Note: Ben's 2nd article on RoHS Directive is available here.
RoHS Compliance(Restriction of Hazardous Substances) is the nickname given to the European Union's directive 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment. RoHS is closely related to the European Union's directive 2002/96/EC on waste electrical and electronic equipment (WEEE). RoHS references Annex 1A of WEEE to specify its scope of coverage (Categories 1-7 and 10). While closely related, RoHS and WEEE deal with different parts of the product life cycle. RoHS seeks to reduce the amount of hazardous materials entering electronic products while WEEE deals with reducing the amount of electronics entering landfills. RoHS is the beginning, and WEEE is the end. Now is the time to determine the impact of RoHS on one's business because the directive went into effect on July 1, 2006.
The RoHS directive currently lists 6 materials as being restricted. Some use the language "banned", which is incorrect since RoHS specifies maximum concentration values (MCV's) for each material and provides a list of applications exempt from the restrictions (concentrations are specified in Commission Decision 2005/618/EC). RoHS language provides for future expansion of the restricted list should scientific evidence suggest the necessity. This is referred to in the directive as the precautionary principle.
Toxicological Profiles from the U.S. Department of Health and Human Services Agency for Toxic Substances and Disease Registry.
Exemptions to the maximum allowed concentrations of restricted materials do exist for cases where technology does not yet allow for substitutions, or where alternatives may have a worse impact on human health and the environment. Some exemptions include mercury in several kinds of fluorescent lamps, lead in steel and aluminum alloys, lead in some types of solder, and military applications.
RoHS Article 3.(a) states that RoHS covers electrical and electronic equipment "which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out in Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current". With that said, a microwave oven would be covered by RoHS because it cannot perform its intended function with the power switched off. On the other hand, a talking doll can still be used as a doll even when the batteries are removed, so it isn't covered by RoHS.
RoHS does allow for non-compliant components after the July 1, 2006 deadline, but only as spare parts for equipment on the market before July 1, 2006.
The RoHS compliance directive places the responsibility of compliance on the "producer" of the equipment. Producer is defined as any person who, irrespective of the selling technique used:
manufactures and sells electrical and electronic equipment under his own brand;
resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the 'producer' if the brand of the producer appears on the equipment, as provided for in subpoint (i); or
imports or exports electrical and electronic equipment on a professional basis into a Member State.
Who is Affected?
Some outside the European Union may ask what RoHS has to do with them; after all, it's a European thing, right? Wrong, RoHS principles and reach are global. The directive indicates that anything covered by RoHS entering the European Union must be in compliance, that includes cables made in China, parts molded in the U.S. and PCB's made in Japan. If it's destined for the EU, it is impacted by RoHS. And it's not just the EU that is taking steps to reduce the toxins in electronic devices, California's Electronics Waste Recycling act of 2003 (SB 20, Chapter 526) echoes the RoHS directive and takes effect January 1, 2007. Japan, China, and Korea are expected to follow with laws of their own.
Important Considerations For Plastic Selection
For OEMs and Processors who are choosing resins, the most important consideration is to ensure that the resin supplier can certify the material as RoHS compliant. RoHS will not affect most materials - if you're curious to know if the materials you are using are RoHS compliant, tell us what materials you are using and we’ll let you know if they are RoHS compliant.
If you haven't already started assessing the impact RoHS or similar laws will have on your business, now is the time to start learning.
ANNEX 1A to WEEE
Categories of electrical and electronic equipment covered by this Directive:
Automatic dispensers for hot or cold bottles or cans
Automatic dispensers for solid products
Automatic dispensers for money
All appliances which deliver automatically all kind of products
Your Expert
Ben Howe is a content manager for IDES Inc. and is responsible for the management of
76652
unique grades of plastic material data sheets from more than
669
resin suppliers. Ben holds a degree in Mechanical Engineering from the University of Wyoming (2001).
Ben Howe is a content manager for IDES Inc. and is responsible for the management of
76652
unique grades of plastic material data sheets from more than
669
resin suppliers. Ben holds a degree in Mechanical Engineering from the University of Wyoming (2001).