Your guide to understanding new RoHS 2 directives
Most manufactures in the supply chain for European goods are familiar with the original Restriction of Hazardous Substances, European Union Directive 2002/93/EC, more commonly known as RoHS. This directive restricts the maximum concentration limits of lead, mercury, cadmium, hexavalent chromium, polybrominated bipheyls (PBB), polybrominated diphenyl ethers (PBDE) in Electrical and Electronic Equipment (EEE).
What is RoHS?
In June of 2011 the European Union Parliament and Council passed Directive 2011/65/EU. Effective January 2, 2013, this new RoHS Directive, also known as RoHS2 or RoHS Recast, updates, adds uniformity, and expands the extent of the previous RoHS Directive. It deals with the same hazardous substances and the same maximum concentration limits as RoHS; therefore, all products meeting the substance restrictions on RoHS remain compliant to the substance restrictions of RoHS2.
What is Changing with RoHS2?
The scope of RoHS2 is expanding to phase in previously excluded categories, such as; medical devices, and monitoring and control instruments, over the next seven years, so that all EEE will be covered by July 2019. Additionally, exemptions have been given new more stringent criteria for meeting the conditions of exemption. One of the new criteria is that all exemptions now have an expiration date with the opportunity for renewal.
In order to create standardized certification and standardized enforcement across the EU member states, RoHS2 becomes a part of the CE marking requirement. This means that it uses the CE mark to demonstrate compliance with the Directive and makes RoHS2 compliance an additional requirement for obtaining CE approval. As with RoHS, manufactures need to work with their supply chain to monitor the hazardous substances in their products. However, RoHS2 has become more ridged in its documentation requirements.
Along with this comes stricter legal enforcement. No longer will a defense of 1. not knowing that the product contains hazardous substances or 2. not understanding RoHS, work. The best defense for manufactures is to practice due diligence. Most manufacturers are interpreting this to mean that phrases, such as, to the best of our knowledge or to our knowledge are no longer acceptable for certifying RoHS2. It also means that if a supplier cannot give you RoHS2 certification, or you are not confident they are in compliance with the new Directive, you are required to send samples to an independent lab for testing. Also, many consultants are advising manufactures to test any parts that they have even the slightest doubts about.