Does your company fall under expiring RoHS exemptions? Time to check!!!!
When the European Union implemented RoHS, they understood the industry was not ready for a full restriction. As part of the RoHS implementation, exemptions were created for defined specific permitted uses for these substances. Each exemption was assigned an expiry date by which time these specific use cases for restricted substances would no longer be permitted. Below are the exemptions that are getting expired in 2019. Exemption Applicable category * End date 6(a) – Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0.35 % lead by weight 1 to 7 and 10 30 – June – 2019 6(b) – Lead as an alloying element in aluminum containing up to 0.4 % lead by weight 1 to 7 and 10 30 – June – 2019 9(b)-(I) – Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications 1 to 7 and 10 21 – July – 2019 21 – Cadmium in phosphor coatings in image intensifiers for X-ray images until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 8 and 9 31 – Dec – 2019 24 – Lead enabling vacuum tight connections between aluminum and steel in X-ray image intensifiers. 8 and 9 31 – Dec – 2019 30 – Hexavalent chromium in alkali dispensers used to create photocathodes in X-ray image intensifiers until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 8 and 9 31 – Dec – 2019 32 – Lead in solders on printed circuit boards of detectors and data acquisition units for Positron Emission Tomographs which are integrated into Magnetic Resonance Imaging equipment. 8 and 9 31 – Dec – 2019 38 – Lead in solder in one interface of large area stacked die elements with more than 500 interconnects per interface which are used in X-ray detectors of computed tomography and X-ray systems. Expires on 31 December 2019. May be used after that date in spare parts for CT and X-ray systems placed on the market before 1 January 2020. 8 and 9 31 – Dec – 2019 *EU RoHS Categories: Category 1 Large household appliances: refrigerators, washers, stoves, air conditioners Category 2 Small household appliances: vacuum cleaners, hair dryers, coffee makers, irons Category 3 Computing and communications equipment: computers, printers, copiers, phones Category 4 Consumer electronics: TVs, DVD players, stereos, video cameras Category 5 Lighting: lamps, lighting fixtures, light bulbs Category 6 Power tools: drills, saws, nail guns, sprayers, lathes, trimmers, blowers Category 7 Toys and sports equipment: videogames, electric trains, treadmills Category 8 Medical devices and equipment Category 9 Control and monitoring equipment Category 10 Automatic dispensers: vending machines, ATM machines Category 11 All other electrical and electronic equipment Here is the list of Industries that needs to comply before the stipulated deadline. Exemption Material End date Large household appliances Small household appliances Computing and communications equipment Consumer electronics Lighting Power tools Toys and sports equipment Medical devices and equipment Control and monitoring equipment Automatic dispensers All other electrical and electronic equipment 6(a) Lead as an alloying element in steel for machining purposes and in galvanized steel containing up to 0,35 % lead by weight 30-06-2019 Yes Yes Yes Yes Yes Yes Yes – – Yes – 6(b) Lead as an alloying element in aluminum containing up to 0,4 % lead by weight 30-06-2019 Yes Yes Yes Yes Yes Yes Yes – – Yes – 9(b)-(I) Lead in bearing shells and bushes for refrigerant-containing hermetic scroll compressors with a stated electrical power input equal or below 9 kW for heating, ventilation, air conditioning and refrigeration (HVACR) applications 21-07-2019 Yes Yes Yes Yes Yes Yes Yes – – Yes – 21 Cadmium in phosphor coatings in image intensifiers for X-ray images until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 31-12-2019 – – – – – – – Yes Yes – – 24 Lead enabling vacuum tight connections between aluminum and steel in X-ray image intensifiers. Expires on 31 December 2019. 31-12-2019 – – – – – – – Yes Yes – – 30 Hexavalent chromium in alkali dispensers used to create photocathodes in X-ray image intensifiers until 31 December 2019 and in spare parts for X-ray systems placed on the EU market before 1 January 2020. 31-12-2019 – – – – – – – Yes Yes – – 32 Lead in solders on printed circuit boards of detectors and data acquisition units for Positron Emission Tomographs which are integrated into Magnetic Resonance Imaging equipment. Expires on 31 December 2019. 31-12-2019 – – – – – – – Yes Yes – – 38 Lead in solder in one interface of large area stacked die elements with more than 500 interconnects per interfaces which are used in X-ray detectors of computed tomography and X-ray systems. Expires on 31 December 2019. May be used after that date in spare parts for CT and X-ray systems placed on the market before 1 January 2020. 31-12-2019 – – – – – – – Yes Yes – – 8(b) Cadmium and its compounds in electrical contacts 29-02-2020 Yes Yes Yes Yes Yes Yes Yes – – Yes – 15 Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages 29-02-2020 Yes Yes Yes Yes Yes Yes Yes – – Yes – 21 Lead and cadmium in printing inks for the application of enamels on glasses, such as borosilicate and soda lime glasses 29-02-2020 Yes Yes Yes Yes Yes Yes Yes – – Yes – 27 Lead in — solders, — termination coatings of electrical and electronic components and printed circuit boards, — connections of electrical wires, shields and enclosed connectors, which are used in (a)
RoHS Compliance – FAQ
What is RoHS Compliance? RoHS (Restriction of Hazardous Substances) is a product-level compliance standard based on the EU Directive 2002/95/EC. It limits hazardous materials in electrical and electronic equipment to ensure environmental and human safety. What are the restricted materials mandated under RoHS? RoHS restricts the following hazardous materials in electrical and electronic products: lead (<1000 ppm), mercury (<100 ppm), cadmium (<100 ppm), hexavalent chromium (<1000 ppm), polybrominated biphenyls (PBB) (<1000 ppm), and polybrominated diphenyl ethers (PBDE) (<1000 ppm), with some limited exemptions. Why is RoHS compliance important? Hazardous materials that are restricted in RoHS are harmful to environment, humans and animals. Why were RoHS regulations created? To reduce the usage of hazardous chemicals and thus reduce its effect on environment, humans and animals. How are products tested for RoHS compliance? RoHS compliance is tested with the help of RoHS analyzers. They are also known as X-ray fluorescence or XRF metal analyzers and are used for screening and verification of the restricted metals. Is RoHS compliance mandatory throughout the world? No, it is not mandatory throughout the world. It is good if you follow RoHS, because following Europe, most of the countries are now bringing up their own RoHS. Which companies are affected by the RoHS Directive? Any companies that sells electronic products, sub-assemblies or components directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted by chemicals banned in RoHS directive Metal industry is also affected, if there are any applications of metal plating, anodizing, chromating or other finishes on EEE components, heat sinks, or connectors. How do I know whether my products are RoHS compliant? RoHS compliance is measured by careful testing and documentation in accordance with RoHS Directive regulations. RoHS consultants help to oversee compliance. Companies can send their products to laboratories for conducting RoHS tests. The labs will test the company’s products and will return the results that will be needed for documentation. Another option is the use of handheld XRF analyzers, small devices instantly test for the presence of elements and substances controlled by the RoHS Directive It will offer instant results as well as saved results for RoHS documentation. How can I obtain a RoHS certification letter? RoHS certificate is a self-declaration letter. You can declare the compliance after checking for RoHS chemicals. The following steps are to be followed for RoHS certification. a. Testing: Through XRF testing and/or lab phthalate solvent extraction testing to be done to determine values of the ten restricted RoHS substances. b. Process Audit: Inspect all applicable manufacturing processes used towards RoHS compliance on-site. c. Documentation Review: Review the Bill of Materials, assembly drawings, materials declarations, test reports, and conformance/compliance certificates from all suppliers. d. Certification Statement: After a successful audit, a RoHS Certificate of Compliance (also known as a Certificate of Conformity or Declaration of Conformity) can be issued. What is the impact of RoHS non-compliance? Companies will not prefer to buy RoHS non-compliance products. Refusing to comply with requests or non-compliant products can result in fines that are £5000 or more. In some cases, businesses can be banned from export of their products. Specific penalties vary from state to state, but non-compliance is always far costlier for a business than compliance. What is RoHS 2 and how does differ from the original RoHS? RoHS 2 is called Directive 2011/65/EU The scope of original RoHS is expanded to cover all electrical/electronic equipment, cables, and spare parts with compliance required by July 22, 2019 or sooner depending on product category. Directive 2011/65/EU was published in 2011 by the EU, is known as RoHS-Recast or RoHS 2. RoHS 2 includes a CE-marking directive, with CE-marking of products, RoHS compliance is also required. RoHS 2 also added Categories 8 and 9 and has additional compliance recordkeeping requirements. What is RoHS 3 and how does it differ from RoHS 2? RoHS 3, or Directive 2015/863, adds four additional restricted substances (phthalates) to the original list of six. What is RoHS 5/6? RoHS 5/6 refers to compliance for 5 out of the 6 restricted substances (no compliance for lead (Pb)). Will there be a “RoHS 4”? / Are there additional substances that will be restricted in the future? Mostly yes. There are discussions (called RoHS Pack 15) taking place for the possible amendment and inclusion of seven new substances. The seven additional substances being assessed are: Beryllium, Cobalt (dichloride and sulphate), Diantimony trioxide, Indium phosphide, Medium-Chain Chlorinated Paraffins (MCCPs), Nickel (sulphate and sulfamate), and Tetrabromobisphenol A (TBBP-A). How are RoHS and REACH related? RoHS restricts substances present in electrical/electronic equipment (wiring, components, circuit boards, displays, sub-assemblies, cabling). REACH controls all chemicals that might be used to manufacture the product. All the RoHS restricted substances are also on the REACH restricted list. How are RoHS and WEEE related? RoHS regulates the hazardous substances used in the manufacture of electrical and electronic equipment (EEE), while WEEE regulates the disposal of this same equipment. WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery. RoHS compliance joins with WEEE by reducing the amount of hazardous chemicals used in electronics manufacture. How is RoHS compliance enforced and what are the penalties? By national enforcement bodies such as the NMO (National Measurements Office). Penalties and fines for non-compliance can vary between EU countries but include fines or products going to be banned in countries and also imprisonment in some member states. Is my business affected by RoHS? Yes, if you use any EEE component in your product. What is EU RoHS Directive 2011/65/EU? EU Directive 2011/65/EU (Restriction of the Use of Certain Hazardous Substances in Electronic and Electrical Equipment) restricts the amount of hazardous substances that can be used in the manufacture of electrical and electronic equipment (EEE). These hazardous substances can be difficult to manage at the end period of the product life cycle. Therefore, the regulations focus on restricting them at the beginning of the cycle in order