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RoHS

The Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment 2002/95/EC; commonly referred to as the Restriction of Hazardous Substances Directive or RoHS) was adopted in February 2003 by the European Union. The RoHS directive took effect on 1 July 2006, and is required to be enforced and become law in each member state. 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.

 

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

  1. Lead (Pb)
  2. Mercury (Hg)
  3. Cadmium (Cd)
  4. Hexavalent chromium (Cr6+)
  5. Polybrominated biphenyls (PBB)
  6. Polybrominated diphenyl ether (PBDE)

 

PBB and PBDE are flame retardants used in several plastics.

The maximum permitted concentrations are 0.1% or 1000 ppm (except for cadmium, which is limited to 0.01% or 100 ppm) 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.

 

The directive applies to equipment as defined by a section of the WEEE directive. The following numeric categories apply:

  1. Large and small household appliances.
  2. IT equipment.
  3. Telecommunications equipment (although infrastructure equipment is exempt in some countries)
  4. Consumer equipment.
  5. Lighting equipment—including light bulbs.
  6. Electronic and electrical tools.
  7. Toys, leisure, and sports equipment.
  8. Medical devices (currently exempt)
  9. Monitoring and control instruments (currently exempt)
  10. Automatic dispensers.

 

It 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. It is enabled through two PDF forms that 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.

 

Examples of product components containing restricted substances

RoHS restricted substances have been used in a broad array of consumer electronics products. Examples of leaded components include:

  • paints and pigments
  • PVC (vinyl) cables as a stabilizer (e.g. power cords, USB cables)
  • solders
  • printed circuit board finishes, leads, internal and external interconnects
  • glass in television and photographic products (e.g. CRT television screens and camera lenses)
  • metal parts
  • lamps and bulbs
  • batteries

Product category 8 and 9 exclusions

Medical devices, and monitoring and control instruments comprise RoHS Category 8 and Category 9 products respectively. The EU recognizes that these products are manufactured in small numbers and generally have a long product life. Further, these products are often used in mission-critical applications where their failure can reasonably be expected to be extremely disruptive, if not catastrophic. Released in July 2006, theReview of Directive 2002/95/EC (RoHS) Categories 8 and 9 – Final Report recommended that Category 8 and 9 products remain exempt from the RoHS directive until 2012 or 2018 depending upon specific product sub-categories and applications. Since the EU has not yet adopted this recommendation, the exact timing of RoHS application to Category 8 and 9 products remains uncertain.

 

On September, 25th 2010, the European Union (EU) published in its Official Journal a European Commission decision amending the Restriction of Hazardous Substances (RoHS) for applications containing lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls or polybrominated diphenyl ethers in electric and electronic equipment. The new directive 2010/571/EU1 adapts RoHS exemptions to scientific and technical progress as an Annex to Article 4(1) of Directive 2002/95/EC (RoHS). Exemptions listed in the Annex of 2010/571/EU are amended in a way that:

  • exemptions are maintained if the hazardous substances in the applications are still impracticable to be eliminated
  • exemptions are removed if the hazardous substances in the applications are possible to be removed or substituted
  • exemptions are set with expiry dates if the hazardous substance in the applications feasible to be removed or substituted in the future
  • the required mercury level in the lighting products are altered, with given limitation and phase out dates

 

The new directive introduces some significant changes to the earlier existing exemption rules. Not only have some allowed values changed but some exemptions have been detailed to specific applications where they have been more general in the past. Some of the listed exemptions have a short life span and will expire soon, e.g. in January 2011.