How to Comply With RoHS 2

by Source Intelligence

on February 28, 2018

 

0:00 Introduction

Welcome to the Source Intelligence brief overview of European regulation RoHS 2. Today we are going to focus on three key items: what is RoHS 2, who is responsible for complying, and how to comply. 

 

0:20 What is RoHS 2?

The restriction of hazardous substances, often referred to as RoHS 2, is a directive of the European Union. This regulation restricts 6 high-risk substances in electronic and electric equipment. The intention of RoHS 2 is to protect human health and the environment from e-waste toxins. Under this directive, technical documentation is required for verifying compliance and conducting further business within the EU. 

 

0:48 RoHS Restricted Substances

RoHS 2 requires safer substitutions for the following 6 restricted substances: 

  • Polybrominated diphenyl ethers (PBDE)
  • Polybrominated biphenyls (PBB)
  • Hexavalent Chromium (Cr VI)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Lead (PB)

If any of these are used during product manufacturing, they must abide by RoHS2 concentration safety limits. 

 

1:10 Who Does RoHS Apply To?

The RoHS 2 requirements apply to end products, specifically electrical and electronic equipment that fall within the scope of the directive, That means it applies to any company importing these types of products to or conducting business within the EU. 

 

1:29 How to Comply with RoHS 2

To achieve RoHS 2 compliance, a set of substance safety limits must be met. To meet this limit, a substance must be measured by its homogenous weight, meaning the substance at its raw level cannot be broken down into further different materials. Examples of homogeneous materials include glass, ceramics, metals, alloys, and paper. 

 

1:50 11 Product Categories Within the Scope of RoHS

Currently, there are  11 categories for products that fall within the scope of RoHS 2. 

  1. Large household appliances 
  2. Small household appliances
  3. Computing and communications equipment
  4. Consumer electronics
  5. Lighting
  6. Power tools
  7. Toys and sports equipment
  8. Medical devices and equipment
  9. Control and monitoring equipment (currently exempt) 
  10. Automatic dispensers
  11. All other EEE

Category 9 products, which are control and monitoring equipment, are currently exempt from RoHS 2. 

 

2:19 Who is Exempt from RoHS?

There are exemptions in RoHS 2 and there are permanent exclusions. Permanent exclusions are usually tools that are considered necessary and stationary in many cases. These include:

  • Large scale machines
  • Construction equipment
  • Space equipment
  • Military equipment
  • Specific medical devices

 

2:37 Declaration of Conformity for RoHS

When manufacturers, distributors, or others are placing products on the market within the EU, they must provide a RoHS 2 disclosure. Specifically, a declaration of conformity, which demonstrates compliance with RoHS 2. There are several steps involved. First, a Declaration of Conformity must be completed and submitted. Once the declaration has been approved, a CE trademark is issued. A product marked with a CE trademark is recognized as compliant under the regulation. 

 

3:09 RoHS 2 Enforcement

All countries within the European Union are responsible for the enforcement of RoHS 2. Implementation will be performed differently by EU member states. However, the core restrictions remain. Enforcement agencies for each country will send a request for documentation to manufacturers or industries operating within the EU. Those who don’t comply with RoHS 2  are subject to fines, penalties, and indictment. Products cannot be sold within the EU until the regulation is satisfied and CE trademarked. 

 

3:40 Amendments to RoHS

A recent directive amends EU RoHS 2 to restrict four additional substances. The four new substances are all phthalates:

  • Bis(2-Ethylhexyl) phthalate (DEHP)
  • Benzyl butyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

The maximum amount a product may have of each of these phthalates is 0.1% at the homogeneous level. The most common application of these phthalates are as plasticizers in wire coating. 

 

4:11 Important Dates for RoHS

Expiring exemptions can work in two different ways. First, an exemption for which a renewal application was submitted in due time will remain valid at least 12 months beyond the date of the decision for application renewal. Second, exemptions for which no application for renewal was submitted in due time will expire as indicated in the RoHS2 directive or annexes. There are key dates for expiring references that can fluctuate under RoHS 2. It is important to note that this regulation is a living document and not static. Therefore, new developments can be implemented yearly and dates are subject to change. Key dates for expiring references are:

  • July 21st, 2021 for medical devices, monitoring, and control instruments;
  • July 21st, 2023 for in-vitro diagnostic medical devices;
  • And July 21st, 2024 for industrial monitoring and control instruments.

 

5:14 How to Comply with RoHS?

RoHS 2 is continuously evolving and full of amendments. This means deadlines fluctuate and expire which can make compliance very confusing. It’s important that you are constantly collecting information from your supply chain to understand the contents of the products that you sell. The best way to comply is to collect product information from suppliers so you can understand the materials and substances contained in those products. 

 

5:41 How Source Intelligence Can Help

Source Intelligence lets you collect supply chain data on all of your products. You can then compare your products to the list of substances covered by RoHS 2. We will also alert you to any changes to RoHS 2. Our platform makes the daunting task of EU RoHS 2 compliance straightforward and cost-effective. 

 

6:00 Key Takeaways

In summary, what is RoHS 2? RoHS 2 is an EU directive designed to protect the environment and humans from e-waste toxins. Who is responsible for compliance? RoHS 2 impacts any company importing or conducting business within the EU (with some exceptions). How to comply? Collect information from your supply chain on the contents of the products you sell. 

Thank you for your attention. For more information, please go to sourceintelligence.com or click the button below to see what our RoHS compliance solution can do for you. 

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