RoHS, also known as Directive 2002/95/EC, is an acronym for Restriction of Hazardous Substances. Originating in the European Union, it restricts the use of the following hazardous materials found in electronics:

•       Lead (Pb)
•       Mercury (Hg)
•       Cadmium (Cd)
•       Hexavalent Chromium (CrVI)
•       Polybrominated Biphenyls (PBB)
•       Polybrominated Diphenyls Ethers (PBDE)
•       The following will be added in July 2019:
  • Bis (2-Ethylhexyl) Phthalate (DEHP)
  • Butyl Benzyl Phthalate (BBP)
  • Dibutyl Phthalate (DBP)
  • Diisobutyl Phthalate (DIBP)

Why is RoHS compliance important?

The restricted materials provide an occupational danger during manufacturing, polluting the environment and landfills when disposed of. RoHS is also linked with the Waste Electrical and Electronic Equipment Directive (WEEE), which encourages the design of electrical products to be environmentally safe in regards to recycling and recovery. Both RoHS and WEEE combine to create the EU legislation pertaining to electrical and electronic equipment.

How are products test for RoHS compliance?

Products are tested in a lab to determine the levels of certain elements, as well as the levels of the restricted hazardous materials, in the homogeneous components of each product. The tests conducted are:

•       X-Ray Fluorescence Spectroscopy (XRF) uses X-ray to determine the levels of metals and alloys within a product. The most common element is Bromine.
•       Fourier Transform Infra-Red Spectrophotometer (FTIR) emits infra-red to identify polymers and polymer blends in a product. Particularly Bromine found in PBB or PBDE form.
•       Scanning Electron Microscopy(SEM/EDX) checks for lead-free solders used in the joints of a product
•       Occasionally Atomic Absorbance Spectrophotometry (AAS) will be used to identify Lead and Mercury in a product.

Will RoHS Compliance let me CE-mark my products?

The RoHS 2, or Recast RoHS Directive 2001/65/EU published in July 2011 expanded the original RoHS to cover all electrical components from spare parts to cabling and casing. RoHS category 8 (medical devices) and 9 (control and monitoring instruments) products were included the RoHS 2. It also requires compliance to be adhered to throughout the entire supply chain, and records kept reflecting this. Records include conformity assessment, CE marking, Maintenance of compliance throughout productions and self-reporting of non-compliance – These records need to be kept for 10 years. Once a company is compliant to the RoHS 2 directive they can mark their products with the CE mark. The original checkmark green label will no longer be required or used once RoHS 2 is awarded.

Why the new substances in 2019?

RoHS 3, or Directive 2015/863, published in 2015 adds an additional four substances (Phthalates) to the restricted list, cited by the REACH legislation. REACH stands for Registration, Evaluation, Authorization, Restriction of Chemicals. It addresses the production and use of chemical substances and their impact on human, and environmental health.

Here at The McDonald Consulting Group, we can provide a compliance analysis of your organization detailing the ways in which you are, or are not, abiding by the Directives. We will analyze all aspects of your organization that is affected by the RoHS Directive, and provide a written report with our findings along with suggestions for improvements. Contact us today to book a consultation.