RoHS Compliance

RoHS Consulting Services

With iCertifi’ s expertise and international network, our RoHS Compliance Consultants provide a comprehensive solution for RoHS requirements, conformity and certification, which enables you to meet compliance goals on time and within budget.

What is RoHS?

RoHS stands for Restriction of Hazardous Substances. It is a compliance procedure that impacts lots of electrical products and the electronics industry as a whole. The original policy is known as Directive 2002/95/EC. This came from the EU originally in 2002 and restricts six materials that are hazardous in electronic and electrical products. Every product in the market of the EU has had to pass RoHS compliance since July 1, 2006.

The original six hazardous substances restricted in the directive are mercury, cadmium, lead, hexavalent chromium, PBB (polybrominated biphenyls), and PBDE (polybrominated diphenyl ethers). There are a few limited exemptions.

The 2002/95/EC directive applies to product distributors and importers, manufacturers, and authorized representatives of large household appliances like refrigerators, small household appliances like vacuum cleaners, communications and computing equipment, lighting, consumer electronics, power tools, sports equipment (e.g. electric trains and video games), toys, and automatic dispensers like ATMs and vending machines.

Organizations can prove their products are RoHS compliant by showing a letter of compliance as issued by a company employee or a third-party testing service.

What is the difference between RoHS 2 and RoHS 3?

There were revisions made to the EU directive in 2011. This was referred to as Directive 2011/65/EU and was known as RoHS 2 or RoHS-Recast. As well as the six hazardous materials, the updated directive includes a CE-marking directive, meaning that RoHS compliance is now required for the CE marking of any product. There were also a couple of new categories added, as well as additional recordkeeping requirements for additional compliance.

In 2015, there were further revisions. This is referred to as Directive 2015/863 or RoHS 3. This directive includes four extra restricted hazardous substances to the existing list of six. These substances are phthalates – bis (2-Ethylhexyl) phthalate (DEHP), benzyl butyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP).

Why must a manufacturer comply with RoHS requirements?

Since around 90% of electrical and electronic products end up in landfills, manufacturers have to ensure their products are free from hazardous levels of certain substances. Manufacturers must show extensive data from supply chains to show that their products are compliant. If one component doesn’t comply, then the whole product isn’t compliant.

Companies must request compliance certificates from all suppliers for the parts used in the equipment or product at a homogenous level.

What is the method of testing for RoHS?

There are different methods of testing for RoHS. These include:

  • Non-destructive analysis – this means using non-destructive X-ray fluorescence (XRF) methods
  • Wet chemical analysis – this happens if there are high levels of substances found which means more testing is required. This way of testing provides accurate results. It also verifies anomalies that might have been found in the XRF analysis.
  • XRF screening – it’s easy to get a quick indication as to the presence of any hazardous substances and where they are using XRF screening. This method of testing is useful for getting an overview of your end product.

What are the steps to RoHS Compliance?

  1. Explain how your product environmental requirements are monitored.
  2. Set up your action plan for RoHS compliance.
  3. Carry out RoHS testing – each part of the product needs to be tested at the source level.
  4. Produce a DoC – Declaration of Conformity. This must include:
    • an ID number – e.g. product name and version, the manufacturer’s legal name and address, the statement “This Declaration of Conformity is issued under the sole responsibility of the manufacturer.
    • An image or product description
    • The requirements that your product complies with
    • The issue date
    • The title and signature of an authorized person
  1. Conformity marking – e.g. CE marking

What are the restricted substances included in the RoHS directive?

The RoHS directive specifies the maximum levels of the following:

  • Benzyl butyl phthalate (BBP): < 1000 ppm
  • Bis (2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
  • Cadmium (Cd): < 100 ppm
  • Dibutyl phthalate (DBP): < 1000 ppm
  • Diisobutyl phthalate (DIBP): < 1000 ppm
  • Hexavalent Chromium: (Cr VI) < 1000 ppm
  • Lead (Pb): < 1000 ppm
  • Mercury (Hg): < 1000 ppm
  • Polybrominated Biphenyls (PBB): < 1000 ppm
  • Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm

Is the RoHS initiative limited to European Union or are there requirements worldwide?

Even if your product isn’t being sold in the EU, many places require a similar certification. These are California, China, Japan, Taiwan, Korea, Norway, India, Ukraine, Singapore, UAE, Turkey, Eurasia/Russia, and Brazil.

How to Demonstrate EU RoHS Compliance?

  1. Testing of the ten substances
  2. Process auditing – inspecting of all processes of manufacture
  3. Review of documentation
  4. A certification statement is issued

Enforcement of RoHS

Individual states take charge of their own enforcement and budget for it. The penalties, therefore, vary between member states in terms of both type and amount. One type of penalty is a fine, which is like a speeding fine. Another penalty is denying importation.