Every North American electronics company that trades in the EU should make at least one New Year’s Resolution: to learn how RoHS 2 will impact them, because ready or not, this regulation takes effect January 2, 2013.
RoHS 1 vs RoHS 2
RoHS 1, which has applied since 2006, restricted the use of six substances in a range of electrical and electronic products. The original six banned substances—lead, cadmium, mercury, hexavalent chromium and flame retardants PBB and PBDE—still remain under RoHS 2, but the intention is to potentially include others, including 4 substances of very high concern as cited under the REACH legislation: HBCDD, DEHP, BBP, DBP. In RoHS 1, the directive applied to eight of the ten product categories which were listed in the Waste Electrical and Electronic Equipment (WEEE) Directive: large household appliances, small household appliances, IT/telecommunications equipment, consumer equipment, lighting equipment, electrical/electronic tools (except large scale stationary industrial tools), toys/leisure/sports equipment and automatic dispensers.
Under RoHS 2, the remaining 2 categories have been added from WEEE: medical devices and monitoring and control instruments including those for industrial use. In addition, there’s one more catch all category: all other EEE not covered by any of the other categories! Yes, there are exclusions, and I’ll tell you where you can find them at the end of this blog.
RoHS 1 simply required that any product in scope should not contain any of the restricted substances and that the party placing the product on the market in the EU (could be the manufacturer, importer or distributor) should maintain records to show compliance, should they be asked. RoHS 2 demands a whole new level of compliance from all parties in the supply chain, including distributors. The precise responsibilities depend on the role, but can include a conformity assessment, CE Marking, maintenance of compliance throughout production, documenting evidence of compliance to be kept for 10 years and self reporting of non-compliance.
RoHS 2 Compliance Deadlines
January 2, 2013: All products covered by the original directive (the eight I cited above) must comply, paperwork and all.
July 22, 2014: Medical devices, monitoring and control instruments (excluding those exclusively for industrial and/or professional use) must comply.
July 22, 2016: In-vitro diagnostic medical devices must comply.
July 22, 2017: Monitoring and control instruments which are designed exclusively for industrial and/or professional use.
July 22, 2019: All other products (the category 11 catch-all)
This blog is meant to serve as an alert and to give you a broad overview of the differences and obligations between RoHS 1 and RoHS 2. Much more detailed information and access to legislation experts can be found here.