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Since late 2018, RAPEX, the EU’s Rapid Alert System for dangerous non-food products, has issued notification of numerous RoHS and POP non-conformities, relating to many types of electrical and electronic product.

SAFEGUARDS | Electrical & ElectronicsNO. 056/19

Earpods plugged to a smart phone

Since late 2018, the EU Rapid Alert System for dangerous non-food products (RAPEX) has issued multiple notifications of non-conformities against the Directive on the Restriction of Hazardous Substance (RoHS) in electrical and electronic equipment. Many types of electrical and electronic product have been found to exceed RoHS limits. This includes communication devices, lighting equipment, electronic accessories, electric toys and other products. Most of the notifications are from the market surveillance bodies of EU Member States Sweden, Malta, Lithuania and Latvia. The notifications show that the RoHS violations are mainly due to excessive content of lead and cadmium in certain solders. Also, short chain chlorinated paraffins (SCCPs) have been detected over the proscribed limit in some plastic materials, in which case the product does not comply with the Regulation on Persistent Organic Pollutants (POP). A non-exhaustive list of recent RoHS and POP alerts is summarized in Table 1.

Table 1. Recent RoHS and POP alerts on RAPEX (non-exhaustive list).

Product Risk Measures adopted by notifying country
Headphones The solder contains lead (54%). Withdrawal of the product from the market. The company is reported to the prosecutor.
Earbuds The solder contains lead (83%).
Earphones The product contains lead and cadmium. Withdrawal of the product from the market.
Foldable desk lamp The solder contains lead (71%). Withdrawal of the product from the market. The company is reported to the prosecutor.
Electric lamp Solder contains lead (65%) and the plastic cord contains short chain chlorinated paraffins (SCCPs) (0.3%). Withdrawal of the product from the market.
Torch The solder contains lead (50%). Withdrawal of the product from the market. The company is reported to the prosecutor.

Torch The solders contain cadmium (0.39%) and lead (48%).
LED helmet light The solder in the product contains lead (46%).
RCA Cable The product contains lead (0.3%). Withdrawal of the product from the market.
Drone with lights The solders contain cadmium (0.1%) and lead (79%).
Safety reflector with LED The solders contain lead (81%) and the plastic contains short-chain chlorinated paraffins (SCCPs) (0.931%). Withdrawal of the product from the market. The company is reported to the prosecutor.
Reindeer kit (headwear with light) Solder of the battery compartment contains lead (79%). Withdrawal of the product from the market.
Fancy-dress accessory (bow tie with light) Solder in the battery compartment contains lead (68%).
Tamagotchi Solder in three different places on the toy contain lead and cadmium in concentrations above the limit values.
Electric ride-on car Lead concentrations in the solders exceed limit values.
Music Keyboard Four solders in the toy contain lead (61%) and cadmium (0.03%).
Toy mobile phone The solders contain too much cadmium (0.19%) and lead (77.3%). Destruction of the product.
LED toy Solder in four different places contain lead and cadmium in concentrations above the limit values. Withdrawal of the product from the market.

It is noteworthy that the restriction of four new phthalates (DEHP, BBP, DBP and DIBP) will come into effect for RoHS Annex I product categories 1 to 7, 10 and 11 from July 22, 2019, and with effect from July 22, 2021 for RoHS Annex I product categories 8 and 9, Medical and Monitoring Devices. The compliance of the newly enforced substances is highly likely to be subject to intense inspection by the EU Member States’ market surveillance authorities.

This increased notification frequency demonstrates that EU Member States are increasingly paying attention to RoHS compliance checks in market enforcement. SGS recommends enterprises to strengthen quality control for compliance with EU RoHS.

For enquiries, please contact:

Li Li 
Technical Support, EET RSTS
t: + (86) 21 61405135

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