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The RoHS Directive

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The recast RoHS directive is mandatory from January 3rd, 2013. The recast RoHS Directive, 2011/65/EU, was implemented from July 2011. The Directive has been known as RoHS recast directive or RoHS II.

The old directive 2002/95/EC will be repealed from January 2nd, 2013 and manufacturers with products within the scope need to follow the new directive.

The scope of the recast Directive are as follows:

  • 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 from 22 July 2014, but in vitro diagnostic medical devices from 22 July 2016
  • Monitoring and control instruments including industrial monitoring and control instruments from 22 July 2014, but industrial monitoring and control instruments from 22 July 2017
  • Automatic dispensers
  • Other EEE not covered by any of the categories above, from July 22, 2019

The entire Directive:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088...

The limits of the restricted substances remain the same:

  • Lead 0.1%
  • Mercury 0.1%
  • Cadmium 0.01%
  • Hexavalent chromium 0.1%
  • Polybrominated biphenyls (PBB) 0.1%
  • Polybrominated diphenyl ethers (PBDE) 0.1%

Manufacturers need to take notice that compliance needs to be shown on homogenous material level.

The directive defines the term homogenous material as following:
"homogeneous material" means one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.

As an example a capacitor on a printed circuit board might consist of 4 to 6 homogenous materials which each need to meet the requirements.

CE-marking

The directive has become a CE-marking directive meaning that all manufacturers covered by the scope of the directive need to make a technical file for hazardous substances and update their manufacturer's declaration with the relevant standards and directives for RoHS.

Exemptions allowed to material

The exemptions to current scope are unchanged from the version dated September 8th, 2011.

Annex IV in the directive is new and covers medical device applications and measuring and control equipment (categories 8 and 9).

The exemptions covers to a large degree following utilization of restricted substances:

  • Equipment utilizing or detecting ionizing radiation
  • Sensors, detectors and electrodes
  • Lead in solder

Standardization for RoHS:

Standards for determining the levels of hazardous substances are available ( IEC 62321-series).

In addition the EU commission has given a standardization task to Cenelec to come up with a harmonized standard for showing “presumption of conformity” with the new directive. The work is on-going and the final standard is expected in late 2012.

However, manufacturers not fully compliant with the new directive need based on experience at least 6 months to:

  • establish necessary systems
  • complete tests
  • order, receive and evaluate required material declarations

More information and assistance can be obtained from:
Maggie [dot] Cheng [at] nemko [dot] com  – phone +86 10 630377387
JonIvar [dot] Tidemann [at] nemko [dot] com  - phone +47 22960455

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