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Frequently Asked Questions about RoHS
- What types of equipment are covered by the Directives?
- How are WEEE and RoHS related?
- Who needs to comply with RoHS?
- Who is considered a producer?
- What does 'producer responsibility' mean for recycling?
- We are not a brand owner, we only assemble using specified materials. Why do I need to do testing?
- Can we continue to sell products containing the restricted substances outside Europe?
- What are the business implications if my products contain amounts of the restricted substances above the maximum allowable limit?
- How do these Directives impact the products I have from Thermo Fisher Scientific, and how do I handle recycling Thermo Fisher Scientific products?
- Which products are currently exempt, and will there be changes in the future that impact my products?
- What documentation will be required for RoHS compliance?
- What does “Homogeneous substance†mean and how does it impact RoHS test results?
- How are spare parts impacted, for both equipment manufactured priori to July 2006 as well as products manufactured after that date?
- What is meant by non destructive testing of a sample?
- Is hexavalent Cr used in capacitors? If so, is it exempt?
- How can XRF relate ppm/% rates to homogeneous substances?
- How do I interpret XRF screening results from a PCB?
- What is the required measurement times for XRF screening?
- What if I have materials declarations from suppliers stating their products do not contain any of the regulated hazardous substances, but my finished products are discovered to have the restricted substances in excess of the maximum allowable limits?
- The flow chart depicting the "Recommended Test Methods for RoHS Substances" has EDXRF for both screening and verification testing for lead and cadmium; is this correct?
- What is this symbol?
- What types of equipment are covered by the Directives?
There are 10 categories of electrical and electronic equipment ranging from large household appliances to automatic dispensers. The WEEE Directive 2002/96/EC covers equipment in categories 1 – 10. The ROHS Directive 2002/95/EC applies to the same products as covered in the Annexes to the WEEE Directive with the exclusion of categories 8 and 9 (medical devices and monitoring & control instruments). http://europa.eu.int/comm/environment/waste/weee_index.htm
Categories of electrical and electronic equipment covered by these Directives
- Large household appliances
- Small household appliances
- IT and telecommunications equipment
- Consumer equipment
- Lighting equipment
- Electrical and electronic tools (with the exception of large-scale industrial tools)
- Toys, leisure and sports equipment
- Medical devices (with the exception of all implanted and infected products). Note: Category 8 devices are exempt from RoHS directive
- Monitoring and control instruments. Note: Category 9 devices are exempt from RoHS directive
- Automatic dispensers
Exemptions: There are a number of applications for lead, mercury, cadmium and hexavalent chromium, which are exempted from the WEEE and RoHS Directives. In addition, producers can submit requests for exemptions. To get details on the latest exemptions, please refer to the local regulating agency for the country in question.
Useful links:
UK Department of Trade and Industry
European Commission
European Environment Agency, WEEE and RoHS
Rohswell: China RoHS and China WEEE
PDF version of Directive 2002/96/EC, which includes more detail on categories as well as exceptions
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- How are WEEE and RoHS related?
The WEEE Directive aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. The RoHS Directive dovetails into WEEE by reducing the amount of hazardous substances used in product manufacture. This reduces the occupational risk to recycling personnel, reduces the need for special handling and treatment, and places less toxins into landfills and the environment.
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- Who needs to comply with RoHS?
If your company is a producer and does business with countries in the EU, per the guidelines below, you will need to comply with the RoHS Directive. Be aware that other countries, including the US, China, and Japan, are also implementing regulations on restriction of hazardous substances, so it is imperative that you check with local regulations to ensure you understand and can comply with local guidelines.
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- Who is considered a producer?
A 'producer' of electrical or electronic products includes companies which manufacture electrical or electronic products, but also importers and distributors of electrical and electronic products. Producers will also include retailers who sell their own branded products and assembly companies selling their own branded products.
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- What does 'producer responsibility' mean for recycling?
Producer responsibility means making the 'producer of a product' responsible for the product once it becomes waste. At the moment in some EU states, the company or individual disposing of waste is responsible for the costs of its disposal or recycling. The general public pay for waste management through various taxes, while businesses pay waste collection companies to remove and manage their waste. In the future, producers of electrical products will be paying for the management of their products once they become waste.
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- We are not a brand owner, we only assemble using specified materials. Why do I need to do testing?
Given the current uncertainty with incoming components, screening is a recommended step to ensure that the appropriate components are used with the appropriate process. This step can assist with protecting the liability of both your customers and yourself. The danger of a mix-up can be costly for a few reasons. For a shipment to the EU, it can mean non-compliance and possible fines and loss of reputation. For shipments of RoHS exempt materials, like those for telecommunication, servers or military, a mix-up can mean product failure.
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- Can we continue to sell products containing the restricted substances outside Europe?
As the ROHS Directive is a European Directive, it will be implemented in all European Member States. Countries outside the European Union will not need to impose the same restrictions however they may choose to do so under their own domestic legislation. China, Japan and the US are just a few examples with local regulations/guidelines regarding restricted substances.
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- What are the business implications if my products contain amounts of the restricted substances above the maximum allowable limit?
There are several implications, including having your products banned from sale or import into EU member countries; or banned from approved supplier lists of major companies (especially global organizations doing business with EU member countries). If your product is placed on the market after July 2006 and contains the banned substances, your company could face serious financial penalties, e.g. violation fines, recalls, etc.
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- How do these Directives impact the products I have from Thermo Fisher Scientific, and how do I handle recycling Thermo products?
Most Thermo Fisher Scientific products fall into either Category 8 or 9 and are therefore exempt from the RoHS Directive. Thermo Fisher Scientific will continue to monitor the application of the RoHS Directive to its products and will comply with any changes as appropriate. Recycling will be offered for those Thermo Fisher Scientific products which are within the scope of the WEEE Directive. Products falling under the scope of the WEEE Directive available for sale after August 13, 2005 will be identified with a "wheelie bin" symbol. More information on recycling Thermo Fisher Scientific products
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- Which products are currently exempt, and will there be changes in the future that impact my products?
The Annex of the ROHS Directive lists a number of current exemptions where the restricted substances can continue to be used. This list of exceptions can be reviewed at European level. Additional exemptions can be proposed when the elimination or substitution with other substances is technically or scientifically impracticable or would cause other undesirable impacts. However, this review process will take time and any further exemptions will need to be supported sufficient and suitable evidence. It will need to be agreed at European level. Details can be found in Annex 1A of the Directive, as well as at other sites like the UK -DTI
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- What documentation will be required for RoHS compliance?
This is not clearly and consistently defined at this time; there are several published guidelines from various organizations attempting to standardize what is necessary for "Self Declarations of RoHS Compliance" and "Materials Compositions Declarations", but these are still only proposals generated by the affected industries (vs. standards). The Directives do state that a producer must show "due diligence" in attempts to meet the restrictions outlined in the Directives. In case of discovery of non-RoHS compliant equipment, a producer needs to provide "evidence" of compliance, and it is generally believed that solely using suppliers materials declarations will be insufficient, and that the producer will need to provide evidence (internal or external test data or certification).
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- What does "Homogeneous substance" mean and how does it impact RoHS test results?
Homogeneous is defined as:" a single unit that can not be mechanically disjointed into single materials. Understood as "of uniform composition throughout". This means samples like raw materials (e.g. solder) and uniform components (e.g. plastic housing) can be tested, whereas things like coated metals/plastics or assembled printed circuit boards will need to undergo some mechanical sample preparation prior to testing for RoHS substances. Depending upon the sample, this could be as simple as removing a plastic cover from a metal component, or as complicated as a full chemical digestion. The IEC "Procedures for the Determination of Levels of Regulated Substances" is one good reference for RoHS sample test protocols.
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- How are spare parts impacted, for both equipment manufactured priori to July 2006 as well as products manufactured after that date?
Products put on the market after July 1st, 2006 (regardless of when they were manufactured), as well as the associated spare parts, are subject to the RoHS Directive and must comply with the stated limits on the identified restricted substances. The RoHS Directive does not apply to spare parts for the repair or re-use of electronic equipment placed on the market prior to the July 1st date . This allows old equipment to be maintained and allows for the potential long term use or re-use of the equipment. So, it is permissible to put spare parts on the market (that contain the restricted substances) for the repair/re-use of electronic equipment put on the market prior to July 1st, 2006, but NOT to repair new equipment (put on the market after July 1st, 2006).
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- What is meant by non destructive testing of a sample?
The sample in question can be analyzed with little to no sample preparation, and the analysis is performed without any changes to the mechanical or physical properties of the sample; the sample (materials, component, system, etc) can be used for its originally intended use after analysis (if levels of the restricted substances are below or equal the stated maximum levels). This type of analysis can be performed by XRF and FTIR.
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- Is hexavalent Cr used in capacitors? If so, is it exempt?
Chromium Oxide is typically found in capacitors. This is not hexavalent Cr, and therefore is not a prohibited substance. However, given that the XRF technique only detects total Cr, this conclusion can not be made without further testing or proper certificates of analysis if measured concentration of chromium exceeds the regulatory level. However, if the analysis for total chromium is substantially below the regulated threshold (at present 1000 ppm/0.1%), then the hexavalent chromium level will be below the maximum limit as well.
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- How can XRF relate ppm/% rates to homogeneous substances?
Portable XRF is based on calibrations that are comprised of homogenous samples that contain various elements at various levels. Given that the components/parts in questions contain well over the RoHS action level, the data generated from the analyzer can be used to make a rapid decision as to whether or not the sample contains <700ppm or >1300ppm in the case of total Cr, Br, Hg and Pb and <70ppm or >130ppm in the case of Cd.
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- How do I interpret XRF screening results from a PCB?
Depending upon the spot size (sample viewing area) for a given XRF instrument, an analysis of a populated PCB can be challenging as it may be difficult to pinpoint exactly where the detection of a prohibited element may be. However, screening with XRF does give a useful first pass, non-destructive indication if there may be an issue. Furthermore, it can assist in ensuring continued surveillance as reading in the same area of a PCB should be similar over a batch or multiple batches of the same product.
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- What is the required measurement times for XRF screening?
Typically non-compliant components provide the analyzer with enough signal from prohibited substances, like Pb, that a 30 second analysis is sufficient. However, some samples may require up to 120 seconds or more. This is mainly to determine whether or not the Cd concentration is below 100ppm. Also, smaller samples usually require longer analysis time. Ultimately, the question "how long to measure" is answered on the basis of desired measurement error; precision of XRF method improves twofold for each fourfold extension of measurement time.
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- What if I have materials declarations from suppliers stating their products do not contain any of the regulated hazardous substances, but my finished products are discovered to have the restricted substances in excess of the maximum allowable limits?
There is a variety of different legislation out there that addresses this issue; be aware that some laws create a number of offences that simply contain an absolute prohibition against doing something. In the case of RoHS, this would be placing non-compliant products on the market. In these cases it does not matter that you did not intend to do wrong or were unaware of requirements, the fact that you have contravened the law is sufficient to allow a potential conviction.
If this occurs, you can use a "due diligence defense", meaning you would need to be able to demonstrate that you have taken all reasonable steps/precautions and have exercised all due diligence to avoid committing the offence. The RoHS regulations do not describe in any detail specific requirements regarding the due diligence defense, but you may want to consider a multi-faceted approach, including
- Demand materials declarations (clearly stating compliance) from your suppliers;
- Audits of suppliers to review test data, process and change control, etc;
- Screening (XRF or FTIR analysis) in your own supply chain, as well as potentially statistical testing on your finished goods;
- Using an independent test lab to certify your or your suppliers products, keep this data for historical documentation;
- Strict separation and inventory management of compliant vs. non-compliant parts.
So, bear in mind that sitting back and doing nothing is unlikely to protect you, and if reasonable precautions are not taken, any defense in this matter will likely fail.
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- The flow chart depicting the "Recommended Test Methods for RoHS Substances" has EDXRF for both screening and verification testing for lead and cadmium; is this correct?
EDXRF is an elemental analysis technique that is indeed recommended for the screening of RoHS elements. The limitations pertaining to ED XRF are related to the limits of detection for a given analyzer, as well as the spot size (sample viewing area) for the analyzer, along with the nature and size of the sample in question. Meaning, if a measurement made on an assembled PCB shows between 75 and 125ppm of Cd, this results is considered inconclusive and further analysis needs to be done. In this case, a small spot analyzer, like the MicroXR, can be used to pinpoint a location down to 1mm area, thus providing a more accurate reading. So, in some cases, the MicroXR can be used for verification testing (but not always).
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- What is this symbol?
These are known as the "wheelie bin" symbols, used to show that the equipment should not be disposed of in the normal waste stream. for electrical equipment manufactured after 13 August 2005, a horizontal bar underneath the crossed-out wheelie bin is added to show that the equipment is waste which has been manufactured after the Directive came into force in August of 2005.
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