SAFEGUARDS | Electrical & Electronics NO. 069/17

SafeGuardS chemical substance

The restrictions on hazardous substances set out in the RoHS Directive (2011/65/EU) have applied to certain categories of electrical and electronic equipment since January 3, 2013. The transition period for industrial monitoring and control instruments shall end and the restrictions shall apply to instruments of that category which are placed on the market from July 22, 2017.

The RoHS Directive 2011/65/EU restricts the use of certain hazardous substances in electrical and electronic equipment (EEE) placed on the EU market.

Categories of EEE covered by the RoHS Directive:

  1. Large household appliances
  2. Small household appliances
  3. IT and telecommunications equipment
  4. Consumer equipment
  5. Lighting equipment
  6. Electrical and electronic tools
  7. Toys, leisure and sports equipment
  8. Medical devices
  9. Monitoring and control instruments including industrial monitoring and control instruments
  10. Automatic dispensers
  11. Other EEE not covered by any of the categories above

The restrictions applied first to EEE categories 1 to 7 and 10. The RoHS recast Directive (RoHS 2, 2011/65/EU [1]) specified the transition period following which the restrictions shall apply to all remaining categories of EEE. Thereby, the scope of application of the restrictions was extended to medical devices and monitoring and control instruments (excluding industrial ones) in 2014 and to in vitro diagnostic medical devices placed on the market from 2016.

Scope Extends to Industrial Monitoring and Control Instruments

From July 22, 2017 the RoHS Directive restrictions shall apply to industrial monitoring and control instruments, including cables and spare parts for their repair, their use, updating of their functionalities or upgrading of their capacity.

The restricted substances and the maximum concentration allowed in homogeneous materials are set out in Annex II of the RoHS directive as follows:

Substance Maximum concentration values by weight
Lead 0.1%
Mercury 0.1%
Cadmium 0.01%
Hexavalent chromium 0.1%
Polybrominated biphenyls (PBB) 0.1%
Polybrominated diphenyl ethers (PBDE) 0.1%

In addition to the substances listed above, Annex II of the Directive contains four phthalates (DEHP, BBP, DBP and DIBP) but the restrictions on the use of these substances shall not apply before July 22, 2019 for some of the categories of EEE and July 22, 2021 for the remaining categories.

Exclusions and Exemptions

It is worth remembering that certain applications are exempt from these restrictions and that these exemptions expire within a timeframe defined in the Directive, unless an extension is applied for by the industry and granted by the European Commission.

Also, some types of EEE are excluded from the RoHS Directive scope, such as transport, non-road mobile machinery for professional use that has an onboard motor, large-scale fixed installations, or equipment specifically designed to be part of another type of equipment that is exempted. The exhaustive list can be found in Annexes III and IV of the Directive.

CE Marking

This Directive imposes obligations on manufacturers, authorized representatives, importers and distributors of EEE in scope. Obligations related to CE marking apply. Among others, manufacturers shall design and manufacture EEE in compliance with RoHS, draw up the required technical documentation and an EU declaration of conformity. They shall implement production control systems and checks to ensure compliance and affix the CE marking.

Be aware that manufacturer obligations apply to importers and distributors in particular when they place EEE on the market under their own name or trademark.

SGS RoHS Services

Through a global network of laboratories and our requirements experts, SGS offers advisory services on requirements and compliance solutions to support companies affected by this Directive, be it for their conformity assessment or risk management in the supply chain. SGS offers RoHS testing services in laboratories accredited for the international standards applicable to these requirements and SGS RoHS Certification which is a voluntary product certification scheme. For further information, please visit our website.

For enquiries, please contact:

Adeline Maijala
Senior specialist – Certification
Requirements and Development
t: +358 9696 3229

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