Key details about the RoHS directive
The restricted materials
In order to be RoHS compliant, products must contain no more than 0.1% of the following substances, except cadmium (no more than 0.01%):
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent chromium (CrVI)
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ethers (PBDE)
- Four types of phthalates (DEHP, BBP, DBP, DIBP) – effective as of 22 July 2019
RoHS compliance testing
Because of the far reach of the directive, and the development of globalisation, RoHS compliance testing is standard practice for the majority of electronics manufacturers and distributors across the world. Without putting electrical and electronic goods through testing, they are not compliant and therefore cannot be sold in the EU.
Affected product categories
- Large household appliances
- Small household appliances
- IT and telecommunications equipment
- Consumer equipment
- Lighting equipment
- Electrical and electronic tools
- Toys, leisure and sports equipment
- Medical devices
- Monitoring and control instruments including industrial monitoring and control instruments
- Automatic dispensers
- Other EEE not covered by any of the above categories
Electrical and electronic product categories exempted from RoHS
Some product types are RoHS-exempt for a variety of reasons, such as some types of equipment used in large scale industry or in military applications. Lead is also exempt in some very specific applications. Note that the list of exemptions is liable to change. For example, medical devices were exempt in the original version of the RoHS directive, but the scope has since widened to include many types of medical devices.
The development of RoHS
As of 2019, there have been three versions of RoHS since the original was published in 2002 (Directive 2002/95/EC). RoHS 2 (Directive 2011/65/EU) widened the scope of the directive to include a broader range of EEE, including cables and spare parts, and also required additional compliance recordkeeping. RoHS 3 (Directive 2015/863) added the four phthalates to the list of restricted materials.
RoHS compliance: responsibility and enforcement
Compliance with the directive is concerned with EEE products that are placed on the EU market, not specifically with manufacturing. This means that an electric or electronic product that contains the restricted materials only violates the RoHS once it is distributed or sold in the EU. Therefore, responsibility to comply with RoHS also lies with the retailer and importer of the product, not just the manufacturer.
Manufacturers, distributors and importers of EEE products must adhere to certain documentation and labelling standards in order to show compliance. This includes labelling products within the scope of RoHS with the CE mark, which also indicates compliance with a range of other health and safety standards. In addition, they must provide a Declaration of Conformity per product, stating that it does not contain any of the restricted substances listed in the directive.
Failure to comply with the RoHS directive is penalised on a national basis by enforcement bodies, and the consequences can therefore differ considerably between EU member states. Typically, however, penalties for non-compliance involve a fine.
More interesting topics to read about
See here for more details about the certified product groups covered under the RoHS directive, from consumer electronics to appliances, and about why non-electrical items may also be covered.