The Restriction of Hazardous Substances
Directive (RoHS) 2002/95/EC was adopted in February 2003 by the European
Union. The RoHS directive takes effect on July 1, 2006, but is not a law; it is
simply a directive. 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 (any
broken or unwanted electrical or electronic appliance. It is a point of concern
considering that many components of such equipment are considered toxic)
Each European Union member state will
adopt its own enforcement and implementation policies using the directive as a
guide. Therefore, there could be as many different versions of the law as there
are states in the EU.
RoHS is often referred to as the "lead-free"
directive, but it restricts the use of the following 6 substances:
PBB and PBDE are flame retardants used in
some plastics.
The maximum concentrations are 0.1%
(except for Cadmium which is limited to 0.01%) 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.
As an example, a radio comprises a case,
screws, washers, a circuit board, speakers etc. A circuit board comprises a
bare PCB, ICs, resistors, switches etc. A switch comprises a case, a lever, a
spring, contacts, pins etc. The contact might comprise a copper strip with a
surface coating.
Everything that can be identified as a
different material must meet the limit. So if it turns out that the case was
made of plastic with 2300 ppm (0.23%) PBB used as a flame retardant, then the
entire radio would fail the requirements of the directive.
Note that batteries are not included
within the scope of RoHS, therefore NiCd, Lead-acid and Mercury batteries are
permitted despite the use of restricted substances.
The directive applies to equipment as
defined by a section of the WEEE directive. These are:
It does not apply to fixed industrial
plant and tools. Compliance is the responsibility of the company which 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.
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.
There is also legislation in China (often
referred to as "China RoHS") that has similar restrictions. Unlike EU
RoHS (products are included unless specifically excluded), there will be a list
of products to which the regulations apply (products are excluded unless
specifically included). There are some products which probably will be included
for China RoHS which are not in scope for EU RoHS - e.g. radar systems.
However, the details of the requirements and list of included products have not
been finalized by the Chinese government. The legislation is scheduled to take
effect 1 March 2007.
Japan does not have any direct legislation
dealing with the RoHS substances, but its recycling laws have spurred the
Japanese manufacturers to move to a lead-free process. These companies have
also been proactive in phasing out other harmful materials which will, in
effect, make their products RoHS compliant.
In addition, California has adopted
similar legislation which will take effect on January 1, 2007. The California
law will use the EU RoHS directive as its guide. These, as well as other
legislation, effectively makes RoHS a world wide compliance issue.
The member exporters of the
council may please note that the European Commission has come out with a
directive 2002/95/EC on restriction of hazardous substance known as RoHS (Restriction of Hazardous Substance). It is going to
come into effect from
In
the Handicrafts sector such products whose functionality is predominately
dependent on electrical and electronic components would be liable for RoHS. For details on the EU directive (Directive
2002/95/EC) the members may click on the link given below.
EU
Directive (RoHS) 2002/95/EC
*******