RoHS

The Restriction of Hazardous Substances Directive 2002/95/EC (RoHS 1), short for Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment, was adopted in February 2003 by the European Union. The initiative was to limit the amount of hazardous chemicals in electronics. The RoHS 1 directive took effect on 1 July 2006, and is required to be enforced and became a law in each member state. The directive restricts (with exceptions) the use of ten hazardous materials in the manufacture of various electronic and electrical equipment. In addition to the exceptions, there are exclusions for products such as solar panels. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC (now superseded ) which sets collection, recycling, and reclamation goals for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic electronic waste. In speech, RoHS is often spelled out, or pronounced , , , or , and refers to the EU standard, unless otherwise qualified.

The Restriction of Hazardous Substances Directive 2002/95/EC (RoHS 1), short for Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment, was adopted in February 2003 by the European Union. The initiative was to limit the amount of hazardous chemicals in electronics. The RoHS 1 directive took effect on 1 July 2006, and is required to be enforced and became a law in each member state. The directive restricts (with exceptions) the use of ten hazardous materials in the manufacture of various electronic and electrical equipment. In addition to the exceptions, there are exclusions for products such as solar panels. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC (now superseded ) which sets collection, recycling, and reclamation goals for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic electronic waste. In speech, RoHS is often spelled out, or pronounced , , , or , and refers to the EU standard, unless otherwise qualified. ===Examples of product components containing restricted substances=== RoHS restricted substances have been used in a broad array of consumer electronics products. Examples of components that have contained lead include: paints and pigments PVC (vinyl) cables as a stabiliser (e.g., power cords, USB cables) solders printed circuit board finishes, leads, internal and external interconnects glass in television and photographic products (e.g., CRT television screens and camera lenses) metal parts lamps and bulbs batteries integrated circuits or microchips Cadmium is found in many of the components above; examples include plastic pigmentation, nickel–cadmium (NiCd) batteries and CdS photocells (used in night lights). Mercury is used in lighting applications and automotive switches; examples include fluorescent lamps and mercury tilt switches (these are rarely used nowadays). Hexavalent chromium is used for metal finishes to prevent corrosion. Polybrominated biphenyls and diphenyl ethers/oxides are used primarily as flame retardants. ===Life-cycle impact assessment of BFR-free plastics=== The ban on concentrations of brominated flame retardants (BFR) above 0.1% in plastics has affected plastics recycling. As more and more products include recycled plastics, it has become critical to know the BFR concentration in these plastics, either by tracing the origins of the recycled plastics to establish the BFR concentrations, or by measuring the BFR concentrations from samples. Plastics with high BFR concentrations are costly to handle or to discard, whereas plastics with levels below 0.1% have value as recyclable materials. There are a number of analytical techniques for the rapid measurement of BFR concentrations. X-ray fluorescence spectroscopy can confirm the presence of bromine (Br), but it does not indicate the BFR concentration or specific molecule. Ion attachment mass spectrometry (IAMS) can be used to measure BFR concentrations in plastics. The BFR ban has significantly affected both upstream (plastic material selection) and downstream (plastic material recycling). === 2011/65/EU (RoHS 2) === The RoHS 2 directive (2011/65/EU) is an evolution of the original directive and became law on 21 July 2011 and took effect on 2 January 2013. It addresses the same substances as the original directive while improving regulatory conditions and legal clarity. It requires periodic re-evaluations that facilitate gradual broadening of its requirements to cover additional electronic and electrical equipment, cables and spare parts. The CE logo now indicates compliance and RoHS 2 declaration of conformity is now detailed (see below). In 2012, a final report from the European Commission revealed that some EU Member States considered all toys under the scope of the primary RoHS 1 Directive 2002/95/EC, irrespective of whether their primary or secondary functions were using electric currents or electromagnetic fields. From the implementation of RoHS 2 or RoHS Recast Directive 2011/65/EU on, all the concerned Member States will have to comply with the new regulation. The key difference in the recast is that it is now necessary to demonstrate conformity in a similar way to the LVD and EMC directives. Not being able to show compliance in sufficiently detailed files, and not ensuring it is implemented in production is now a criminal offence. Like the other CE marking directives it mandates production control and traceability to the technical files. It describes two methods of achieving presumption of conformity (Directive 2011/65/EU Article 16.2), either technical files should include test data for all materials or a standard accepted in the official journal for the directive, is used. Currently the only standard is EN IEC 63000:2018 (based on IEC 63000:2016 superseded EN 50581:2012), a risk based method to reduce the amount of test data required (Harmonised Standards list for RoHS2, OJEU C363/6). One of the consequences of the requirement to demonstrate conformity is the requirement to know the exemption use of each component, otherwise it is not possible to know compliance when the product is placed on the market, the only point in time the product must be 'compliant'. Many do not understand that 'compliance' varies depending on what exemptions are in force and it is quite possible to make a non-compliant product with 'compliant' components. Compliance must be calculated on the day of placing on the market. In reality this means knowing the exemption status of all components and using up stock of old status parts before the expire date of the exemptions (Directive 2011/65/EU Article 7.b referring to Decision 768/2008/EC Module A Internal production control). Not having a system to manage this could be seen as a lack of diligence and a criminal prosecution could occur (UK Instrument 2012 N. 3032 section 39 Penalties). RoHS 2 also has a more dynamic approach to exemptions, creating an automatic expiration if exemptions are not renewed by requests from industry. Additionally new substances can be added to the controlled list, with 4 new substances expected to be controlled by 2019. All these mean greater information control and update systems are required. Other differences include new responsibilities for importers and distributors and markings to improve traceability to the technical files. These are part of the NLF for directives and make the supply chain a more active part of the policing (Directive 2011/65/EU Articles 7, 9, 10). There has been a recent additional amendment 2017/2102 to 2011/65 ==Scope exclusions== With the recast of the original RoHS (I) Directive (2002/95/EC), the scope of the directive was decoupled from the scope of the WEEE Directive and an open scope was introduced. The RoHS (II) Directive (2011/65/EU) was applicable to all electrical and electronic equipment. Scope limitations and exclusions were specifically introduced in Article 2(4) a) – j) of the recast Directive. All other EEE was in scope of the Directive, unless specific exemptions have been granted through Commission delegated acts (see next paragraph). The scope exclusions are listed below This Directive does not apply to: equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes; equipment designed to be sent into space; equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment; large-scale stationary industrial tools; large-scale fixed installations; means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved; non-road mobile machinery made available exclusively for professional use; active implantable medical devices; photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications; equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis. ==Restriction exemptions== There are over 80 exemptions, some of which are quite broad. Exemptions will automatically expire after 5 or 7 years unless renewed. According to Hewlett-Packard: "The European Union is gradually narrowing the scope of and expiring many of the current RoHS exemptions. In addition, it is likely that new substance restrictions will be introduced in the next several years." Some exemptions: Lead as an alloying element in steel containing up to 0.35% lead by weight, aluminium containing up to 0.4% lead by weight, and copper alloy containing up to 4% lead by weight is permitted. (Category 6c) Lead in high melting temperature type solders (i.e. lead-based solder alloys containing 85% or more lead by weight). (Category 7a) "Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, transmission, and network management for telecommunications." (Category 7b) Limited amounts of mercury in fluorescent and other light bulbs where it is essential to their functioning comprise RoHS 2 Categories 1, 2, 3, and 4 Medical devices were exempt in the original directive. RoHS 2 narrowed the exemption's scope to active implantable medical devices only (Category 4h). In vitro diagnostic devices (IVDD) and other medical devices are now included. Automotive vehicles are exempt (Category 4f). Vehicles instead are addressed in the End of Life Vehicles Directive (Directive 2000/53/EC). ==Future possible additions== New substance restrictions being considered for introduction in the next few years include phthalates, brominated flame retardants (BFRs), chlorinated flame retardants (CFRs), and PVC. ==Other regions== ===Asia / Pacific=== China Order No. 39: Final Measures for the Administration of the Control and Electronic Information Products (often referred to as China RoHS ) has the stated intent to establish similar restrictions, but in fact takes a very different approach. Unlike EU RoHS, where products in specified categories are included unless specifically excluded, there will be a list of included products, known as the catalogue – see Article 18 of the regulation – which will be a subset of the total scope of Electronic Information Products, or EIPs, to which the regulations apply. Initially, products that fall under the covered scope must provide markings and disclosure as to the presence of certain substances, while the substances themselves are not (yet) prohibited. There are some products that are EIPs, which are not in scope for EU RoHS, e.g. radar systems, semiconductor-manufacturing equipment, photomasks, etc. The list of EIPs is available in Chinese and English. The marking and disclosure aspects of the regulation were intended to take effect on 1 July 2006, but were postponed twice to 1 March 2007. There is no timeline for the catalogue yet. Japan: Japan does not have any direct legislation dealing with the RoHS substances, but its recycling laws have spurred Japanese manufacturers to move to a lead-free process in accordance with RoHS guidelines. A ministerial ordinance Japanese industrial standard for Marking of Specific Chemical Substances (J-MOSS), effective from 1 July 2006, directs that some electronic products exceeding a specified amount of the nominated toxic substances must carry a warning label. South Korea: South Korea promulgated the Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles on 2 April 2007. This regulation has aspects of RoHS, WEEE, and ELV. ===United States=== The Consumer Product Safety Act was enacted in 1972 followed by the Consumer Product Safety Improvement Act in 2008. California has passed the Electronic Waste Recycling Act of 2003 (EWRA). This law prohibits the sale of electronic devices after 1 January 2007, that are prohibited from being sold under the EU RoHS directive, but across a much narrower scope that includes LCDs, CRTs, and the like and only covers the four heavy metals restricted by RoHS. EWRA also has a restricted material disclosure requirement. Effective 1 January 2010, the California Lighting Efficiency and Toxics Reduction Act applies RoHS to general purpose lights, i.e. "lamps, bulbs, tubes, or other electric devices that provide functional illumination for indoor residential, indoor commercial, and outdoor use." ===Ireland=== Worldwide standards and certification are available under the QC 080000 standard, governed by the National Standards Authority of Ireland, to ensure the control of hazardous substances in industrial applications. ===Sweden=== In 2012 Sweden's Chemicals Agency (Kemi) and Electrical Safety Authority tested 63 consumer electronics products and found that 12 were out of compliance. Kemi claims that this is similar to testing results from prior years. "Eleven products contained prohibited levels of lead, and one of polybrominated diphenyl ether flame retardants. Details of seven companies have been passed to Swedish prosecutors. Kemi says that levels of non-compliance with RoHS are similar to previous years, and remain too high." ===Health benefits=== RoHS helps reduce damage to people and the environment in third-world countries where much of today's "high-tech waste" ends up. The use of lead-free solders and components reduces risks to electronics industry workers in prototype and manufacturing operations. Contact with solder paste no longer represents the same health hazard as it used to. ===Reliability concerns unfounded=== Contrary to the predictions of widespread component failure and reduced reliability, RoHS's first anniversary (July 2007) passed with little fanfare. Most contemporary consumer electronics are RoHS compliant. As of 2013, millions of compliant products are in use worldwide. Many electronics companies keep "RoHS status" pages on their corporate websites. For example, the AMD website states: Although lead containing solder cannot be completely eliminated from all applications today, AMD engineers have developed effective technical solutions to reduce lead content in microprocessors and chipsets to ensure RoHS compliance while minimizing costs and maintaining product features. There is no change to fit, functional, electrical or performance specifications. Quality and reliability standards for RoHS compliant products are expected to be identical compared to current packages. RoHS printed circuit board finishing technologies are surpassing traditional formulations in fabrication thermal shock, solder paste printability, contact resistance, and aluminium wire bonding performance and nearing their performance in other attributes. The properties of lead-free solder, such as its high temperature resilience, has been used to prevent failures under harsh field conditions. These conditions include operating temperatures with test cycles in the range of −40 °C to +150 °C with severe vibration and shock requirements. Automobile manufacturers are turning to RoHS solutions now as electronics move into the engine bay. ===Flow properties and assembly=== One of the major differences between lead-containing and lead-free solder pastes is the "flow" of the solder in its liquid state. Lead-containing solder has a lower surface tension, and tends to move slightly to attach itself to exposed metal surfaces that touch any part of the liquid solder. Lead-free solder conversely tends to stay in place where it is in its liquid state, and attaches itself to exposed metal surfaces only where the liquid solder touches it. This lack of "flow" – while typically seen as a disadvantage because it can lead to lower quality electrical connections – can be used to place components more tightly than they used to be placed due to the properties of lead-containing solders. For example, Motorola reports that their new RoHS wireless device assembly techniques are "...enabling a smaller, thinner, lighter unit." Their Motorola Q phone would not have been possible without the new solder. The lead-free solder allows for tighter pad spacing. ===Some exempt products achieve compliance=== Research into new alloys and technologies is allowing companies to release RoHS products that are currently exempt from compliance, e.g. computer servers. IBM has announced a RoHS solution for high lead solder joints once thought to remain a permanent exemption. The lead-free packaging technology "...offers economical advantages in relation to traditional bumping processes, such as solder waste reduction, use of bulk alloys, quicker time-to-market for products and a much lower chemical usage rate." Test and measurement vendors, such as National Instruments, have also started to produce RoHS-compliant products, despite devices in this category being exempt from the RoHS directive. ==References== ==Further reading== ==External links== RoHS Compliance in the EU – www.rohs.eu Official United Kingdom site on RoHS EU RoHS Enforcement Guidance Document, V.1; EU RoHS Enforcement Authorities Informal Network; May 2006 Properties of Lead-Free Solders National Institute of Standards and Technology Support of Industry Compliance with the EU Directive on Restriction of Certain Hazardous Substances (RoHS) on nist.gov Case study on RoHS2 compliance

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