RoHS directive – A useful guide for entrepreneurs

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Importing electronic devices to the EU member countries requires to fulfil a range of additional rules by exporters. One of such procedures is complying with the RoHS directive that is the main point of the following article. We are going to explain the most important issues that are connected with the RoHS document, as well as describe the procedures related to products imported in accordance with the RoHS procedure.

What is the RoHS directive?

The name of the directive is an abbreviation of Restriction of Hazardous Substances and it was introduced by the European Union. The ordinance was voted through on 27 January 2003, but it went into effect on 1 July 2006.

The main goal of the RoHS is to prevent, as much as possible, from using substances that are included in electrical and electronical products which are dangerous for user’s health. Another important aim of the RoHS document is protection of the natural environment by utilization of such products.

According to the RoHS, electrical and electronical products can’t include substances that are dangerous for health. It concerns finished goods which are sold in the European Union, excluding semi-finished products that are necessary in order to produce the finished goods.

Where is the RoHS directive effective?

The procedures must comply with the RoHS ordinance in the member countries of European Union, in Switzerland, Turkey, Norway, and Iceland, however, other countries in the world also perform it records.

What kinds of products must comply with the RoHS directive?

According to the RoHS decree, the following groups of products must comply with its norms:

  1. Large and small household appliances, e.g. coffeemakers, electric cookers.
  2. IT equipment, e.g. computers, printers.
  3. Telecommunication devices, e.g. cordless phones, fax machines.
  4. Commonly used products, e.g. radio sets, musical instruments.
  5. Lightning equipment, e.g. light bulbs.
  6. Tools, e.g. drills, excluding large stationary industrial equipment.
  7. Toys, e.g. video game consoles, but also leisure and sports equipment.
  8. Medical devices, e.g. devices used in cardiology, in-vitro diagnostic devices.
  9. Monitoring and control instruments, e.g. thermostats, excluding military equipment.
  10. Automatic dispensers, e.g. coffee dispensers, cash machines.

What products are included in the group of products that are subject to dispute and don’t have to comply with the RoHS directive?

Some products should comply with the RoHS ordinance, but due to their characteristics, they are not subject to it.

We have prepared a few examples of such products, i.e.:

  1. Toys that produce sounds, e.g. teddy bear. It should be included in the ‘toys’ category, being subject to the RoHS decree, however it was accepted that the electronic system, that allows the toy to produce sounds, is only an additional element, and when it stops working, the toy will still play its role. That is why, such toys are exempt from the RoHS ordinance.
  2. Offset printers. In general, printers should be included in the ‘IT equipment’ category, however an offset printer works differently than the ‘traditional’ one. A ‘traditional’ printer works along with the computer – we open the particular file and the content that is to be printed is taken directly from our computer. The offset printer takes the content that is to be printed from printing forms, not from the computer. That is why, the offset printer can’t be included in the ‘IT equipment’ category. In such a case, the offset printer is a kind of a tool, but such a category also must be accordant with the RoHS directive. However, when the printer is stationary and quite large, it is exempt from the RoHS decree.
  3. Mobile power generators which are powered by fuel (oil or petrol). Such products should be included in the ‘tool’ category, however considering the fact that they are powered by fuel instead of electricity, they are exempt from the RoHS ordinance.

The above examples show that the RoHS decree is not completely strict, and there are products that don’t have to comply with the directive, although they seem to be their subjects.

What are the possible concentration values of the substances according with the RoHS directive?

The substances considered to be harmful according to the RoHS ordinance are: lead, mercury, cadmium, hexavalent chromium, and polibrominated biphenyls (PBB). In some cases, it is not possible to completely eliminate such substances from the electric and electrical devices, that is why, the maximal concentration of them was set. The product is allowed to include every aforementioned substance in the amount of 0,1% of its weight, excluding cadmium that is allowed to be included in 0,01%.

How should the RoHS marking look on the product?

The RoHS directive does not precise the exact marking that should be placed on the products. However, producers should place the marking in such a way to be apparent for the client. The marking is put so as the clients know if the product complies with the RoHS decree. In addition, while importing, it is needed to pay attention to such markings as ‘green’ and ‘PB free’. When the particular product has one of these markings, it does not necessarily comply with the RoHS directive. The ‘green’ marking means that the product does not include substances which are harmful to health, but it does not mean that soldering was performed in a lead-free way. It is guaranteed only by the RoHS marking. The ‘PB free’ marking means only that the particular product does not include lead.

Who was influenced by the RoHS directive the most?

  1. Importers and all individuals who trade products that are subject to the RoHS ordinance in the EU member countries, because they have to precisely check if their suppliers produce goods that comply with the RoHS decree. Most of them forget about it.
  2. Producers who sell their products that are subject to the directive to the EU member countries, because they are obliged to appropriately adjust their products, what makes the manufacturing cost higher due to the necessity of using more expensive metals and substances.

Is the declaration of RoHS compliance needed?

The European Union does not require the declaration of RoHS compliance from producers. Most of producers include the information if the product complies with the RoHS directive or not on the packages of their goods.

It needs to be remembered that in order to make the product compliant with the RoHS, it is not enough to pay attention to the limits of the concentration of the substances. The products must be also soldered in a lead-free way.

Summary

When we produce or import electric and electrical products to the European markets, we need to pay special attention to certificates such as RoHS, WEEE and CE. While looking for a supplier, importers can’t just take the price into account, but they have to precisely check if the particular producer meets all the standards for their products. We, as a company, always check what certificates the producer has while verifying and looking for a supplier for our clients.

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