RoHS Directive 2017/2102/EU amending Directive 2011/65/EU
The directive on the restriction of the use of hazardous substances in electrical and electronic equipment (RoHS Directive), updated in 2011, restricts the use of lead, mercury, cadmium, chromium and brominated flame retardants in such equipment. It contains a list of exemptions (some of them limited in time) updated by way of delegated acts.
In January 2017, the European Commission put forward a legislative proposal modifying the RoHS Directive. It aims to:
• Enable secondary market operations (e.g. reselling, second-hand market) for certain electrical and electronic equipment; and
• Enable repair with spare parts of certain electrical and electronic equipment that were placed on the market before 22 July 2019.
Any and all EEE which fall into one of the following categories must adhere to the Directive:
• Large household appliances.
• Small household appliances.
• IT and telecommunications equipment.
• Consumer equipment.
• Lighting equipment.
• Electrical and electronic tools.
• Toys, leisure and sports equipment.
• Medical devices.
• Monitoring and control instruments including industrial monitoring and control instruments.
• Automatic dispensers.
• Other EEE not covered by any of the categories above.
The RoHS Directive does not apply to:
• Items in scope, but fall within exemptions of specific applications listed within Annex III and IV of the Directive
• Equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes;
• Equipment designed to be sent into space;
• Equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment;
• 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 intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications;
• Equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis.
The materials used for the electrical and electronic equipment, including components and spare parts for repair, should not contain any of the following substances:
• Cadmium (0,01 %)
• Lead (0,1 %)
• Hexavalent Chromium (0,1 %)
• Mercury (0,1 %)
• PBB’s (Polybrominated biphenyls) (0,1 %)
• PBDE’s (Polybrominated diphenyl ethers) (0,1 %)
• DEHP (Bis (2-ethylhexyl) Phthalate) (0,1 %)
• BBP (Butyl Benzyl Phthalate) (0,1 %)
• DBP (Dibutyl Phthalate) (0,1 %)
• DIBP (Diisobutyl Phthalate) (0,1 %)
Manufacturers must ensure the substances are not contained within their product, by creating a technical file concerning the product and evidence of the materials used.
Technical documentation will need to be kept for a minimum of 10 years after the product has been placed on the market.
Of course you will also need to ensure that the series manufacture of the product does not harm its conformity. If a batch is found to be non-conforming then it is your duty as the manufacturer to recall the products and keep distributors informed.
The product itself needs to be marked with:
• A CE mark
• A type, batch or serial number
• Your name registered trade name or registered trademark
• A contact address
At present, there is only one harmonised standard for RoHS: BS EN IEC 63000:2018 (Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances) This document specifies the technical documentation that the manufacturer compiles in order to declare compliance with the applicable substance restrictions. The documentation of the manufacturer’s management system is outside the scope of this document.
HOW WE CAN HELP:
The CE Marking Authority has over 40 years experience with regulatory requirements and can assist manufacturers, importers, and users of machinery and their components by offering a range of services to meet your needs. Here are some of the services on offer:
• Consultancy to understand your route to conformity and applicable requirement
• Technical file review
• Consultancy advice on related Directives (Machinery, LVD, EMC & PED)