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Frequently
Asked Questions About RoHS
1.What is RoHS?
RoHS is European Union Directive 2002/95/EC on the Restriction of Certain
Hazardous Substances in Electrical and Electronic Equipment.
2. What hazardous substances are covered by
RoHS?
RoHS restricts the use of lead (Pb), cadmium (Cd), mercury (Hg), hexavalent
chromium (Cr6+), polybrominated biphenyls (PBBs) and polybrominated
diphenyl ethers (PBDEs). Those restrictions are in addition to existing
regulations, such as the 47 categories of dangerous substances restricted
for use in nearly every product by EU Directive 76/769/EEC and its numerous
amendments.
3. What products are covered by RoHS?
The scope of RoHS is given in the EU WEEE Directive Annex IA, categories
1 -7 and 10. The following is a summary of covered product categories:
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (except large-scale stationary and
industrial tools)
7. Toys, leisure and sports equipment
10. Automatic dispensers
Categories 8 and 9, which cover medical devices and measuring and control
instruments, are exempt from RoHS requirements until which time the
EU Commission includes them (estimates are that this will occur in 2008
or 2009).
Electrical and Electronic Equipment (EEE) is defined as devices which
are dependent on electric current or electromagnetic fields to work
properly, including that equipment used to generate, transfer, or measure
such currents or fields. The definition of EEE for RoHS is limited to
those devices operating on a maximum 1000 Volts AC or 1500 Volts DC.
4. When do my products have to be compliant with RoHS?
The RoHS Directive goes into effect on July 1, 2006. If you are selling
products on the EU market, your products must be RoHS/WEEE compliant
by that date. Note, however, that many manufacturers are requiring compliance
from their suppliers earlier than July 1, 2006 so they can make sure
they can supply finished goods to the EU.
5. What are Maximum Concentration Values (MCVs)?
Maximum Concentration Values (MCVs) are limits set by the European Commission
for each RoHS-restricted substance in the Commission Decision 2005/618/EC
amending the RoHS Directive. MCV limits apply to each !°homogeneous
materiali± making up a product. Note that EU officials have stated that
RoHS is considered to be a ban on the listed substances, and that any
intentional use of those substances is not allowed. Other EU officials
have stated that the term i°intentional usei± has no meaning in relation
to RoHS. The MCVs are as follows:
0.1% by weight maximum for Pb, Hg, Cr6+, PBBs, and PBDEs
0.01% by weight maximum for Cd
6. What is a i°homogeneous materiali±?
The term i°homogeneousi± is understood as i°of uniform composition throughouti±.
Examples of i°homogeneous materials!± are individual types of: plastics,
ceramics, glass, metals, alloys, paper, board, resins, and coatings.
The Commission further states that a !°homogeneous material!± cannot
be mechanically disjointed into different materials.
7. What does i°mechanically disjointedi± mean?
The term !°mechanically disjointed!± means that the materials can be,
in principle, separated by mechanical actions. This means that an insulated
wire is considered as two homogeneous materials: the metal wire and
the plastic insulating material.
8. Are there any exemptions to RoHS?
Yes. The list of exemptions is growing all the time. Exemptions may
be found in RoHS and the RoHS Directive Annex. Information on pending
exemptions may be found at the UK
DTI website.
9. My company is based in the US. Why should we
worry about RoHS?
If you sell electrical or electronic equipment to any member country
of the European Union, or if you sell parts or materials to companies
that then sell their products on the EU market, your products are likely
to be covered by RoHS. But even if your products aren?ˉt destined for
the EU market, you still may have something to worry about. First, laws
such as SB 20 and SB 50 in California are already taking effect in the
US, and many more are in the works here and in countries such as China,
Japan, and Canada. Also, you may find that availability and reliability
are issues, since the !°old!± products containing restricted substances
will become harder to find and more expensive to buy. For example, even
though medical devices are now exempt from RoHS, manufacturers may have
problems getting printed circuit boards with the tried and true tin-lead
solder. That means they will have to test circuit boards with !°lead-free!±
solders to make sure they will be as reliable as the !°old!± boards.
10. Where do I find information on RoHS?
The following are good sources:
The United Kingdom Department
of Trade and Industry (DTI) ¨C they have the lead responsibility
for RoHS, WEEE, ELV, and Packaging Directives in the EU. Search for
!°DTI!± and go to the environment department, or click on the link above.
DTI - Sustainable Development and Environment: Latest
TAC Committee meeting notes
Europa is the website of the European Union. Information on RoHS is
available on that site, but is not as easy to find as on the DTI site.
Click on any of the links below.
EUROPA
- Environment
EUROPA
- RoHS Directive
EUROPA
- WEEE Directive
EUROPA
- Committee on Environment, Public Health and Food Safety
EEA
- European Environment Agency - Home
SCADPlus:
WASTE MANAGEMENT
The Electronics
Industry Alliance (EIA) often has free information on RoHS, but
you may have to join to get full access.
iNEMI
is also a good source of free information.
AeA is a good source for RoHS seminars and other information. AeANET
: Advancing the Business of Technology
11. My customer has sent me a i°material declarationi±; why does it
ask for information on substances not covered by RoHS?
Material Declarations are prepared by electrical and electronic OEMs
and companies throughout the supply chain. Rather than being specific
to RoHS, they are a compilation of all requirements concerning restricted
substances world wide. Those requirements may be from regulations or
they may be something your customer wants or needs. Material Declarations
also include elements or compounds that are not restricted but either
may become restricted or are needed by the company to assess other issues,
such as residual value. For example, it is desirable to know the gold
content of a material even though gold is not restricted, since the
material may have residual value depending upon its mass and gold content.
12. Do I need to test all my products for every item on the material
declarations?
No. If you tried to do that, you would get a very big bill from a laboratory.
First, you should try to obtain information on the concentration of
RoHS and other declarable substances in your materials from your suppliers
or from the manufacturer of the materials. If that information is not
available, you have two real choices: 1) test each homogeneous material
you use, but limit the testing to one set per unique material to avoid
duplication; only test the materials for substances that are likely
to be present as additives or contaminants (your lab should be able
to help with this); or 2) stop doing business with that client. Note
that the substances to be tested will vary from material to material;
for example, it does not make sense to test steel for brominated flame
retardants, but it does make sense to test for them in plastic.
In every case, it is highly recommended that you have your legal representative(s)
review the material declaration before and after you fill it out. These
material declarations may be used to place blame on you and/or your
company in case of an infraction in the EU. Tell your legal representative(s)
that the UK (and probably all other EU member states) will allow !°due
diligence!± as a defense for infractions. That means that third parties,
such as your company, may be prosecuted for infractions if your customer
can show due diligence. Part of that due diligence will be based on
the material declarations received from suppliers.
13. We sell populated circuit boards. How do we
demonstrate compliance with RoHS?
This is a difficult subject. The best and cheapest way is to get information
on RoHS compliance for each material or component from your suppliers.
If this is not possible, you have a difficult task. You will have to
get information for each !°homogeneous material!± comprising your populated
circuit board. It would be best to test each material BEFORE they get
made into individual components. Barring that, supply enough individual
parts to your lab (including samples of solders) so they may be tested
¨C it is very difficult, if not impossible, to test every homogeneous
material on a populated board for RoHS compliance. That is why ASTM
International Committee F40 has proposed testing materials for compliance
prior to their use in component manufacture: it is easier, and it is
less costly to the entire supply chain.
14. Why can?ˉt we just grind components into a
powder, then test for RoHS compliance?
Remember, RoHS compliance is based on each !°homogeneous material!±
and not components or devices. If a component or populated circuit board
is ground up and tested, restricted substance concentrations in the
homogeneous materials are diluted. If a lab grinds up a complex component
or entire product, they will not be able to state anything about RoHS
compliance, since they will not know which material any restricted substances
found come from, or if the restricted substance comes from an exempt
application.
The grinding equipment specified by the electronics OEMs to use in grinding
up components is difficult if not impossible to clean. Plastic and low
melting elements (e.g., lead) get smeared onto the blades and other
surfaces of the equipment. Also, abrasive samples such as populated
circuit boards will abrade parts of the equipment such as stainless
steel and contaminate the sample with chromium and/or nickel or other
elements.
For example, let?ˉs say that a circuit board is ground up using the
electronic OEM technique. The first issue will be whether the ground
sample has been contaminated by past samples or the grinding equipment.
Even if that was not an issue, let?ˉs say the final ground sample is
analyzed for TOTAL lead, cadmium, hexavalent chromium, mercury, PBB,
and PBDE. The analysis cannot separate exempt lead from non-exempt lead,
exempt cadmium from non-exempt cadmium, and so on. So which is the !°good!±
lead and which is the !°bad!± lead? No one can tell. Besides, there
is no way to create a certified reference material to validate the results.
So such testing is essentially WORTHLESS. If an electronics OEM tells
you to grind up your sample and you tell us to grind up your sample,
we cannot state compliance. Neither should you. Let the OEMs have the
data and let them state conformance or non-conformance based on the
results.
15. This is all very confusing. Isn?ˉt there a
better way to regulate substances?
While the EU has noble goals concerning protection of human health and
the environment, their means of doing so cause confusion and great expense
to industry. There is a better way to do this, and the EU is bound by
the World Trade Organization Agreement on Technical Barriers to Trade
(TBT) to do things to minimize costs and unnecessary work. Unfortunately,
no sector affected by the EU hazardous substances Directives has decided
to take the EU to task on the issues. The result is that supply chains
all over the world are spending billions of dollars more than necessary
to comply with the EU legislation. It is likely to get worse before
it gets better, but something must be done. If you feel your business
is spending too much on compliance issues PLEASE WRITE YOUR REPRESENTATIVES
IN GOVERNMENT! Government will only take action if industry says there
is a problem. Here are two people you can write to concerning RoHS issues:
Robert Straetz Dept. of Commerce, International Trade Admin. 14th &
Constitution Ave. Room 3632 Washington, DC 20230
202.482.4496 Email
Jim Sanford Deputy Assistant USTR for European Affairs Office of the
U.S. Trade Representative 1724 F Street, NW. Washington, DC 20508
202.395.3320 Email
16. What is being done to help companies comply
with RoHS?
ASTM International has created Committee F40 on Declarable Substances
in Materials. This Committee was formed to help industry develop the
standards and test methods necessary to comply with RoHS and other legislation.
ASTM is working with the US government and industry trade associations
to help fix this mess. If you would like to help, please feel free to
get involved ¨C email
Don Shuman at IMR Test Labs.
17. What test methods are used to assess RoHS
compliance?
Standard test methods are under development. The EU Member States have
not told anyone how they will test products for compliance, which is
a violation of the WTO TBT Agreement. Meanwhile, most labs are adapting
current tests to determine concentrations of RoHS substances in materials.
X-Ray Fluorescence (XRF), Inductively Coupled Plasma Atomic Emission
Spectrometry (ICP-AES), Cold Vapor Atomic Absorption Spectrometry (CVAAS),
Direct Mercury Analysis (DMA), UV-VIS, GC-MS, and other techniques are
currently being used.
18. What is i°Due Diligencei± defense?
Due diligence means that you can show that you did everything !°a reasonable
person would do!± in order to comply with the law. It also means that
you may be able to show that an infraction was not due to your or your
company?ˉs actions; you may be able to show that an infraction was due
to someone else?ˉs action or inaction. Material Declarations are used
to show due diligence, since they are used to get statements of compliance
from suppliers. Once such a document is in the possession of a company,
it may be possible to point to the document and state that there was
no reason to disbelieve the information given. Then, an infraction may
be assigned to a third party as if they had committed it themselves.
So anyone making false, misleading, or incorrect statements on material
declarations may be prosecuted as if they had committed the infraction.
19. How do I document my compliance efforts to
show due diligence?
Keep your test results, Certificates of Analysis, and Material Declarations
in a safe, accessible place. It is recommended that you keep both hard
copies and electronic copies. Make sure you keep records of everything
you fill out for other companies. Also, it is important to document
any changes you made to your products, production method, or materials
in order to comply with RoHS ¨C this also helps show due diligence.
Keep track of costs associated with compliance as well.
20. Is plating a i°homogeneous materiali±?
According to the EU Commission, plating and coatings are !°homogeneous
materials!±. The problem with this view is that in chemical analysis,
plating and coatings are commonly removed from substrates by chemical
means, and are not !°mechanically disjointed!± from the substrate. This
is not such a big problem technically, however, since there are quite
a few chemical methods for removing plating and coatings from surfaces.
But if the Commission or the TAC decides to specify that plating and
coatings must be removed by mechanical means, we will be left with insurmountable
technical challenges involved with mechanical removal of plating and
coating from small, complex parts. Imagine trying to mechanically remove
a 0.001!± zinc coating from the surface of a galvanized screw without
removing any of the steel. Impossible? Maybe. Impractical? Absolutely.
One exception to the chemical removal of coatings from substrates is
hexavalent chromium conversion coatings. Since hex chrome coatings vary
in mass over time due to exposure to the environment and because hexavalent
chromium coatings are often very thin (on the order of 200 nanometers),
determining the total coating mass on a chromated surface is difficult
if not impossible. Besides, there exist no certified reference materials
with which such a method could be evaluated, and it is unlikely that
such reference materials will ever be produced. It is the standard practice
that hexavalent chromium coatings are determined in units of mass of
hexavalent chromium per unit area (such as ug/cm2) instead of weight
percent. But the EU Commission has not backed away from their definition
of hexavalent chromium conversion coatings as homogeneous materials,
nor have they changed their MCV units of weight percent.
21. Where in i°oldi± electronic equipment is hexavalent
chromium found?
Hexavalent chromium is used in two general applications in relation
to electronic equipment: as a chromate conversion coating on metal surfaces
to act as a corrosion inhibitor, and as pigments in plastic and ink.
Other possible applications in relation to electronic equipment are
the use of hexavalent chromium in the textile, leather, and glass industries.
Note that the chromium found in a metal alloy such as stainless steel
is not considered to be in the hexavalent state, and it is not environmentally
available; the exception to this statement is when high chromium steels
are welded, hexavalent chromium may be created and released in the fumes.
Pigment colors that may contain hexavalent chromium include red, yellow,
orange, and green.
22. What are the steps my company should take
toward demonstrating RoHS-compliance of our products?
The first step is education. It is very important to understand, as
much as possible, what it means to be RoHS-compliant and what products
are affected by RoHS. One of the most important things to know is that
the (proposed) basis of compliance is each !°homogeneous material!±;
that means that each material used to construct every part in every
covered electrical and electronic product must comply with RoHS. It
is also important to know what is and is not exempt from RoHS. There
are several ways to go about educating yourself and your company, including
attending seminars, hiring in a consultant for a seminar, and reading
free information available on the internet (the best official sites
are www.dti.gov.uk/sustainability/
and www.europa.eu.int/comm/environment/index_en.htm.)
The second step is awareness. Make sure that upper management is aware
of RoHS, when it comes into effect, why the company's products are affected,
and what the potential impact on the company might be. Most people in
the know about RoHS will tell you that it is vital that leadership and
support for a RoHS-compliance effort comes from upper management. RoHS-compliance
can be a costly and time-consuming endeavor, so upper management will
have to be on board. RoHS-compliance can mean that your company will
have to go through big changes, including retooling, redesign, renumbering
of part numbers, adjustment of purchasing practices, and editing of
drawings and other internal company documentation such as material specifications.
The third step is assessment of your product line. In a very real sense,
this is risk assessment: you are trying to determine in which cases
you know you are compliant, in which cases you know you are not in compliance,
and in which cases you do not know if you are compliant. Risk assessment
should be conducted with !°due diligence!± in mind, meaning that you
should do what a reasonable person would do to ensure your products
comply. That usually means you have to be able to back up your claims
of compliance with statements and/or data. The following mantra should
be running through your head: !°What do we think, what do we know, what
can we prove?!±
The fourth step is to do a survey of your materials and parts suppliers.
You should ask them if their products are RoHS-compliant and if they
are, ask them if they can supply either a statement to that effect or
a certificate of analysis. If not, ask them if and when they expect
to be compliant or if they would be willing to get the necessary information
together to support their product compliance. That may require them
to do a survey of their suppliers and/or test their products. You may
want to test their products if the statements you receive are suspect.
The fifth step is to fill in the gaps in your product compliance. That
may mean you will have to change suppliers to those who can demonstrate
RoHS-compliance, or you may have to test your remaining items for compliance.
Make sure that any testing you have done is done by a competent laboratory;
the best choice is a materials testing laboratory with accreditation
to ISO 17025. It is not recommended that you engage a laboratory without
the assurance that their results are trustworthy. A key to making such
a judgment is to ask the laboratory if, based on the results of testing,
they will make a statement of RoHS-compliance. If they will not do so,
you may as well be throwing your money away.
The sixth and last step is to organize all the information you have
gathered to back up statements of compliance for each product. This
information should be kept available in case it is requested by your
clients or by an enforcement authority. It is recommended that you keep
hard copies in addition to electronic copies of the information.
23. What is the difference between a PBDO and
a PBDE?
There is no difference. These are acronyms which stand for different
names of the same compounds. So PBDOs are restricted by RoHS, because
they are PBDEs.
24. What is the official definition of i°homogeneous
materiali±?
Unfortunately, there isn?ˉt one, and there will not be an official definition.
The EU Commission says that only the European Court of Justice may decide
what the definition will be. The best advice I can give is to follow
the definition(s) given in the EU Commission FAQ document or the UK
DTI draft RoHS regulations, because the definitions will not appear
in any official document.
25. Should energy dispersive XRF be used to determine
RoHS compliance?
Because energy dispersive XRF, or EDXRF, is a quick and easy technique
for measuring chemical compositions, IMR Test Labs has hoped that it
would be a useful, time and cost-saving method for analysis of samples
for RoHS substances. But even the IEC TC 111 WG3 has shown in a recent
round robin that the technique is not yet accurate or precise enough
to yield dependable results. We continue to hope that EDXRF will be
developed into a sound, trustworthy technique for analysis of RoHS substances
in a wide variety of materials. Right now, we suggest that anyone using
XRF to measure RoHS substance concentrations take care in evaluating
the results.
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