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.

Some of the excluded products such as vehicles are covered by the existing special legislation restricting the use of certain substances.

It is the responsibility of the manufacturer and the importer to assess whether the appliance falls outside the scope of the RoHS Directive. Sometimes, the buyer might also require that the equipment e complies with the RoHS Directive, even if legislation do not require it.

Examples of large fixed industrial tools: CNC lathes, newspaper presses and cranes. The mere bolting of a tool to the floor structure does not make the tool a large fixed industrial tool. Large fixed installations include various production lines, belt conveyor systems and lifts.

If the product can be used for a variety of purposes covered or excluded from the scope, the product must comply with the RoHS Directive. For example, if the same refrigerator is sold for use in hotel rooms and motorhomes, the refrigerator must meet RoHS requirements.

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

For phthalate restrictions, you should note that they do not apply to toys, as the phthalate restrictions for toys are laid down in annex XVII, item 51, of the REACH regulation.

The maximum allowed concentrations in homogeneous material are:

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 is either uniform material or material consisting of a combination of materials that cannot be separated by mechanical means. Twisting, cutting, crushing, grinding and rubbing are examples of mechanical means. Electrical and electronic equipment consist of a variety of homogeneous materials, which must not contain restricted substances above the maximum concentration. Plastic case of display monitors, copper wire in a cable and the soldering material on a soldered joint are examples of homogeneous materials. In certain situations, the maximum concentrations can be exceeded (see chapter Exemptions).

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.

Standards

Standard EN IEC 63000:2018 on technical documentation has been harmonised under the RoHS Directive. The standard determines what kind of information is required in the technical documentation to demonstrate compliance with the RoHS Directive.

The IEC 62321 or SFS-EN 62321 series of standards are commonly used in RoHS analyses. The standards define the procedures for the pre-treatment of samples and the analytical steps for the different analysis methods.

Demonstration of conformity

For the RoHS Directive, the manufacturer can use internal production control in accordance with Module A of Annex II to Decision No 768/2008/EC establishing a common framework for the marketing of products and repealing Decision 93/465/EEC as the conformity assessment procedure for electrical appliances. The documents and test reports in accordance with the conformity assessment procedure are attached to the technical documentation.

Internal production control is a conformity assessment procedure in which the manufacturer fulfils certain obligations and assures responsibility for ensuring that the products in question meet the requirements of the legal provisions that apply to them.

The manufacturer must draw up technical documentation that can be used to assess whether the product complies with its essential requirements. The technical documentation must also include an appropriate analysis and assessment of the risks. The manufacturer must also ensure that the appliance complies with the technical documentation and the regulations relating to the appliance. The manufacturer affixes the CE marking and other required markings to the product and prepares an EU declaration of conformity.

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.