RoHS 2: The Directive Continues to Evolve

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The "recast" RoHS Directive 2011/65/EU came into force on 3 January 2013, replacing the former RoHS Directive, 2002/95/EC. Many major changes have been enacted, and many more are to come. These include

  • Expanded scope
    • Medical devices and monitoring and control instruments came into scope 22 July 2014
    • In vitro medical devices came into scope as of 22 July 2016
    • Industrial monitoring and control instruments came into scope as of 22 July 2017
    • Other electrical and electronic equipment (EEE) not covered by any of the existing 10 product categories come into scope as of 22 July 2019

  • Broader and more inclusive definitions
    • Electrical and electronic equipment, or EEE, means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current.
    • "Dependent" means, with regard to EEE, needing electric currents or electromagnetic fields to fulfill at least one intended function.
      • A greeting card that plays a tune or a toy teddy bear that talks would now be in scope of the directive

  • More Substances
    • Delegated Directive 2015/863 adds four phthalates to the list of restricted substances in Annex II of RoHS as of July 22, 2019 for most product categories:

      • Bis(2-ethylhexyl) phthalate (DEHP)
      • Butyl benzyl phthalate (BBP)
      • Dibutyl phthalate (DBP)
      • Diisobutyl phthalate (DIBP)

    • Sweden would like to add Medium Chain Chlorinated Paraffins (MCCPs) - and it's part of the current study (see below)
    • Denmark would like to add small linear and branched brominated alkyl alcohols (SBAAs)
    • A new study was launched in January 2018 to review seven additional substances for possible restriction. Task 2 of Part 1 of Pack 15 identifies the targeted substances as:

      • Diantimony trioxide (flame retardant)
      • Tetrabromobisphenol A (TBBP-A, flame retardant)
      • Indium phosphide (InP)
      • Medium chain chlorinated paraffins (MCCPs) - Alkanes, 14-17, chloro
      • Beryllium and its compounds
      • Nickel sulphate and nickel sulfamate
      • Cobalt dichloride and cobalt sulphate

      Many of these substances are widely used in electrical and electronic equipment. If these substances are critical to your product, contact us today.

    ALERT! Updates on the status of the seven substances under consideration are in

    1. DCA's Oct 14, 2019 TTI MarketEYE article and
    2. The December 2019 DCA Newsletter.

  • Substantial documentation requirements
    • Formal Declaration of Compliance - declare it
    • Conformity assessment and Technical Documentation, on file, current and available to enforcement agents for 10 years - prove it
    • CE marking to signify RoHS compliance required - demonstrate it

  • And More!!
    • We remain under RoHS 2; this is NOT "RoHS 2.1" or "RoHS 3". Read Mike Kirschner's article on RoHS terminology in Compliance & Risks' August 2017 Quarterly Newsletter!
    • The EU RoHS Scope has finally been corrected and updated
    • Hundreds of exemptions exist and, since they all expire and can be renewed only by an application accompanied by extensive technical documentation, you must keep track of which exemptions are used in your product and where. DCA's TTI MarketEYE April 2020 article captures the current tranche of exemption renewals and expirations.
    • There are many other RoHSes! They can and do have different requirements. Make no assumptions about regulatory requirements in other markets. Read this article for examples of when "RoHS" is not "RoHS".

What can DCA Do for You?

Work with someone who actually understands RoHS. DCA can help you learn about and manage the impact of RoHS and other EU Directives and regulations, as well as national and international market regulations and customer requirements, and plan your transition to compliance or improve your efficiency. From assessing your suppliers' RoHS compliance capabilities, to updating key design and procurement supplier-, material- and component-related business processes, to identifying and working with you to configure a systems solution that tracks material composition, to identifying and resolving potential and actual technical back-end risks, we can do it all. Please contact us for more information.