Five years after the introduction of RoHS, a new European Union RoHS Directive (known as RoHS2) was adopted by the European Council on 27 May 2011. The new Member State RoHS2 Regulations will take effect 18 months after its adoption. However, many companies are not aware of the new RoHS2 scope, the obligations of distributors and the associated sample testing requirements.
The original RoHS is an EU Directive (2002/95/EC) pertaining to the Restriction of Hazardous Substances in Electrical and Electronic Equipment (EEE). It was adopted by the EU in February 2003 and brought into force 1st of July 2006. This directive was brought into force in order to limit the component concentration of six hazardous substances found in EEE as they are harmful to the environment, mainly through the pollution of landfills. RoHS Directive covers a wide range of products, including not only integrated electrical and electronic products but also individual parts, raw materials and packing cases.
RoHS2 is an updated / recast version of RoHS. There are no additions to or difference in the six restricted substances, as can be viewed in table below. However, there is a proposed inclusion of Category 8 (medical devices from 2014) and Category 9 (control and monitoring instruments from 2014) and also a new Category 11, which captures all other ‘grey area’ electrical equipment(from 2019), and encorporates new CE Marking requirements. The date of this proposed inclusion is 2012 or later.
RoHS does not require any specific product labeling, however many manufacturers have adopted their own compliance marks. Examples of the visual indicators in use today include explicit “RoHS compliant” labels, green leaves, check marks, and “PB-Free” markings. Chinese RoHS labels use a lower case “e” within a circle with arrows, which can also designate compliance.
The new proposed RoHS2 directive attempts to address this issue of non-defined/non-approved/non harmonized compliance marks and reduce confusion by mandating the use of the CE mark and by introducing an additional enforcement agency, Trading Standards.
RoHS2 will work closely with REACH. Controlled substances such as HBCDD, DEHP, BBP and DBP by REACH might also be added to RoHS2 list in the future.
For more information, please contact G&M Compliance, Inc. at 714.628.1020