About the RoHS Directive
The "Directive of the European Parliament and of the Council on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS)" already became European law on 13th February 2003. This Directive aims at tackling the problem of increasing electrical and electronic equipment waste. The RoHS Directive requires substitution of various heavy metals and brominated flame retardants in electrical and electronic equipment.
Requirements of the Directive are summarised below to allow manufacturers to have a brief understanding of the requirements. For details of the Directive, it is suggested to visit the following website:
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS)
This Directive requires producers to phase out the use of certain hazardous substances in electrical and electronic equipment by 1 July 2006.
The scope of this Directive covers both commercial and domestic equipment. It applies to electrical and electronic equipment falling under the categories 1,2,3,4,5,6,7 and 10 set out in Annex IA to Directive No 2002/96/EC (WEEE) and to electric light bulbs, and luminaires in household.
Substances to be phased out by 1 July 2006
With effect from 1 July 2006 new electrical and electronic equipment put on the market shall not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE).
Maximum Concentration Values:
Applications of lead, mercury, cadmium and hexavalent chromium in the following conditions are exempted from the requirements:
1. Mercury in compact fluorescent lamps not exceeding 5 mg per lamp
2. Mercury in straight fluorescent lamps for general purposes not exceeding:
- halophosphate 10 mg
- triphosphate with normal lifetime 5 mg
- triphosphate with long lifetime 8 mg.
3. Mercury in straight fluorescent lamps for special purposes.
4. Mercury in other lamps not specifically mentioned in this Annex.
5. Lead in glass of cathode ray tubes, electronic components and fluorescent tubes.
6. Lead as an alloying element in steel containing up to 0.35% lead by weight, aluminium containing up to 0.4% lead by weight and as a copper alloy containing up to 4% lead by weight.
7. - lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)
- lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunications
- lead in electronic ceramic parts (e.g. piezoelectronic devices).
8. Cadmium and its compounds in electrical contacts and cadmium plating except for applications banned under Directive 91/338/EEC (1) amending Directive 76/769/EEC (2) relating to restrictions on the marketing and use of certain dangerous substances and preparations
9. Hexavalent chromium as an anti-corrosion of the carbon steel cooling system in absorption refrigerators.
10. Lead used in compliant pin connector systems
11. Lead as a coating material for the thermal conduction module c-ring
12. Lead and cadmium in optical and filter glass
13. Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80% and less than 85% by weight
14. Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit Flip Chip packages
15. DecaBDE in polymeric applications
16. Lead in lead-bronze bearing shells and bulbs
17. Lead in linear incandescent lamps with silicate coated tubes
18. Lead halide as radiant agent in High Intensity Discharge (HID) lamps used for professional reprography applications
19. Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb) as well as when used as specially lamps for diazo-printing reprography, lithography, insect traps, photochemical and curing processes containing phosphors such as SMS ((Sr,Ba)2MgSi2O7:Pb)
20. Lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact Energy Saving Lamps (ESL)
21. Lead oxide in glass used for bonding front and rear substrates of flat fluorescent lamps used for Liquid Crystal Displays (LCD)
22. Lead and cadmium in printing inks for the application of enamels on borosilicate glass.
23. Lead as impurity in RIG (rare earth iron gamet) Faraday rotators used for fibre optic communication systems.
24. Lead in finishes of fine pitch components other than connectors with a pitch of 0.65mm or less with NiFe lead frames and lead in finishes of fine pitch components other than connectors with a pitch of 0.65mm or less with coppler lead frames.
25. Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors.
26. Lead oxide in plasma display panels (PDP) and surface conduction electron emitter displays (SED) used in structural elements, notably in the front and rare glass dielectric layer, the bus electrode, the black stripe, the address electrode, the barrier ribs, the seal frit and frit ring as well as in print pastes.
27. Lead oxide in the glass envelope of Black Light Blue (BLB) lamps.
28. Lead alloys as solder for transducers used in high-powered (designated to operate for several hours at acoustic power levels of 125 dB SPL and above) loudspeakers.
29. Hexavalent chromium in corrosion preventive coatings of unpainted metal sheetings and fasterners used for corrosion protection and Electromagnetic Interference Shielding in equipment falling under category three of Directive 2002/96/EC (IT and telecommunications equipment). Exemption granted until 1 July 2007.
30. Lead bound in crystal glass as defined in Annex I (Category 1,2,3 and 4) of Council Directive 69/493/EEC
The exemption list is being reviewed and subject to adjustment in the coming months.
Categories of Electrical and Electronic Equipment Affected
|Categories of Electrical and
Electronic Equipment Affected
|Large household appliances
||Refrigerators, washing machines, microwaves, air conditioners…
|Small household appliances
||Vacuum cleaners, irons, hair dryers, shavers, clocks…
|IT and telecommunications equipment
||Mainframes, personal computing, facsimile, telephone…
||Radio, television, Hi-Fi…
||CFLs, flow pressure sodium lamps…
|Electrical and electronic tools
(with the exception of large-scale
stationary industrial tools)
|Drills, saws, sewing machine…
|Toys, leisure and sports equipment
||Electric trains or car racing sets, hand-held video game consoles…
||Automatic dispenser for hot or cold bottles or cans
|Electric light bulbs
|Luminaries in households
Non-binding Flow Chart for RoHS Compliance Assessment Using Documentation (click to enlarge)
Source: EU RoHS Enforcement Authorities Informal Network
Table 1 - Typical List of Overview Documentation (Common to both Route A and Route B)
|Point of contact within the organization that will deal with the RoHS enforcement request.
|This should include the size of the organization, product range and approximate levels of sales.
|Approach to compliance|
|This should be a general overview of any compliance systems that the company has in place and which are suitable for assisting compliance with the RoHS Directive.
|An overview of the data quality system, (in those cases where the producer relies significantly upon supplier information to demonstrate compliance)|
|This could include risk assessments, acceptance criteria, purchasing procedures and any other relevant documentation and may be a combination of both process-based and product/part-based documentation.|
Table 2 - Typical Compliance Documentation List
Route A: Process-based Technical Documentation
|Compliance Assurance System (CAS)|
|1. A definition of the purpose of the system, its essential requirements and specification. This specification should cover compliance both within the company and within the supply chain
2. A formally defined process which implements the requirements of the system and is integrated within the organisation quality and management systems
3. A technical documentation system (paper and/or electronic) to support the process and measures to assure conformity with the requirements of the system together with necessary training, tools and infrastructure.
|Evidence of Active Control of the CAS|
|4. Results of internal and supplier audits to validate Compliance Assurance System and/or processes. i.e. the supplier's ability to assure compliance
5. Evidence that the system is being followed including results of product specific conformance assessments comprising items such as product assessments (including justification of RoHS categorisation and use of exemptions), materials declarations, procurement, inventory and production controls and substance analysis where appropriate.
6. Overview of any internal data system used for the management of RoHS compliance data.
Route B: Product/Part-based Technical Documentation
|7. Producers' or suppliers' warranties / certificates declaring that the use of the restricted substances is within the permitted levels.
8. Producers' or suppliers' completed materials declaration for each part (including revision for revised parts) and justification of RoHS categorisation and use of exemptions. These declarations would be limited to the list of RoHS substances, not full materials declarations.
9. Analysis report for homogeneous materials in parts/components, (which could be the producers or suppliers own internal or external test results). The test results should refer to homogeneous materials in parts / components.
10. Those who use approach B only (SMEs) must also provide evidence that procedures are being followed to show that materials declarations have been assessed to determine if they can be trusted. Enforcement authorities will also need to see documented compliance procedures.
California RoHS update
China RoHS (Chinese version only)
Norwegian RoHS proposal - the Prohibition on Certain Hazardous Substances in Consumer Products
On the 8th of June Norway notified the WTO of its intention to prohibit 18 substances from consumer goods in Norway - with a few exceptions. Called the Prohibition on Certain Hazardous Substances in Consumer Products, the name bears more than a passing resemblance to the EU RoHS Directive, Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment.
The scope is much wider than RoHS. It covers all consumer goods - with a few exceptions. Consumer goods are defined in the draft regulations as “by consumer product what is meant is any product that is intended for consumers or that can reasonably be expected to be used by consumers”. This includes item groups such as clothing, bags, construction, toys etc. The regulation does not apply to food products, food packaging, fertilizers, medical equipment and tobacco, as well as means of transport, permanently mounted equipment for means of transport and tyres and similar accessories for means of transport.
The regulation proposes to restrict 18 substances, with only 2 (lead and cadmium) being in common with the generic EU RoHS. The ones that are more relevant to the Electrical and Electronic Industry are:
1. Arsenic (Gallium Arsenide devices),
2. TBBPA, (Flame retardant as used in FR4 PCB Substrate)
3. HBCD (flame retardant)
4. DEHP (PVC Plasticiser)
5. Bisphenol A. (monomer used for polycarbonate)
6. Lead (any consumer product not covered by RoHS excluding medical devices)
7. Cadmium (any consumer product not covered by RoHS excluding medical devices)
The limit values, some as low as 25ppm (Bisphenol A), are applied at homogenous level, in a similar manner to EU RoHS.
The overall comparison to EU RoHS is that:
1. It is much broader, not confined to Electrical and Electronic Equipment
2. Lead and lead compounds are more stringent - MCV of 0.01 weight % (compared to 0.1weight% as required by EU RoHS)
3. More elements and substances - 18 compared to 6
The Norwegian proposal is scheduled to be adopted on 15 December 2007 and come into force on 1 January 2008.