RoHS Regulation - Frequently Asked Questions

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RoHS is the commonly known term referring to both the original RoHS Directive and the RoHS Recast

Directive , which replaced the original RoHS as of January 1 2013. You will also see RoHS II referred to as

the RoHS Recast. The RoHS recast contains the same principal restrictions as the previous RoHS Directive

but has an increase in requirements compared to the previous RoHS directive.

EU ROHS DIRECTIVEFREQUENTLY ASKED QUESTIONS

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TABLE OF CONTENTS1. What is RoHS? ............................................................................................................................................3

2. What is RoHS II? How does it differ from RoHS? .................................................................................4

3. What substances are included in RoHS? ..............................................................................................5

4. What does this mean to me as a non-European manufacturer? .................................................... 6

5. How can I go about confirming compliance with RoHS? ..................................................................6

6. What are Exemptions, and why are they important? ..........................................................................6

7. How can I declare myself as compliant with RoHS/RoHS II? .......................................................... 7

8. What is required in a declaration? ...........................................................................................................8

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1. WHAT IS ROHS?RoHS is the commonly known term referring to both the original RoHS Directive1 and the

RoHS Recast Directive2, which replaced the original RoHS as of January 1 2013. You will also

see RoHS II referred to as the RoHS Recast. The RoHS recast contains the same principal

restrictions aas the previous RoHS Directive but has an increase in requirements compared to

the previous RoHS directive.

As a supplier or manufacturer receiving a request from Assent, the most pertinent aspects

of RoHS are that it applies to EEE3 and engenders a ban of the use of 6 substances past

the applicable threshold (or maximum concentration value – MCV). These substances are

listed in Question 3.

There are a number of other requirements under RoHS that may apply to you, please contact

Assent if you would like further assistance with RoHS compliance.

1 Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment

2 Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (recast)

3 There are timelines of applicability associated to certain categories of EEE and there are certain EEE considered out of scope.


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2. WHAT IS ROHS II? HOW DOES IT DIFFER FROM ROHS?RoHS II (or the RoHS recast) replaced RoHS in January of 2013. The same 6 substances are

dealt with in both directives however there are a number of additional compliance requirements

that arose in the recast. Below is a high-level summary of those additions:

• RoHS II now falls under the CE Mark

• Associated labelling and documentation requirements

• Exemptions are expiring

• Any exemptions being used must be disclosed

• New substances can be added and there are 4 that have been prioritized for consideration:

• HBCDD (Hexabromocyclododecane)

• DEHP (Bis(2-ethylhexyl) phthalate)

• BBP (Benzyl butyl phthalate)

• DBP (Di-n-butyl phthalate)


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3. WHAT SUBSTANCES ARE INCLUDED IN ROHS?There are six substances that each have a threshold based on weight. The numbers are listed below:

ROHS RESTRICTED MATERIALS:

SUBSTANCE ROHS LIMIT: MCV – MAXIMUM CONCENTRATION VALUES

LEAD (PB) < 0.10% = < 1,000 PPM

MERCURY (HG) < 0.10% = < 1,000 PPM

HEXAVALENT CHROMIUM (CR VI) < 0.10% = < 1,000 PPM

CADMIUM (CD) < 0.01% = < 100 PPM

POLYBROMINATED BIPHENYLS (PBB)

< 0.10% = < 1,000 PPM

POLYBROMINATED DIPHENYL ETHERS (PBDE)

< 0.10% = < 1,000 PPM


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4. WHAT DOES THIS MEAN TO ME AS A NON-EUROPEAN MANUFACTURER?Although this directive is European based, it requires that all companies that import into the

EU adhere to them. Although this may not affect your sales directly; it is important to note that,

if you are receiving requests from Assent, it affect the sales of your client base. As such it is

important to have information available to your customers should they request it.

5. HOW CAN I GO ABOUT CONFIRMING COMPLIANCE WITH ROHS?Manufacturers can run their own quality assurance divisions to verify that none of their products

contain the RoHS restricted substances. Alternatively manufacturers may also use third party

companies such as Assent to survey suppliers that make the parts/components that to into

your products. Additionally, testing can also be done to verify the substance breakdown of the

products you sell.

6. WHAT ARE EXEMPTIONS, AND WHY ARE THEY IMPORTANT?Exemptions to RoHS are granted to narrowly-defined applications for which the elimination of

the prohibited substance is technically or scientifically impracticable or when the only available

substitution produces more negative than positive benefits to the environment, health, or

consumer safety.


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Exemptions are temporary in nature and, under the RoHS recast, are subject to review at least

every four years, until such time as a reliable and safe substitution is available. For this reason,

many exemptions carry an expiration date. You can see the full Exemptions list here.

7. HOW CAN I DECLARE MYSELF AS COMPLIANT WITH ROHS/ROHS II?Under the RoHS recast, manufacturers of finished products must declare compliance via:

• CE mark

• Declaration of Compliance fulfilling the required elements listed in Annex II of the RoHS recast.

• CE Technical File

Documentation requirements are found in Module A of Annex II of Decision 768/2008/EC.

For unfinished products (components and parts), the majority of manufacturers have chosen to

use declarations to confirm compliance with the RoHS recast. Although some manufacturers

choose to provide chemical breakdowns (Full Material Declarations (FMDs)) of their products

instead. This is entirely up to the manufacturer in deciding how this information is communicated

to their clients.


http://assentcompliance.com/supplier-success-center/files/Assent-RoHS-ExemptionList.pdf

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8. WHAT IS REQUIRED IN A DECLARATION?For parts and components, declarations requirements are not dictated in the actual directive.

For an official standard, one can refer to EN 62474:2012 – “Material declaration for products

of and for the electrotechnical industry”. There are typical declaration acceptance standards

and these are requirements for Assent clients:

• Company Letterhead: This includes, Logo, Address and contact information of the company

representative

• Dated Letter: A date when this declaration has taken place

• Appropriate Regulatory Reference: You will need to mention that you stating a declaration

for RoHS, somewhere on the document.

• Clear Positional Statement: Declare whether or not you are compliant with RoHS II

• Whether or not any exemptions are used: You will also need to specify which exemptions

have been used if any

• Appropriate Signatory: Have a company representative sign the document to confirm

authenticity. This isn’t required but heavily encouraged.


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RoHS Regulation - Frequently Asked Questions