Restriction of Hazardous Substances Directive - Details

Details

Each European Union member state will adopt its own enforcement and implementation policies using the directive as a guide.

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. Hexavalent chromium is used in the welding, grinding, or brazing of stainless steel.

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.

As an example, a radio is composed of a case, screws, washers, a circuit board, speakers, etc. The screws, washers, and case may each be made of homogenous materials, but the other components comprise multiple sub-components of many different types of material. For instance, a circuit board is composed of a bare PCB, ICs, resistors, capacitors, switches, etc. A switch is composed of a case, a lever, a spring, contacts, pins, etc., each of which may be made of different materials. A contact might be composed of a copper strip with a surface coating. A speaker is composed of a permanent magnet, copper wire, paper, etc.

Everything that can be identified as a homogeneous material must meet the limit. So if it turns out that the case was made of plastic with 2,300 ppm (0.23%) PBB used as a flame retardant, then the entire radio would fail the requirements of the directive.

In an effort to close RoHS loopholes, in May 2006 the European Commission was asked to review two currently excluded product categories (monitoring and control equipment, and medical devices) for future inclusion in the products that must fall into RoHS compliance. In addition the commission entertains requests for deadline extensions or for exclusions by substance categories, substance location or weight. New legislation was published in the official journal in July, 2011 which supersedes this exemption.

Note that batteries are not included within the scope of RoHS. However, in Europe, batteries are under the European Commission's 1991 Battery Directive (91/157/EEC), which was recently increased in scope and approved in the form of the new battery directive, version 2003/0282 COD, which will be official when submitted to and published in the EU's Official Journal. While the first Battery Directive addressed possible trade barrier issues brought about by disparate European member states' implementation, the new directive more explicitly highlights improving and protecting the environment from the negative effects of the waste contained in batteries. It also contains a program for more ambitious recycling of industrial, automotive, and consumer batteries, gradually increasing the rate of manufacturer-provided collection sites to 45% by 2016. It also sets limits of 5 ppm mercury and 20 ppm cadmium to batteries except those used in medical, emergency, or portable power-tool devices. Though not setting quantitative limits on quantities of lead, lead-acid, nickel, and nickel-cadmium in batteries, it cites a need to restrict these substances and provide for recycling up to 75% of batteries with these substances. There are also provisions for marking the batteries with symbols in regard to metal content and recycling collection information.

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

1. Large household appliances.
2. Small household appliances.
3. IT & 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 (exemption removed in July, 2011)
9. Monitoring and control instruments (exemption removed in July, 2011)
10. Automatic dispensers.
11. Semiconductor devices

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.