Are You Ready for RoHS?

What is RoHS?

RoHS is an abbreviation for a new European Union directive 2002/95/EC designed to prevent the use of toxic materials in electronic equipment. RoHS stands for “Restriction of the use of certain Hazardous Substances in electrical and electronic equipment”.

The initiative is in the form of a directive from the European Parliament to all member states. Effective July 1, 2006, it requires the EU members to ensure that new electrical and electronic equipment put on the market for the first time from July 1, 2006 should not contain the following:

• Lead (Pb)
• Cadmium (Cd)
• Mercury (Hg)
• Hexavalent Chromium (Cr VI)
• The fire retardants polybrominated biphenyls (PBBs)
• Polybrominated diphenyl ethers (PBDEs)

This applies to equipment made in Europe or imported. The restrictions apply to 8 main categories:

1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment including light bulbs
6. Electrical or electronic tools, but not large scale stationary industrial tools
7. Toys, leisure and sports equipment, including video game equipment
8. Automatic dispensers

Medical devices, military equipment and monitoring and control instruments are presently exempt from RoHS. Batteries are also exempt, but they will be covered in Europe under a future battery-specific directive. There are also a bewildering array of special cases and exemptions depending on whether the equipment is self standing or designed to be used only as a part in another product. For example, printers are covered under RoHS, but ink cartridges are not.

Parts made for use in older equipment are, for the time being, exempt. Under RoHS, users are actually encouraged to keep their old electronic equipment functioning.

What does this mean for manufacturers?

Essentially it means that manufacturers of new consumer electrical and electronic equipment or parts will have to demonstrate that their products and parts do not contain more than the allowed limits of lead, mercury, cadmium, chromium VI, PBB and PDBE, if they wish to sell in Europe.

The present limits are 0.1% by weight (1000 ppm) of all of the above hazardous materials except cadmium, where the limit is 0.01% (100 ppm). These limits apply to what the directive refers to as “homogenous materials” used in the manufacturing process. Examples of homogenous materials include plastics, ceramics, glass, metals, paper, board, resins and coatings. Depending on the end use, it may also include solder, which from this point must not contain more than 0.1% lead.

As an example, in the case of electrical cable consisting of metal wires surrounded by a plastic coating, the limits apply individually to the wire and plastic; each of which must be free of the listed hazardous materials.

There are many exemptions based on the type of product and how it is used. Manufacturers will need to review their products against the list of exemptions to determine which of their products fall under RoHS. They will then need to determine whether the materials contain the listed hazardous materials. In some cases this may require direct testing for the listed chemicals.

Manufacturers will need to document that their materials for sale in Europe are RoHS compliant. Manufacturers are expected to retain the documentation for 4 years and provide the documentation to regulators on request.

There are, as yet, no formal RoHS product labeling requirements, but many manufacturers have already developed markings indicating RoHS compliance.

Does RoHS still apply if I don’t ship to Europe?

Technically, RoHS only applies to Europe, however there are other areas with similar types of legislation. For example, China has its own version of RoHS, and in the United States, California has the Electronic Waste Recycling Act of 2003 (SB 20 and SB 50).

How can ISI help?

ISI is a team of scientists with more than 15 years of experience in determining the composition of a range of materials. At our Burlington, Ontario facility, we have a test lab where we carry out sample preparation and then either directly test for a range of materials including PBBs and PDBEs or sub-contract the metals testing to a GLP-compliant lab with whom we collaborate frequently.

Our scientists are able to review your suspect materials and ascertain whether they contain the RoHS-listed chemicals. In some cases, this may require direct testing. The results are reported in either a technical paper or a Certificate of Analysis, depending on the situation. As the compliance requirements become more clear, we will ensure that our documentation is consistent with RoHS requirements.

Contact us directly at 905-634-4200 to learn more about how we can help.