RoHS 3 – (EU) 2015/863 – Some FAQ’s

Now that we have been under the ‘new’ EU RoHS for a few months I thought it would be a good time to write a brief article to cover some of the most commonly asked questions.

  • What changed? RoHS 2011/65/EU restricts six substances. (EU) 2015/863 adds four more substances to this list. The original six substances are four heavy metals (including lead, not just lead) and two flame retardants. (EU) 2015/863 is an amendment to 2011/65/EU which added restrictions on the use of four phthalates.
  • What are phthalates? Phthalates are also called ‘plasticizers’ These are chemicals used in plastics to make them more flexible.
  • Does everything have to be retested to prove compliance? Not necessarily. Parts that are made of metal, 100%, have no phthalates. Most manufacturers have known about this amendment since it was introduced, four years ago, so chances are your products need new documentation but not new testing.
  • Since (EU)2015/863 is an amendment to the RoHS Directive 2011/65/EU then isn’t a claim of compliance to RoHS 2011/65/EU also a claim of compliance to (EU)2015/863? That can be a question that is subjective, based on a few other “ifs”. For example, if the document claims compliance to RoHS 2011/65/EU and lists only the original six substances then we would not accept this (F2 Labs performs many EN 50581:2012 reviews for our customers). However, if the document indicates compliance to RoHS 2011/65/EU, while not indicating the list of restricted substances, and it is signed & dated past July 22, 2019 – we would probably accept it.

There are a few nuances to RoHS and we can help you with this.

We can be contacted via this link. We can be reached by phone at
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