regulation and outline the essential requirements for compliance and the RoHS test.

 

What is RoHS Testing?

The RoHS Directive is legislation adopted by the European Union (EU) that restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). RoHS stands for Restriction of Hazardous Substances, and its primary goal is to minimize the risks posed by hazardous substances in EEE throughout their lifecycle.

 

What are the typical tests included in a RoHS test schedule for a product being imported to Europe?

To ensure compliance with RoHS requirements, testing laboratories typically conduct a series of tests on products being imported to Europe. A RoHS test schedule typically includes:

  • X-ray fluorescence (XRF) testing: This non-destructive testing method uses X-rays to identify the elements present in a material. This test is commonly used to determine the presence of heavy metals, such as lead, cadmium, and mercury.
  • Inductively coupled plasma mass spectrometry (ICP-MS): This more sensitive analytical method can be used to quantify the levels of specific elements in a material. This test is often used to confirm the results of XRF testing and to determine the levels of restricted substances in a product.
  • Gas chromatography-mass spectrometry (GC-MS): This gas chromatography-mass spectrometry technique can be used to identify and quantify organic compounds in a material. This test is often used to determine the presence of phthalates and other organic restricted substances in a product.
  • Further chemical Analysis: Laboratory technicians may conduct chemical analysis to identify and quantify the presence of restricted substances, such as lead, cadmium, and mercury, in materials and components of the product.

The specific tests that are carried out will vary depending on the type of product being imported and the specific RoHS test requirements that apply to the product. However, the tests listed above are some of the most common tests that are used to assess compliance with RoHS.

It is important to note that RoHS is a dynamic regulation, and the specific requirements may change over time. Therefore, it is important to check with the European Chemicals Agency (ECHA) website to ensure that you are aware of the latest requirements.

Here are some additional tips for importers of products into the EU with respect to RoHS:

  • Work with a reputable lab that has experience testing for RoHS compliance.
  • Get the test results in writing and keep them on file for future reference.
  • Be aware of the latest changes to the RoHS requirements.

 

Which substances are restricted by the RoHS Directive?

RoHS applies to a wide range of electrical and electronic products, including appliances, IT equipment, consumer electronics, lighting products, medical devices, and more. The directive restricts the use of hazardous substances, for example:

  • Cadmium (Cd): < 100 ppm (0.01%)
    Cadmium is used in electronic equipment, car batteries, metal coatings, and pigments. A known human carcinogen that affects multiple organ systems. CAS number = 7440-43-9.
  • Lead (Pb): < 1000 ppm (0.1%)
    Lead is used in solder, lead-acid batteries, electronic components, cable sheathing, x-ray shielding, and in the glass of cathode-ray tubes. A known human carcinogen that affects the nervous and renal systems. CAS number = 7439-92-1.
    NOTE: RoHS 0.1% lead amounts are exempted when used as an alloying element in steel, aluminum, copper; in specific solders; and in specific glass and ceramic applications up through 2024. For more information, see RoHS Annex III Lead Exemptions.
  • Mercury (Hg): < 1000 ppm (0.1%)
    Mercury is used in batteries, switches, thermostats, and fluorescent lamps. A known human carcinogen that affects multiple organ systems. CAS number = 7439-97-6.
  • Hexavalent Chromium (Cr VI) < 1000 ppm (0.1%)
    Chromium VI is used in chrome plating, dyes, and pigments. While some forms of chromium are non-toxic, chromium VI can produce toxic effects in multiple organ systems. CAS number = 18540-29-9.
  • Polybrominated Biphenyls (PBB): < 1000 ppm (0.1%)
    Also known as congeners, PBBs are flame retardants found in computer monitors and TV plastic enclosures. They have been found in indoor dust and air through evaporation. A known human carcinogen that affects the endocrine system.
  • Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm (0.1%)
    Similar to PBBs – added to plastic enclosures to make them difficult to burn. A known human carcinogen that affects the endocrine system.
  • Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm (0.1%) (RoHS 3)*
    DEHPs are used to soften PVC and vinyl insulation on electrical wires and in medical tubing. A known human carcinogen that affects the immune and reproductive systems.
  • Benzyl butyl phthalate (BBP): < 1000 ppm (0.1%) (RoHS 3)*
    These are used to soften PVC and vinyl insulation on electrical wires.
  • Dibutyl phthalate (DBP): < 1000 ppm (0.1%) (RoHS 3)*
    DBPs are part of the di-n-phthalate family used to soften PVC and vinyl insulation on electrical wires.
  • Diisobutyl phthalate (DIBP): < 1000 ppm (0.1%) (RoHS 3)*
    These are also used to soften PVC and vinyl insulation on electrical wires.

These substances are restricted in RoHS regulations because they can pose a risk to human health and the environment. The directive aims to reduce the amount of these substances in electrical and electronic products, which will help to protect people and the planet.

*Reference RoHS 3:

European Commission. (2015, March 31). Directive 2015/863 amending Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment.

Data source: https://www.rohsguide.com/rohs-substances.htm

 

Key Requirements for RoHS Test Compliance

To comply with the RoHS directive, businesses must meet the following obligations:

  1. Substance Restrictions: Manufacturers must ensure that their products do not contain levels of restricted substances above the maximum allowed concentrations. The current limits under RoHS are 0.1% (1000 parts per million) by weight for each restricted substance, except for cadmium (0.01%).
  2. RoHS Test: Manufacturers are responsible for conducting product testing, when deemed appropriate, to verify compliance with RoHS requirements. This involves analyzing samples of their products to determine the presence and concentration of restricted substances.
  3. Supplier Declaration of Conformity: Manufacturers must obtain a declaration of conformity from their suppliers, indicating that the supplied components or materials comply with RoHS requirements. This ensures transparency and traceability within the supply chain.
  4. Technical Documentation: Manufacturers must keep technical documentation that demonstrates compliance with RoHS. This includes records of testing, supplier declarations, and other relevant documentation.
  5. CE Marking: Once a product has been determined to be compliant to the RoHS directive (and to other applicable legislation such as EMC, RED…), it must be affixed with the CE marking. Note, some manufacturers affix a “RoHS” logo on their products, and it actually demonstrates a lack of awareness about actual requirements.

 

Benefits of RoHS Compliance

Complying with RoHS offers several benefits, including:

  1. Environmental Protection: By reducing the use of hazardous substances in EEE, RoHS helps to prevent pollution and minimize the environmental impact of electronic products throughout their lifecycle. Also, a RoHS non-compliant product cannot be recycled into new EEE.
  2. Human Health and Safety: RoHS protects consumers and workers from potential health risks associated with exposure to hazardous substances present in electronic products.
  3. Market Access: Compliance with RoHS is a legal requirement to access the EU market. Ensuring RoHS compliance enables businesses to expand their market reach within the EU and gain a competitive advantage.
  4. Reputation and Brand Value: Complying with RoHS demonstrates a company’s commitment to environmental sustainability and responsible manufacturing practices, enhancing its reputation and brand value.

 

Conclusion

The RoHS directive plays a crucial role in ensuring the safety of electrical and electronic equipment while minimizing the environmental impact of these products. By adhering to RoHS, businesses not only fulfill their legal obligations but also contribute to a safer and more sustainable electronics industry.

For more detailed information on RoHS, you can visit this website:

European Commission: The official website of the European Commission provides information on RoHS directive, including the directive, guidance documents, and updates: https://ec.europa.eu/

You may also like to read: 11 Common Electronic Product Certification And Compliance Requirements

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