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 I list is very comprehensive. Basically, any equipment that has an electrical function is within the scope of this Directive. Equipment that falls within the scope of RoHS must meet all substance restriction levels in Annex I. More specifically, it means that every single part of your product (every pin, every resistor, every screw, even labels and paint) must also meet those substance restriction levels. You cannot use a small part composed of 5% lead and compare it to 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 contain up to 4% lead. 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 are plasticizers that make plastic and rubber more or less pliable.
Therefore, the importance of (EU)2015/863 lies in the expansion of Annex II under 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 with RoHS 2011/65/EU encompasses compliance with (EU)2015/863, provided the original six-substance list is not referenced.
I wrote that in bold and italics because I often see references to “RoHS3”, “RoHS10”, or even “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 export equipment or products to the EU. Every Thursday evening at about 10 PM Eastern time, you will receive an email with a list of products that are stopped in EU customs. Not all products that are stopped are considered especially hazardous.
Today, I opened the link in my email and reviewed a couple of products that were stopped for non-compliance with 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 the Commission Delegated Directive (EU) 2015/863.
- Both products were stopped due to excessive lead in the welds. They did not note that the entire product has a lead level above acceptable levels: only the welds.
If I had to guess, based on my experience handling RoHS compliance for F2 Labs customers since 2014, I would bet that the products did not claim any RoHS compliance at all, or had a weak claim (no EN 50581:2012 report 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 is to determine whether we can exclude it. (Yes, there are some exclusions!). We can help you too.
We can be contacted via this link. We can be reached by phone at 877-405-1580
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