EU RoHS

Did you Know?

RoHS Europe
  • RoHS (Restriction of the use of certain Hazardous Substances) imposes limitations for concentrations of lead (Pb), cadmium (Cd), mercury (Me), hexavalent chromium (Cr 6+), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDEs) contained in electrical and electronic Equipment.

 

  • From 22 July 2019 (or 2021 for products categories 8 and 9), 4 phthalates are also beeing added to the restricted susbtances list: DEHP, BBP, DBP and DIBP.

 

  • The concentrations of the restricted substances are not regulated at the component level, but at the homogeneous materials level, which constitutes each component. Therefore, one to dozens of homogeneous materials should be analyzed within the same component (i.e. various plastics, metals, ceramics, epoxy finishes, painting, welding etc.) one by one…

 

  • In order to confirm EU RoHS conformity of an assembly, you should not only consider each electronic component, and also the materials of every cable, label, hardware (such as screws...), welding, paste, casing, chassis, etc... in other words, wherever restricted substances may be found.

 

 

  • RoHS allows restricted substances to be exempted for certain classes of products and applications. However, several of these exemptions expire. Therefore, the expiration dates on exemptions must be monitored as they are regularly updated.
Download
General RoHS Exemptions List
Eu RoHS list of exemptions with applicable expiration dates
RoHS exemptions AH 18 June 2017.pdf
Adobe Acrobat Document 321.3 KB
Download
Medial Devices and Monitoring and Control Instruments RoHS Exemptions List
Eu RoHS list of exemptions
RoHS exemptions Medical Monitoring and C
Adobe Acrobat Document 218.8 KB
  • Medical devices and monitoring & control instruments are now under the scope of RoHS.
  • Statistically, manufacturers declare at least one exemption in 90% of their Printed Circuit Board Assemblies (PCBA) and Electrical and Electronics Equipment (EEE).
  • As per Directive 2011/65/EU, technical product documentation with procedures must now be prepared and provided upon request to surveillance authorities.
  • Asking a supplier if he is compliant to RoHS or finding a RoHS logo on a spec. sheet is not sufficient. Indeed, the manufacturer’s declarations of conformity the (DoC) must be collected, specifying whether exemptions are used and if so, what they are.
  • Complying with the European RoHS does not automatically imply that it will conform to the China RoHS. However, the information already gathered will be valuable and will simplify the compliance process with China RoHS.

How to Ensure Compliance with EU RoHS?

Product Compliance

RoHS Enviropass

You must ensure compliance with restricted substances thresholds, and monitor any reported exemptions. In the vast majority of cases for PCBA and complex products, the documentation review from suppliers and subcontractors is the best option because unlike chemical analysis or other analytical tests (i.e. XRF testing), it enables:

 

  • Better money value for the assessment of all the homogeneous materials which constitute a product
  • To check and reuse the tests already carried out by the suppliers instead of redoing them
  • To find out which exemptions numbers have already been claimed
  • To monitor products compliance over the changing requirements (i.e. changes in exemptions) or new designs (i.e. replacement of suppliers, of parts etc.). Only the documents of affected parts will be reviewed
  • To build robust technical documentation.

 

Since its introduction, the standard EN 50581 - Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances - recommends the documentary approach with suppliers, which is recognized by both industry and enforcement authorities.

 

In the absence of sufficient documentation for a component, a risk analysis is conducted and recommendations are given (either chemical analysis or component replacement). Chemical analysis is therefore taken as a last resort, only after a careful documentary review, and focuses on uncertain homogeneous material only.

 

Technical Documentation

With RoHS 2, it is mandatory to build technical file showing the method for verifying a product’s compliance. The technical documentation must contain specific information documented in the procedure.

 

Download
Technical Documentation - Table of Contents
Table des matières de la documentation technique
Technical Documentation - Table of Conte
Adobe Acrobat Document 353.1 KB

The Enviropass Approach

 

You can choose three types of services as needed:

  • Classic EU RoHS
  • Deluxe EU RoHS

  • Documentary Review

Classic EU RoHS

With Classic EU RoHS, you allow Expertise Enviropass to undertake the documentary assessment of your products.  A Certificate of Conformity is issued for each product in compliance with the requirements of Europe RoHS.

Deluxe EU RoHS

Deluxe EU RoHS does not only provide you with fishes… but also teaches you how to fish! Indeed Deluxe EU RoHS includes:

 

  • Training in products auditing that will allow you to analyze more products yourself
  • Adapting technical documentation procedures and making you a master in monitoring your products compliance in regards to the Europe RoHS

  • Evaluating a product's assessment and issuing a Certificate of Conformity if applicable

Documentary Review

You have built the technical documentation for a product yourself, but you want to make sure that the data quality is sufficient ? Let Enviropass:

  • Review your technical documentation
  • Advise you on potential gaps

  • Issue an applicable Certificate of Conformity