Understanding the requirements for compliance to RoHS 2011/65/EU is not difficult (and we can help you), but ignoring them can get your product stopped upon entry into the EU.
RoHS stands for the “restriction of hazardous substances”. Initially, it restricted four heavy metals and two flame retardants per Annex II.
Compliance with the RoHS Directive 2011/65/EU is required for categories of electrical and electronic equipment which are indicated in Annex I.
The Annex II list is very comprehensive. Basically, any equipment that has any electric function is in the scope of this Directive. Equipment that is in the scope of RoHS must meet all of the substance restriction levels in Annex I. More specifically it means that every single part in your product (every pin, every resistor, every screw, even labels, and paint) must also individually meet those substance restriction levels. You cannot use a small part which is composed of 5% lead and compare that part in the context of the weight of the whole device. Each part must also be compliant.
The EU has published many amendments to the RoHS Directive. Most deal with very specific exemptions that are industry or application-specific. For instance – brass and other copper alloys can have a lead content of up to 4%. The EU publishes these in the Official Journal of the EU and also on a RoHS web page that is constantly updated. That page is here.
Below is a screenshot of the RoHS page with links to RoHS 2011/65/EU and all of the published amendments.
Notice that there are many, many amendments – but only (EU)2015/863 and (EU)2017/2102 are separated from the main list. (EU)2017/2102 is a short document that clarifies some language and addresses the use of spare parts and pipe organs (yes, pipe organs). (EU)2015/863 is much more important because it added four new substances to the Annex II list above: four phthalates. Phthalates, I have learned, are plasticizers that make plastic more pliable. Googling it, I came to a CDC fact sheet defining them in greater detail.
Therefore the importance of (EU)2015/863 is contained in the expansion of Annex II in RoHS 2011/65/EU. See below.
The last four substances are the “new” restricted phthalates. Now that I have laid the groundwork, we have arrived at the main purpose of this article:
Claiming compliance to RoHS 2011/65/EU encompasses a claim of compliance to (EU)2015/863 also as long as the original six-substance list is not referenced.
I wrote that in bold and italics because many times I see reference to “RoHS3” or “RoHS 2015/863.” Because of the confusion surrounding this, we write it as “RoHS 2011/65/EU + (EU)2015/863” on our proposals and much of our correspondence with our customers.
I have referenced the EU’s RAPEX weekly reports many times in the history of this blog. Click that link and subscribe if you are involved in the export of equipment and products to the EU. Every Friday, you will receive an email with a list of products that are stopped in EU customs. Not all products that are stopped – just what they consider to be especially hazardous.
Today I opened the link in my email and reviewed a couple of products that were stopped for non-compliance to RoHS. See below.
Both of those images open to the corresponding alerts. I want to draw your attention to two things:
- RoHS 2 is referenced. This means RoHS 2011/65/EU. Remember: that also means Commission Delegated Directive (EU)2015/863.
- Both products were stopped because the welds contained excessive lead. They did not note that the whole product has a higher than acceptable level of lead: just the welds.
If I had to guess, based on my experience in handling RoHS compliance for F2 Labs customers since 2014, I would bet that the products did not claim any compliance to RoHS at all, or had a weak claim (no report to EN 50581:2012 to back it up).
Is the picture at the bottom of this article what comes to mind when you think about RoHS? Don’t. We have handled hundreds of RoHS compliance projects for our customers. The first step we take is to determine if we can exclude it. (Yes, there are some exclusions!). We can help you too.