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What is RoHS?

RoHS is short for Restriction of Hazardous Substances.

Directive 2002/95/EC - RoHS
UK Regulation 2008 No 37
  
UK Guidance Notes on 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."

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:
  Decision tree for determining whether your products fall within the scope of RoHS, or whether they are exempt
  Description of the approximately thirty exemptions granted to specific product applications, including any restrictions on the use of the exemption
  Discussion of the legal concept of due diligence in documenting the compliance of your products with RoHS
Also in 2008, the European Union issued a series of RoHS studies to evaluate the need for future changes in the RoHS directive:
  The costs and benefits of the current directive
  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
  Whether the scope of RoHS should be expanded to include category 8 & 9 equipment, i.e. medical devices and monitoring & control instruments
  Whether other substances should be added to the list of six RoHS prohibited substances
In December 2008, the EU issued the first draft of RoHS Recast (RoHS 2.0). Progress toward adoption has been slow. Although approved by the European Parliament in November 2010, it still awaits the action of the Council.
This summary of RoHS is designed to provide you with an accurate, easy-to-understand overview of the topic. However:
ê We have not attempted to cover the implementation issues that need to be addressed at your company or in your supply chain. For this type of assistance, please email or call us at 972-679-8996 to inquire about our services.
ê This summary 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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