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What is
RoHS?
RoHS is short for
Restriction
of Hazardous Substances.
Directive 2002/95/EC - RoHS
On January 27, 2003, the
European
Parliament issued a directive “on the restriction of the use of certain
hazardous substances in electrical and electronic
equipment.” The RoHS directive became
effective on July 1, 2006 and applies to
new electrical and electronic equipment placed on the European market on or
after July 1st. However, spare parts will continue to be available for
products that were put on the market prior to that date.
RoHS named six
hazardous
substances of immediate concern: lead, mercury, cadmium, hexavalent
chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers
(PBDE). It also provides for the addition of other hazardous substances, as
soon as scientific evidence is available.
The
maximum concentration
values tolerated for the RoHS substances were established by
amendment in 2005. Values are measured by weight at the homogeneous
material level. The maximum concentration value tolerated for lead,
mercury, hexavalent chromium, PBB, and PBDE is 0.1% by weight in
homogeneous materials and for cadmium is 0.01%.
Covered
electrical
and electronic equipment includes any equipment that
depends upon electric currents or electromagnetic fields for its operation.
Large household appliances; small household
appliances; IT and telecommunications equipment; consumer equipment;
lighting equipment and light bulbs; electrical and
electronic tools (except large-scale stationary industrial tools); toys,
leisure and sports equipment; and vending machines are covered.
Exemptions
may be granted to narrowly-defined applications when the elimination of a prohibited
substance is technically or
scientifically impracticable or when the only available substitution produces more negative than positive benefits to
the environment, health, or consumer safety. Exemptions are temporary
in nature and subject to review at least every four years, until such time
as a reliable and safe substitution is available.
Enforcement
is by the EU member states, each within its own borders.
Penalties are to be "effective, proportionate and dissuasive."
UK Regulation 2008 No 37
UK Guidance Notes on RoHS
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In
February 2008, the United Kingdom issued Regulation 2008 No 37,
updating the transposition of RoHS into national law. New guidance notes
were issued concurrently. Guidance topics include: |
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Decision tree for
determining whether your products fall within the
scope of RoHS, or whether they
are exempt |
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Description of the
approximately thirty
exemptions granted to specific product applications,
including any restrictions on the use of the exemption |
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Discussion of the legal concept of
due
diligence
in documenting the compliance of your
products with RoHS |
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Also in 2008, the
European Union issued a series of RoHS studies to evaluate the need
for future changes in the RoHS directive: |
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The
costs and
benefits of the current directive |
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The
need to
"simplify" the directive to provide more consistency
between the Member States, a shorter and more predictable process
for granting exemptions, and better market surveillance and the
elimination of free riders |
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Whether the scope
of RoHS should be expanded to include
category 8 & 9
equipment, i.e. medical devices and monitoring &
control instruments |
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Whether other
substances should be added to the list of six RoHS
prohibited
substances |
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In December 2008,
the European Union provided the first look at the revised RoHS
and WEEE directives: |
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New proposed
RoHS directive
(RoHS2) |
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New proposed WEEE
directive (WEEE2) |
If you need assistance
in implementing or managing your company's RoHS compliance, we stand ready
to help you. Just
email
us or give us a call at 972-679-8996 for a timely and personalized response.
This summary is intended to give you an easy-to-understand overview and does
not constitute legal advice. The actual standard in the original language
should be reviewed and used for all business, legal, and product compliance
purposes.
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Technical Consulting
PO Box 867705, Plano, Texas 75086
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