A Guide to Global RoHS Compliance
Electrical and electronic equipment, while essential in everyday life, generate a staggering amount of waste each year. These products contain toxic substances that harm human health, animals, and the environment. As a result, many countries worldwide have implemented RoHS programs to minimize hazardous waste generation.
The European Union’s RoHS directive was the first RoHS program introduced to the global market in 2002, but RoHS programs have rapidly expanded since then and are expected to continue growing over time. Understanding RoHS compliance is critical for actors within the supply chain—particularly manufacturers, distributors, retailers, and importers—to avoid disruptions and legal consequences.
This e-book will examine the foundations of RoHS compliance, highlight examples of RoHS programs around the world, and address the most common global compliance challenges. Finally, it will explain how using Source Intelligence’s Global RoHS solution streamlines the data collection process and simplifies communication with suppliers.
Global RoHS Compliance Explained
What is Restriction of Hazardous Substances (RoHS) Compliance?
RoHS is a set of laws that restrict the use of hazardous substances in electrical and electronic products above specific concentrations. While the EU was the first to introduce its RoHS program, RoHS now extends far beyond Europe with active programs in several countries worldwide. This growth is expected to continue with more countries implementing RoHS requirements as the quantity of hazardous electronic waste increases and the dangers of these substances become more widely known.
Which Substances are Restricted under RoHS?
In general, RoHS programs target hazardous compounds typically found in electronics and electrical equipment. This includes heavy metals, such as lead and cadmium, as well as specific classes of compounds often found in plastics. Both categories are known to be harmful to humans, and many substances within those categories are banned from use in other types of products, such as house paint, children’s toys, and food ware.
For example, lead used to be a common ingredient in house paint, yet it was banned in the U.S. in 1978 after it was linked to significant health concerns for children. However, lead and other regulated substances are key components of electronics, so RoHS restricts the use of certain compounds rather than banning them.
Which Companies Are Obligated to Comply with RoHS?
Given that each country with a RoHS program has its own requirements, the scope of companies with compliance obligations varies between countries. Generally, companies that manufacture, import, distribute, or sell electronics and electrical equipment can be subject to RoHS obligations. Additionally, RoHS programs often extend beyond finished products to include parts, components, and accessories. Companies must check for RoHS requirements within each country they operate in to confirm their obligations.
Examples of Global RoHS Compliance Programs
While RoHS policies exist on a global scale, and obligation requirements vary by country, the European Union (EU), United Kingdom (UK), and China are often the primary influencers in the development of RoHS in new countries, making them great examples for understanding how RoHS differs around the world. Let’s explore the RoHS policies and compliance obligations of the EU, UK, and China in further detail.
European Union (EU) RoHS
EU RoHS was introduced in 2002 before being replaced by RoHS 2, officially named Directive 2011/65/EU, in 2013. RoHS 2 expanded the exemption list, updated the compliance process, added the Conformité Européene (CE) marking as a requirement to demonstrate compliance, and more.
Scope
Any business that manufactures, imports, or sells applicable electrical and electronic equipment (EEE) in the EU must comply with RoHS. This includes companies that do not directly sell to consumers but instead sell to resellers, distributors, or other businesses that place their products on the market.
Items within scope of the EU RoHS directive include (but are not limited to) products, equipment, sub-assemblies, spare parts, components, and cables. The directive separates EEE into eleven categories:
- Large home appliances
- Small home appliances
- I.T. and telecommunication equipment
- Consumer equipment
- Lighting equipment
- Electrical and electronic tools
- Sports equipment and toys
- Medical devices
- Monitoring and control equipment
- Automatic dispensers
- Other electrical and electronic equipment outside of these categories
Restricted Substances
There are currently ten restricted substances under the EU RoHS directive. The restricted compounds and their maximum allowable threshold at the homogeneous level are listed below:
- Lead (Pb) – 0.1%
- Cadmium (Cd) – 0.01%
- Hexavalent Chromium (Cr VI) – 0.1%
- Mercury (Hg) – 0.1%
- Polybrominated Diphenyl Ethers (PBDE) – 0.1%
- Polybrominated Biphenyls (PBB) – 0.1%
- Benzyl butyl phthalate (BBP) – 0.1%
- Bis(2-ethylhexyl) phthalate (DEHP) – 0.1%
- Diisobutyl phthalate (DIBP) – 0.1%
- Dibutyl phthalate (DBP) - 0.1%
Exemptions
There are exemptions to RoHS compliance in Article 4(1) within the directive. Annexes III & IV list restricted substances that are exempt when used in specific applications. Exemption use must be disclosed in RoHS compliance declarations.
Compliance Process
EU RoHS is a self-declaring directive that requires companies to generate a technical file. A technical file contains information about the product (lab test results, bill of materials, etc.) and the steps taken to ensure RoHS compliance. Companies must keep a technical file for 10 years following a product being placed on the market.
Once the Technical File is generated and RoHS compliance is verified, the liable party must submit a RoHS Declaration of Conformity (DoC). The appropriate country's customs will approve the DoC and issue a CE trademark certifying RoHS compliance. The CE marking must be displayed on the product, or the product’s packaging must display the CE trademark.
United Kingdom (UK) RoHS
UK RoHS, named Regulation 2012 No. 3032 – The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations, was implemented in 2012. While the regulation is the foundational legislation of the UK, there are differences in how it is applied in Great Britain and Northern Ireland.
Scope
UK RoHS refers to companies within the scope of the regulation as economic operators, which includes manufacturers, importers, distributors, and retailers. UK RoHS applies to any EEE placed or made available on the market.
Restricted Substances
UK RoHS restricts the same ten substances as EU RoHS to the same maximum thresholds.
Exemptions
Economic operators can apply for an exemption under UK RoHS for certain technical applications. However, Great Britain has its own exemptions system independent of the EU, while Northern Ireland follows. However, Great Britain has its own EU exemption list.
UK RoHS covers all EEE, spare parts, and cables, but exempt items include:
- Pipe organs
- Space equipment
- Military equipment
- Professional non-road machinery
- Solar or photovoltaic panels
- Large stationary industrial tools
- Implantable medical devices
Compliance Process
The UK RoHS compliance process is like EU RoHS. Economic operators must submit a Technical Package, including a Declaration of Conformity, a record of the conformity assessment, and any additional production control documentation (such as laboratory test reports). The Technical Package must be kept for 10 years after the product was first placed on the market and made available for the Office of Product Safety Standards (OPSS) if requested. Some EEE items require the Technical Package to be kept for longer than 10 years.
After submitting a technical file, manufacturers must declare their products RoHS compliant by affixing either a UKCA mark (for Great Britain) or a CE mark (for Northern Ireland) to the product. However, starting in 2025, the CE mark will no longer be accepted, and the UKCA mark will be standard.
Discover more about global RoHS compliance
You’ve just explored the foundations of RoHS compliance and how it’s implemented in the EU and UK. Next are sections on China RoHS and other global RoHS programs, common challenges in compliance, and an in-depth look at Source Intelligence’s Global RoHS solution.
Read the full e-book to stay ahead of evolving requirements and keep your organization on track.