1. Scope of article
This article is meant to explain Directive 2011/65/EU on the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment, commonly referred to as RoHS. The article aims to answer such questions as:
- Is my product within the scope of RoHS?
- Do I need to send my product for testing to show compliance with RoHS?
2. The RoHS directive
Within the EU, 3 directives regulate most substances and chemicals in products. REACh and POP are market-wide and apply to all products, while RoHS only applies to electronic products.
2.1. Scope of RoHS
As is stated in the full title “the restriction of the use of certain hazardous substances in electrical and electronic equipment” of the directive, it applies specifically to electrical and electronic equipment (EEE).
EEE is here defined as equipment that requires electric currents or electromagnetic fields in order to fulfil at least one intended function. Large-scale equipment and equipment with voltage ratings over 1000 V AC or 1500 V DC are excluded from the directive’s scope. Additionally, some very specific groups of products are exempted, such as military equipment and devices to be sent into space.
Cables and spare parts for EEE are also included in the scope of RoHS.
2.2. Restricted substances
RoHS currently restricts the concentration of 10 substances:
- Lead
- Mercury
- Cadmium
- Hexavalent chromium
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ethers (PBDE)
- Bis(2-ethylhexyl) phthalate (DEHP)
- Butyl benzyl phthalate (BBP)
- Dibutyl phthalate (DBP)
- Diisobutyl phthalate (DIBP)
None of these substances are allowed to exist in any larger concentration than 0.1% (wt.) in any homogeneous material, cadmium is limied to 0.01%. “Homogeneous Material” essentially means any material that is not feasibly separated by mechanical means, from another material. For example, the conductors are not feasibly separated from the board within a circuit board, but the solder of a solder joint can feasibly be removed. The conductors and the circuit board are therefore considered a homogenous material.
This means that each of these homogeneous materials in an EEE must be evaluated against RoHS individually. Additionally the materials of an EEE that are not in themselves of an electrical nature, for example plastic covers, must also be assessed. This can quickly become quite an extensive process for EEEs with many materials and components, which they often have.
2.3. Implementation of RoHS
When searching for information about RoHS on the internet, it is common to find references to RoHS 1, 2 and 3. Understandably one could assume that we are currently on the third iteration of RoHS, but this is not correct. RoHS 1 is a previous RoHS directive (2002/95/EU), which was later replaced by RoHS 2 (2011/65/EU) which is the current directive. RoHS 3 is a directive (2015/863) that amended RoHS 2 with additional substances.
All-in-all, the numbering seems more confusing than it needs to be (from what we can see, no other updated directives have been given such numbering). Instead, let’s say RoHS, meaning the directive in effect (2011/65/EU) including any amendments.
3. Complying with RoHS
As previously mentioned, to be compliant with RoHS, every single homogeneous material must be assessed for the concentration of the 10 substances. Even very small products could easily include tens of separable materials which would mean hundreds of tests. Even if each of these tests is small and fast, it is still an incredible amount of data for a single product. In addition, most, if not all, ingoing components and materials in electronic equipment are used in many different products. So why waste the effort of repeatedly testing the same material?
3.1. EN IEC 63000:2018
The EC has recognised that requiring test reports for all materials would never be a feasible obligation for manufacturers, especially Small and Medium-sized Enterprises (SME). So a methodology for compliance has been defined within the single harmonised standard under RoHS, EN IEC 63000:2018 (which replaced the earlier EN 50581:2012 in 2021).
This standard is relatively cheap, short and easily understood. Therefore, we recommend that manufacturers , who have EEEs as a core part of their business, purchase and read the standard in full. For those that only produce the occasional EEE, we will summarise.
In short, the standard allows manufacturers and suppliers to apply a system of “trust” where every single actor along the supply chain has “trust” in the actors above them. “Hopefully” this chain of trust reaches the original manufacturer of a single component or material, where that actor has tested the product, “hopefully”. But this is the very short version. Due to the length of the standard and its copyrighted nature, we cannot explain in much more detail without infringing said copyright (it is so short that certain previews show almost the entire standard).
The responsibilities of manufacturers are divided into:
- Collecting information about RoHS for all materials, parts and components including the manufacturing process (e.g., is PB (lead) used in the soldering process?).
- Assessing whether the information is sufficient and reliable
- Update information to reflect changes in materials, parts, and components
