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How can RoHS compliance be demonstrated / proven?
The RoHS Directive restricts the use of the six substances but does not specify how producers can comply or the requirements for market surveillance; this will be specified in national law.
Two key principles of the Directive are:
What is the RoHS Directive?
RoHS stands for the "Restriction of the use of Certain Hazardous Substances in Electrical and Electronic Equipment" and applies to equipment put on the market from 1st July 2006. The Directive (2011/65/EU) restricts the use of 6 substances (lead, mercury, cadmium, hexavalent chromium and the 2 brominated flame retardants, PBB & PBDE). RoHS is closely linked to the WEEE Directive and takes its scope from it.
Where are the restricted substances found?
The restricted materials can be found in a variety of different applications, including the following:
What is the definition of electrical and electronic equipment used by RoHS?
RoHS affects specified types of EEE (Electrical and Electronic Equipment) and is defined in the WEEE Directive as: "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 falling under the categories set out in Annex IA and designed for use with a voltage rating not exceeding 1000 Volt for alternating current and 1500 Volt for direct current"
Will all RoHS compliant products be identified with a new part number?
A variety of different approaches have been taken to RoHS and part numbering:
How can I test components for RoHS compliance?
There are various ways of testing for RoHS compliance, ranging from fairly simple methods to highly complex chemical analysis. Whichever technique is chosen it is important to ensure that it tests the "homogeneous material" and not the entire component or assembly.
One of the most cost-effective methods of RoHS screening is a technique known as ED-XRF (electro dispersive x-ray fluorescence). In this technique the sample is excited with an x-ray beam and the resultant emissions collected and analysed. The emissions spectra can identify the presence and concentration of materials present.
The technique does have some limitations, including
Can I still manufacture non-compliant products?
If the product is within the scope of the RoHS Directive it is still legal to manufacture a non-compliant version, however it cannot be sold in the EU after 1st July 2006. In practice there is likely to be very little demand for non-compliant products.
Is there a difference between "lead-free", "green" and "RoHS compliant"?
These terms are often used interchangeably, but may not mean the same things. From a manufacturer's perspective there are two key aspects to component compliance:
Does RoHS apply only to newly designed products?
No, RoHS applies to the manufacture and import of the 8 specified categories of EEE (electrical and electronic equipment) from 1st July 2006. It affects designs already in existence at this time as well as new equipment.
What is the definition of an "Homogeneous Material"?
An homogeneous material has been defined as a material which can be mechanically separated from another material (e.g. through scraping or abrasion), without chemical separation. The "tinning" on a component lead is therefore an homogeneous material as it can be separated from the copper wire, whereas the Lead (Pb) contained in a ceramic cannot be separated from the ceramic by mechanical means. Another example of an homogeneous material is the plastic sheath on a cable.
Will I still be able to buy and use non-compliant components?
Non-compliant components may still be used for the repair of "historic" electrical equipment (i.e. put on the market before 1st July 2006). They may also be used in the manufacture and repair of products outside the scope of RoHS.
The availability of non-compliant components will be dictated by the demand for them. For economic reasons component manufacturers will generally only produce one version of a component. If a significant proportion is used in the manufacture of new electrical equipment then the component is likely to be available only as "RoHS compliant". Certain components are only manufactured as spare parts for existing equipment and will therefore never be made compliant.
Distributors may stock supplies of non-compliant components to support applications outside the scope of RoHS. This is likely to be a short-term situation as supplies will be limited.
Which countries are affected by RoHS? Where does the RoHS Directive apply legally?
RoHS is an EU Directive and therefore only legally applies within the EU member states. However RoHS has a wider impact for 2 main reasons:
Does the RoHS Directive specify how compliant products should be marked?
Unlike the WEEE Directive, RoHS does not specify a "compliance mark". A number of manufacturers now indicate compliance on product packaging by using symbols or a suffix to their part number (e.g. PBF, LF, or G).
Who is affected by RoHS?
The effects of RoHS are widespread. Legally it affects anyone who:
However the real impacts are far wider, RoHS has implications for many other parts of the supply chain including:
What is the definition of RoHS compliance?
A RoHS compliant product is defined as not containing any of the restricted materials in concentrations exceeding the maximum permitted levels. i.e. 0.1% by weight for Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr [VI]), and the 2 brominated flame-retardants (PBB & PBDE) and 0.01% for Cadmium (Cd) in an homogeneous material.
The RoHS Directive applies only to the specified categories of electrical products; it does not apply to the manufacture and sale of components. However, in order to manufacture compliant equipment, "compliant" components and lead-free solders will be required. It is important that the components used do not exceed these limits and (where necessary) are able to withstand the higher process temperatures required by lead-free solders.
RS Components has obtained compliance information from its suppliers and taken all reasonable steps to confirm this before making it available to customers.
What is the reason for implementing the RoHS Directive? What is the objective of the RoHS Directive?
RoHS should be considered in association with the WEEE Directive. Their objectives are jointly to improve environmental performance at all stages in a product's life cycle. Some of the materials used in electronics can present environmental and health hazards during manufacturing or at "end of life" disposal. The EU has therefore taken steps to restrict the use of these materials (RoHS) and encourage the safe disposal or re-use of electrical equipment (WEEE).
How will RoHS & WEEE be implemented?
There is a key difference between the WEEE and RoHS Directives. WEEE specifies minimum standards that each member state must implement but may exceed. RoHS is a single market Directive, which means it must be implemented identically by each member state.
What types of equipment (EEE) are affected by RoHS?
The RoHS Directive takes its scope from Annex 2 of the WEEE Directive, but excludes 2 categories (Monitoring & Control and Medical devices). The range of affected products is listed below, further guidance is expected to be issued by national bodies responsible for implementing and enforcing the directives on a country by country basis (e.g the Department of Trade & Industry and National Weights and Measures Laboratory in the UK)
Large Household appliances:
- Large cooling appliances
- Refrigerators & Freezers
- Other large appliances used for refrigeration, conservation and storage of food
- Washing machines
- Clothes dryers
- Dish washing machines
- Electric stoves
- Electric hot plates
- Other large appliances used for cooking and other processing of food
- Electric heating appliances & electric radiators
- Other large appliances for heating rooms, beds, seating furniture
- Electric fans & air conditioner appliances
- Other fanning, exhaust ventilation and conditioning equipment
Small household appliances:
- Vacuum cleaners
- Carpet sweepers
- Other appliances for cleaning
- Appliances used for sewing, knitting, weaving and other processing for textiles
- Irons and other appliances for ironing, mangling and other care of clothing
- Grinders, coffee machines and equipment for opening or sealing containers or packages
- Electric knives
- Appliances for hair-cutting, hair drying, tooth brushing, shaving, massage and other body care appliances
- Clocks, watches and equipment for the purpose of measuring, indicating or registering time
IT and telecommunications equipment:
- Centralised data processing: Mainframes, Minicomputers, Printer units
- Personal computing: Personal computers (CPU, mouse, screen and keyboard included), Laptop computers (CPU, mouse, screen and keyboard included), Notebook and Notepad computers
- Copying equipment
- Electrical and electronic typewriters
- Pocket and desk calculators and other products and equipment for the collection, storage, processing, presentation or communication of information by electronic means
- User terminals and systems
- Telephones, pay telephones, cordless telephones,
- cellular telephones, answering systems and other products or equipment of transmitting sound, images or other information by telecommunications
Electrical and electronic tools (with the exception of large-scale stationary industrial tools):
- Saws - Sewing machines
- Equipment for turning, milling, sanding, grinding, sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar processing of wood, metal and other materials
- Tools for riveting, nailing or screwing or removing rivets, nails, screws or similar uses
- Tools for welding, soldering or similar use
- Equipment for spraying, spreading, dispersing or other treatment of liquid or gaseous substances by other means
- Tools for mowing or other gardening activities
- Luminaires for fluorescent lamps
- Straight fluorescent lamps
- Compact fluorescent lamps
- High intensity discharge lamps, including pressure sodium lamps and metal halide lamps
- Low pressure sodium lamps
- Other lighting or equipment for the purpose of spreading or controlling light with the exception of filament bulbs
- Radio sets
- Television sets
- Video recorders
- Hi-fi recorders
- Audio amplifiers
- Musical instruments
- And other products or equipment for the purpose of recording or reproducing sound or images, including signals or other technologies for the distribution of sound and image than by telecommunications
Toys, leisure and sports equipment:
- Electric trains or car racing sets
- Hand-held video game consoles
- Video games
- Computers for biking, diving, running, rowing, etc.
- Sports equipment with electric or electronic components
- Coin slot machines
· - Automatic dispensers
What alternatives are available to the restricted substances?
There are various alternatives to the restricted substances, however none has exactly the same characteristics. Some of the most common alternatives are listed below:
How does RoHS affect maintenance and repair?
Non-compliant components can be used to maintain or repair Electrical and Electronic Equipment (see 'What is the definition of EEE?') which is put on the market before 1st July 2006.
Many components will not be available indefinitely in a non-compliant form. It is possible to make an acceptable tin/lead solder joint onto a "lead-free" component. Consequently repair of non-compliant EEE with compliant components should not normally cause any problems.
The repair of non-compliant equipment with lead-free solders should be avoided if possible. Lead-free solders melt at higher temperatures than leaded solders and this may cause problems with existing solder joints and components.
N.B. EEE put on the market after 1st July 2006 should only be repaired using compliant components and lead-free solder.
What are the maximum permitted concentrations of the restricted substances?
The maximum concentrations by weight permitted in an homogeneous material are 0.1% for Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr [VI]) and the 2 brominated flame-retardants (PBB & PBDE), and 0.01% for Cadmium (Cd).
I have heard that cutting and welding materials containing Chromium can create Hexavalent Chromium. Is this a problem?
It appears that welding stainless steel or chromium plated steel produces toxic fumes which contain chromium trioxide (CrVI). This is possible as chromium metal will oxidise if heated and at welding temperature may make a small amount of CrVI. This must form as minute dust particles to exist in the hexavalent state because the oxide (CrO3) is unstable above its melting point, which is 197 deg C, decomposing to trivalent chromium oxide. There will not be Cr6 on the welded stainless steel surface because the steel will be too hot and any CrO3 that is present will decompose to CrIII.