Ensure Your Products Comply With The Latest EU RoHS 2 Directives

The New Changes in the EU RoHS 2

In an ongoing effort to further protect consumers and ensure businesses comply with strict environmental laws, the European Union (EU) tightened regulations governing the use of hazardous materials in all electrical and electronic equipment (EEE) sold in member states.

RoHS 2 became law on 21 July 2011 to close loopholes left open in the initial Restriction of Hazardous Substances Directive (RoHS 1) and expand restrictions to cover all electrical and electronic equipment, cables, and spare parts destined to be sold in the EU.

Businesses supplying EEE products to the EU are required to fully comply with RoHS 2 by July 22, 2019, or sooner, depending on the product category.

Changes in the Types of Businesses Affected

Under RoHS 1, only manufacturers, importers, and distributors of EEE products using restricted substances were required to comply. However, RoHS 2 aims to expand the scope of compliance to all businesses involved in the supply chain, including component suppliers and representatives.

The Costs of Non-Compliance

EU safety standards authorities have powers to perform inspections and tests and demand compliance documentation. Companies failing to comply with the regulations face hefty fines of EUR 5,000 and can have their products withdrawn from the market.

Manufacturers Must Now Have the CE Seal of Approval

The CE label has replaced the original RoHS label with a green check mark. In order to comply with RoHS 2, manufacturers of EEE products must be able to prove their compliance with recordkeeping and self-reporting before the CE mark can be applied to their products.

As well as applying the CE label to EEE products, the RoHS 2 directive dovetails into the EU’s Waste from Electrical and Electronic Equipment (WEEE) Directive 2002/96/EC, which aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. All applicable products in the EU market after August 13, 2006, must pass WEEE compliance and carry the "Wheelie Bin" sticker.

RoHS 2 Restricted Substances

EU RoHS 2 lists a total of ten hazardous substances included in products as homogeneous materials – substances that cannot be mechanically separated into different materials – and stipulates maximum concentration values for each toxic chemical.

Substance (homogeneous materials) Maximum Concentration (ppm)
Cadmium (Cd) 0.01%
Mercury 0.1%
Lead (Pb) 0.1%
Hexavalent chromium (Cr6+) 0.1%
Polybrominated biphenyls (PBB) 0.1%
Polybrominated diphenyl ethers (PBDE) 0.1%
Substances Added in 2015
Bis(2-Ethylhexyl) phthalate (DEHP) 0.1%
Benzyl butyl phthalate (BBP) 0.1%
Dibutyl phthalate (DBP) 0.1%
Diisobutyl phthalate (DIBP) 0.1%

RoHS 2 Restrictions on Phthalates

New restrictions on certain phthalates were introduced in 2015. Commonly referred to by the acronyms DEHP, BBP, DBP and DIBP, these substances are plasticisers that are often used to soften plastics.

DEHP, BBP, and DBP are already restricted in toys for children under 3 years old, which come under stricter regulations applied through entry 51 of Annex XVII to REACH Regulation (EC) No 1907/2006. Those chemicals must comprise less than 0.1% of the children’s products.

DINP, DIDP, and DNOP restrictions at less than 0.1% apply to toys and childcare products that can be placed in children’s mouths.

DEHP, BBP, DBP, and DIBP in all other electrical and electronic equipment are restricted from 22 July 2019 with the exception of medical devices (Category 8), and monitoring and control equipment (Category 9), which were given until 22 July 2021 to comply.

RoHS 2 Exemptions

A number of EEE products that were exempt in the RoHS 1 directive remain so in RoHS 2. These include:

  • Military equipment
  • Large-scale stationary industrial tools
  • Large-scale fixed installations
  • Active implantable medical devices
  • Photovoltaic panels

Be aware that batteries and package materials for EEE products are not included in RoHS directives as they fall under different directives.

While Cadmium in EEE products is restricted in RoHS 2, its use in certain applications such as helium-cadmium lasers is currently exempt due to present technological limitations of any viable alternatives. More details on specific restrictions and exemptions can be found here: annexes III and IV of RoHS 2.

RoHS Outside The EU

Other countries outside the EU are also implementing similar restrictions on hazardous substances to the EU RoHS directives, including: China; Japan; Korea; Taiwan and the USA.

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