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The RoHS Directive has recently been revised, Directive 2002/95/EC has been replaced by Directive 2011/65/EU, “RoHS II,” as of January 2, 2013 and some new requirements will be phased in over 6 years after publication of RoHS II in the Official Journal of the European Union in July 2011.

Selected examples of major changes in the new directive include:

  • RoHS is now a CE marking directive
  • Expanded Product Scope by phasing out permanent exemptions for medical devices, monitoring and control equipment as well as a new “open scope” category including other electrical and electronic equipment not covered by any of the other 10 categories
  • Maximum Validity period of exemptions for categories 1 to 7, 10, and 11 is up to 5 years & maximum validity period of exemptions for categories 8 and 9 is up to 7 years
  • New “obligations” for importers, manufacturers, and distributors
  • Manufacturers or their “authorized representative” must submit technical documentation (to substantiate compliance) upon request of a member state enforcement agency, and retain such documentation for 10 years after a covered product is placed on the market

One of the key changes here is the more stringent requirement for traceability of compliance documentation and retention of that data. The difficulty of this is that the RoHS directive requires this information for each homogenous material of the product. This requires a deep understanding and monitoring of the materials and chemicals being used throughout the supply chain. For companies who now need to check if their products are compliant to the RoHS Directive, there is more guidance and experience in the marketplace to follow including the revised IEC 62321 standard for sampling and testing products for RoHS and the harmonised EN 50581 standard for technical documentation.

IEC 62321 Revised

The IEC 62321 standard, which has been revised as of May 2013, provides some general guidance on:

  • Appropriate sampling strategy for testing product materials,
  • Detailed disassembly procedures and examples,
  • Improved sample preparation,
  • XRF screening methods and “wet” chemical testing methods

Also, IEC 62321-2 Annex B includes a list of components and the likelihood that these common components would contain the RoHS substances. The testing strategy would need to be tailored depending on the company’s final product whether it is a raw material, component, subassembly, or final product.

EN 50581

The harmonized EN 50581 standard provides more detailed information about what the expectations are for technical documentation required under RoHS II as a consequence of the CE mark.

EN 50581 covers the following aspects: content and traceability of the technical documentation, supplier and material confidence assessments (also covered in EN 62321), collection of technical documentation and evaluation of documentation for quality and trustworthiness including whether or not test reports follow IEC 62321 methods.

Information about the chemical content of components is more available than it ever was and there are methods and tools to support the collection and retention of this information that are cost effective and prevent unnecessary testing of materials and components.

  • RoHS II compliance strategies could include any combination of the following:
  • Utilizing software to manage material information from suppliers
  • Continuous supplier training programs
  • Conducting risk assessments on suppliers and materials
  • Test where necessary per a “Smart” testing strategy
  • Implementation of a data monitoring program
  • Implementation of a supplier monitoring program

WEEE update

If you are wondering what happened to WEEE, it is still around! The RoHS directive has been separated from the WEEE Directive. The WEEE Directive has also been revised.

WEEE II Directive 2012/19/EU will have a major impact on manufacturers and importers, and will require them to: register the products with respective organizations in EU Member States and provide required information; organize and finance the collection and the recycling of the electrical/electronic waste; inform waste management facilities of the appropriate re-use and treatment information for the products it places on the market; mark their product with the appropriate marking and implement Ecodesign in order to facilitate product reuse and reduce recycling costs.

Other countries outside the EU, are also adopting “RoHS – like” requirements. It is important to follow these legislations as well as other chemical requirements that have an impact on EEE products such as REACH, Danish Executive Order 113, and California Proposition 65.

For further information, please contact:

Nicole Effenberger
Business Unit Manager
International Electronics & EE Chemicals
SGS North America, Inc.
t: +1 973 461 7906

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