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Restriction of Hazardous Substances Directive (RoHS) Explained

The Restriction of Hazardous Substances Directive (RoHS) 2002/95/EC was adopted in February 2003 by the European Union. The RoHS directive takes effect on July 1, 2006, but is not a law; it is simply a directive. This directive restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste.

Details

Each European Union member state will adopt its own enforcement and implementation policies using the directive as a guide. Therefore, there could be as many different versions of the law as there are states in the EU.

RoHS is often referred to as the "lead-free" directive, but it restricts the use of the following 6 substances:

  1. Lead
  2. Mercury
  3. Cadmium
  4. Chromium VI (Also known as hexavalent chromium or Cr6+)
  5. PBB
  6. PBDE

PBB and PBDE are flame retardants used in some plastics.

The maximum concentrations are 0.1% (except for Cadmium which is limited to 0.01%) by weight of homogeneous material. This means that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically — for example, the sheath on a cable or the tinning on a component lead.

For example, a radio is comprised of a case, screws, washers, a circuit board, speakers etc. A circuit board is comprised of a bare PCB, ICs, resistors, switches etc. A switch is comprised of a case, a lever, a spring, contacts, pins etc. The contact might be comprised of a copper strip with a surface coating.

Everything that can be identified as a different material must meet the limit. So if it turns out that the case was made of plastic with 2300 ppm (0.23%) PBB used as a flame retardant, then the entire radio would fail the requirements of the directive.

Note that batteries are not included within the scope of RoHS, therefore NiCd, Lead-acid and Mercury batteries are permitted despite the use of restricted substances.

The directive applies to equipment as defined by a section of the WEEE directive. These are:

  • Large and small household appliances.
  • IT equipment.
  • Telecommunications equipment (although infrastructure equipment is exempt in some countries)
  • Consumer equipment.
  • Lighting equipment — including light bulbs.
  • Electronic and electrical tools.
  • Toys, leisure and sports equipment.
  • Automatic dispensers.

The RoHS directive does not apply to fixed industrial plant and tools. Compliance is the responsibility of the company that puts the product on the market, as defined in the Directive; components and sub-assemblies are not responsible for product compliance. Of course, given the fact that the regulation is applied at the homogeneous material level, data on substance concentrations needs to be transferred through the supply chain to the final producer. An IPC standard has recently been developed and published to facilitate this data exchange, IPC-1752 http://www.ipc.org/ipc-175x. It is enabled through two Adobe forms which are free to use.

RoHS applies to these products in the EU whether made within the EU or imported. Certain exemptions apply, and these are updated on occasion by the EU.

There is also legislation in China (often referred to as "China RoHS") that has similar restrictions. Unlike EU RoHS (products are included unless specifically excluded), there will be a list of products to which the regulations apply (products are excluded unless specifically included). There are some products which probably will be included for China RoHS which are not in scope for EU RoHS - e.g. radar systems. However, the details of the requirements and list of included products have not been finalized by the Chinese government. The legislation is scheduled to take effect 1 March 2007.

Japan does not have any direct legislation dealing with the RoHS substances, but its recycling laws have spurred the Japanese manufacturers to move to a lead-free process. These companies have also been proactive in phasing out other harmful materials which will, in effect, make their products RoHS compliant.

In addition, California has adopted similar legislation which will take effect on January 1, 2007. The California law will use the EU RoHS directive as its guide. These, as well as other legislation, effectively makes RoHS a world wide compliance issue.

See also

External links

This article is licensed under the GNU Free Documentation License. It uses material from the Wikipedia article "The Restriction of Hazardous Substances Directive".

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