RoHS and REACH Awareness and Guidelines

RoHS and REACH Awareness and Guidelines:

Restriction of Hazardous Substances RoHS in Electronics and Electricals products, impacts the entire electronics industry and many electrical products as well. The original RoHS, also known as Directive 2002/95/EC, originated in the European Union in 2002 and restricts the use of six hazardous materials found in electronic and electrical products. All applicable products in the EU market since July 1, 2006 must pass RoHS compliance.

Directive 2011/65/EU was published in 2011 by the EU, which is known as RoHS-Recast or RoHS 2. RoHS 2 includes a CE-marking directive, with RoHS compliance being required for CE marking of products. RoHS 2 also added Categories 8 and 9 i.e. ‘Medical devices and equipment’& ‘Control and monitoring equipment’ and has additional compliance record-keeping requirements.

Directive 2015/863 was published in 2015 by the EU, which is known as RoHS 3, with addition of four more restricted substances (phthalates) to the list of six.

RoHS specifies maximum levels for the following 10 restricted substances. The first six applied to the original RoHS while the last four were added under RoHS 3.

Lead (Pb) < 1000 ppm: Lead is commonly used in the electrical and electronics industry in solder, lead-acid batteries, electronic components, cable sheathing and in the glass of cathode-ray tubes.

Mercury (Hg) < 1000 ppm: Mercury is widely used metals in the production of electrical and electronic appliances and is concentrated in batteries, switches and thermostats, and fluorescent lamps.

Cadmium (Cd) < 100 ppm: Cadmium is used in electronic equipment, car batteries, and pigments.

Hexavalent Chromium (Cr VI) < 1000 ppm: While some forms of chromium are non-toxic, Chromium VI can produce toxic effects.

Polybrominated Biphenyls (PBB) < 1000 ppm: These are flame retardants found in electronic and electrical appliances. They have been found in indoor dust and air through evaporation from plastics.

Polybrominated Diphenyl Ethers (PBDE) < 1000 ppm: These are also flame retardants found in electronic and electrical appliances. Combustion of printed wiring boards release toxic emissions.

Bis(2-Ethylhexyl) phthalate (DEHP) < 1000 ppm: These are used to soften PVC and vinyl insulation on electrical wires.

Benzyl butyl phthalate (BBP) < 1000 ppm: These are used to soften PVC and vinyl insulation on electrical wires.

Dibutyl phthalate (DBP) < 1000 ppm: These are used to soften PVC and vinyl insulation on electrical wires.

Diisobutyl phthalate (DIBP) < 1000 ppm: These are used to soften PVC and vinyl insulation on electrical wires.

Why, How, Which, What & Where of RoHS compliance

The restricted materials are hazardous to the environment, pollute landfills and they are also dangerous in terms of occupational exposure during manufacturing and recycling.

Portable RoHS analyzers, also known as X-ray fluorescence or XRF metal analyzers are used for screening. The screening method estimates the PBBs & PBDEs as Bromine, and is to be used only for the segregating the non- compliant parts. For the accurate estimation,the referee method as per the IEC Guidelines is used which employs the techniques of GC-MS for estimation of Phthalates, PBBs & PBDEs. Lead, Mercury & Cadmium are estimated by ICP-OES & Hexavalent Chromium using the technique of UV-Vis Spectrophotometer.

Any business that sells electronic and applicable electronic products, sub-assemblies or components directly to EU countries or sells to resellers, distributors or integrators that in turn sell products to EU countries is impacted if they utilize any of the restricted materials.

RoHS 2, Directive 2011/65/EU, was published in July 2011 by the European Commission. The scope of the original RoHS was expanded to cover all electronic/applicable electrical equipment, cables, and spare parts with compliance required by July 22, 2019 or sooner depending on product category.

RoHS 2 is also a CE-marking directive, with RoHS compliance now being required for CE marking of products. As such, all manufacturers of electrical/electronic products must comply with RoHS 2 before the CE mark can be applied on their products. The original green RoHS label with the checkmark is no longer required or used as the CE mark now includes RoHS compliance.

What is REACH and how is it related to RoHS?

REACH is a general regulation and stands for Registration, Evaluation, Authorization, Restriction of Chemicals, and addresses the production and use of chemical substances and their potential impact on Human health and the Environment. REACH is monitored by the ECHA (European Chemicals Agency) and deals with the list of 191 SVHCs ( Substances of Very High Concern ) as per Annex XIV of REACH Directive and a list of Restricted substances as per Annexure XVII. While RoHS bans substances present in electronic/applicable electrical equipment, REACH controls all chemicals that might be used to make a product, including solvents, paints, and chemicals.

What is WEEE?

WEEE is the acronym for Waste from Electrical and Electronic Equipment. WEEE, also known as Directive 2002/96/EC, mandates the treatment, recovery and recycling of electric and electronic equipment. All applicable products in the EU market after August 13, 2006 must pass WEEE compliance and carry the "Wheelie Bin" sticker.

How are RoHS and WEEE related?

WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS regulates the hazardous substances used in electronic and applicable electrical equipment, while WEEE regulates the disposal of this same equipment.The RoHS Directive currently applies to products in Categories 1 thru 11 (as per Schedule 1 of the WEEE Directive).

The following product categories are impacted under the RoHS Directive:

Cat 1. Large household appliances: refrigerators, washers, stoves, air conditioners

Cat 2. Small household appliances: vacuum cleaners, hair dryers, coffee makers, irons

Cat 3. Computing & communications equipment: computers, printers, copiers, phones

Cat 4. Consumer electronics: TVs, DVD players, stereos, video cameras

Cat 5. Lighting: lamps, lighting fixtures, light bulbs

Cat 6. Power tools: drills, saws, nail guns, sprayers, lathes, trimmers, blowers

Cat 7. Toys and sports equipment: video games, electric trains, treadmills

Cat 8. Medical devices and equipment *

Cat 9. Control and monitoring equipment *

Cat 10. Automatic dispensers: vending machines, ATM machines

Cat 11. All other electronic and electrical equipment (EEE) not covered under the other categories **

* Compliance deadline for Category 8 & 9 products for RoHS 3 phthalate restriction is July 22, 2021

** Compliance deadline for Category 11 products for RoHS 3 phthalate restriction is July 23, 2019

The following products are currently exempted from RoHS compliance:

  • National security use and military equipment,
  • Outer space equipment,
  • Non-road mobile machinery,
  • Large stationary industrial tools and installations,
  • R&D equipment,
  • Implantable medical devices,
  • Photovoltaic panels,
  • Certain light bulbs and some batteries,
  • Certain light bulbs and some batteries,
  • Spare parts for electronic equipment in the market before July 1, 2006. 

Other RoHS Green Initiatives Worldwide

Your business probably will not escape RoHS compliance just because your products don't sell in the EU. There are other countries that have worked out their own version of RoHS as well.

  1. California RoHS (SB20) Compliance
  2. China RoHS Compliance
  3. Japan RoHS Compliance
  4. Korea RoHS Compliance
  5. Norway RoHS Compliance (PoHS)
  6. Sigapore RoHS Compliance (SG-RoHS)
  7. Turkey RoHS Compliance
  8. India RoHS Compliance 

We at TUV India (P) Ltd. provide the testing for RoHS, REACH & California 65, as material testing facilities within our State-of-the-art testing Laboratories at Pune and Bengaluru are approved by NABL. We also provide awareness sessions on RoHS & REACH compliance and various other directives which have importance towards Environment and Society. TUV India also does product certification such as CE Mark and GS Sign (conformity to European norms). TÜV India partners with TÜV NORD to certify the CE mark of the European Union.

Standing for the French Conformité Européenne, the CE mark has become the passport for product groups wishing to enter the European market. As a notified body to the European Union, TÜV India will assist your company to achieve compliance testing in a domain regulated by EC directives (Low-voltage directive, toys directive, machinery directive, EMC directive etc.). Within the framework of the CE mark we are therefore able to offer all the requisite services on a one-stop basis.

The necessary areas of the CE conformity assessment include the following :

  • Type approval testing
  • Compatibility tests (electromagnetic, biological compatibility etc.)
  • Safety tests in our own testing laboratories
  • Examination of product design
  • Preparation of expert appraisal reports
  • Certification of quality systems. 

About The Author

Sumankumar GuptaSenior Lead Auditor - IMS
TUV India Pvt Ltd