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Summary



The Restriction of Hazardous Substances in Electronic Equipment Directive (2011/65/EU) came into force on the 21st July 2011. The application and enforcement were aligned with the New Legislative Framework.

The Directive is aimed at eradicating certain hazardous substances from new electrical and electronic equipment (EEE). Producers of EEE within the scope of the Directive are responsible for ensuring that their products meet the requirements of the Directive.

The RoHS requirements apply to end products that fall within the scope of the Directive. However, as a final product is made up of components and sub-assemblies it is inevitable that all components and sub-assemblies must not contain any of the restricted substances above the defined maximum concentration values. A technical file must be produced supporting compliance to the directive. There are specific exemptions from the RoHS directive as the Commission realizes that it may not be possible to manufacture some products without the use of banned substances. The RoHS Regulations in the UK are specifically worded so that any European Commission Decisions reflecting exemptions to the RoHS Directive become UK law as soon as they are officially published.

The RoHS enforcement agency for the UK is the Office for Product Safety and Standards. Contravening or failing to comply with the prohibition on hazardous substances in the RoHS Regulations could result in those held responsible facing a fine up to the statutory maximum (currently £20000) on summary conviction or an unlimited fine on conviction on indictment. Also, the 2008 RoHS Regulations gave the enforcement agency the further power to issue enforcement notices requiring non-compliant goods to be withdrawn from the market.

Purpose



The RoHS (2011/65/EU) Directive prevents all new electrical and electronic equipment placed on the market in the European Economic Area from containing Lead, Mercury, Cadmium, Hexavalent chromium, Poly-brominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE), except in certain specific applications, in concentrations greater than the values shown within the Directive.

On 31st March 2015 the RoHS Directive was amended by Directive 2015/863 which adds a further 4 restricted substances. The effective date of restriction for the additional substances is from 22nd July 2019 for products placed on the EU market. Medical devices have until 22nd July 2021 to comply with the additional restrictions. The GOV.UK website provides useful information. 

These values have been established as 0.01% by weight per homogeneous material for Cadmium and 0.1% for the other nine substances.

The additional substances are:

  • Bis (2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

They are all Substances of Very High Concern (SVHC) as defined in 2015/863 Paragraph 5.

The restriction of DEHP, BBP and DBP does not apply to toys as this is already covered under Regulation 197/2006 entry 51 to Annex XVII.

We are also aware of the stakeholder consultation in the first part of 2018 covering the collection of information for seven substances to be subjected to an assessment with a view to the review and amendment of the RoHS Annex II list of restricted substances. The seven additional substances are:

  • Diantimony trioxide
  • Tetrabromobisphenol A (TBBP-A)
  • Indium phosphide
  • Medium Chain Chlorinated paraffins (MCCPs)
  • Beryllium and its compounds
  • Nickel sulphate and Nickel sulfamate

Cobalt dichloride and Cobalt sulphate 


 

 

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