Hazardous substances in electrical and electronic equipment – RoHS

The use of certain metals, plasticizing agents and fire retardants in electrical and electronic equipment is subject to restrictions. The purpose of RoHS (Restriction of Hazardous Substances) legislation is to protect human health and the environment and reduce the harmfulness of waste.

The scope of RoHS

The RoHS legislation applies to all electrical and electronic equipment (EEE).

EEE refers to devices that

need electric currents or electromagnetic fields to fulfil at least one intended function or
generate, transfer or measure such currents or fields and
has a voltage rating not exceeding 1,000 volts for alternating current and 1,500 volts for direct current.

Examples of EEE are household appliances, televisions, phones, battery-operated tools, watches, vending machines and various monitoring devices, such as fire detectors. Many products that are not thought to be electronic devices but that contain, for example, battery-operated LED lights, actually meet the definition of EEE. Clothes and other textiles with LED lights are electrical equipment.

RoHS does not apply to the following:

equipment which is necessary for the protection of essential security interests or for military purposes
equipment designed to be sent into space
large-scale stationary industrial tools
large-scale fixed installations
means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved
non-road mobile machinery made available exclusively for professional use
active implantable medical devices
photovoltaic panels designed, assembled and installed by professionals
equipment designed for the purposes of research and development and made available on a business-to-business basis
pipe organs
equipment which is specifically designed to be installed as part of another type of equipment mentioned above.

Which substances are restricted?

Restrictions apply to the use of following substances in EEE, their cables and spare parts:

cadmium, Cd
lead, Pb
mercury, Hg
hexavalent chromium, Cr6+
polybrominated biphenyls, PBB
polybrominated diphenyl ethers, PBDE
bis (2-ethylhexyl) phthalate, DEHP
butyl benzyl phthalate, BBP
dibutyl phthalate, DBP
di-isobutyl phthalate, DIBP

Maximum concentration values:

cadmium, 0.01 % by weight
all other substances, 0.1 % by weight

The maximum concentration values are the maximum permissible concentrations of the hazardous substances in homogeneous materials. ‘Homogeneous material’ means material of uniform composition throughout that cannot be separated into different materials by mechanical actions. Examples of homogeneous materials are the plastic casing of a computer, the copper wire in a cable and the solder of a soldered seam. Homogeneous material can also be a combination of materials, if they cannot be separated by mechanical actions. Examples of mechanical actions include rotating, cutting, crushing, grinding or rubbing.

Note for restrictions on phthalates:

applicable on electrical equipment from 22 July 2019
applicable on medical devices and monitoring and control instruments from 22 July 2021
with respect to DEHP, BBP and DBP, the restriction does not apply to toys; DEHP, BBP and DBP restrictions concerning toys are included in Regulation (EC) No. 1907/2006 (the REACH Regulation), Annex XVII, entry 51.

Exemptions concerning the use of restricted substances

The Commission permits the use of the restricted substances for certain applications. An exemption may be granted for scientific or technical reasons when, for example, no substitute to the substance is available.

The exemptions are applicable:

for up to five years for EEE
for up to seven years for medical devices and monitoring and control instruments.

Obligations of the manufacturer, importer and seller

In addition to requirements on products, the RoHS Directive creates a number of obligations for the manufacturer, importer and seller of the product.

Manufacturers and importers must also take into account requirements concerning manuals.