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RoHS 2 (Restriction of Hazardous Substances 2) is a European Union (EU) directive 2011/65/EU which restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). The restricted hazardous substances listed in the RoHS 2 include lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers. The purpose/objective of the directive is to protect the environment and public health from the impacts of electronics and their waste.
The RoHS 2 directive replaced the first EU RoHS directive 2002/95/EC (RoHS 1) and came into effect on 21 July 2011. Similar to RoHS 1, RoHS 2 restricts the use of six hazardous materials mentioned above. But, as compared to RoHS 1, the RoHS 2 directive covers a broader range of equipment and imposes additional obligations on electronic and electrical equipment manufacturers and importers. These obligations include affixing CE markings on finished products to show compliance as well as producing technical documentation to demonstrate conformity. The product manufacturers must comply with RoHS 2 before they use the CE mark on their products.
The RoHS 2 directive applies to all electrical and electronic products manufacturers, authorized representatives, importers, and distributors aiming to import these products or conduct business within the EU. This directive applies to product categories, including large household appliances, small household appliances, computing and communications equipment, consumer electronics, lighting, power tools, toys and sports equipment, and automatic dispensers. This directive also added Categories 8 and 9 for medical devices, monitoring, and control instruments and set different compliance deadlines for each category.
Labelling and CE marking regulations:
RoHS 2 requires that electrical & electronics product manufacturers carry out compliance checks, prepare the declaration documentation, and affix CЄ markings on their finished products to show they are compliant. The format for the conformity declaration is given in Annex VI of the RoHS 2 directive. Note that by adding the CЄ marking, you are signaling that it’s RoHS compliant. It is a criminal offense to affix a CЄ mark to a product that is not compliant with the RoHS directive.
RoHS is closely related to WEEE
RoHS is closely related to the Waste Electrical and Electronic Equipment Directive (WEEE) Directive 2012/19/EU. The WEEE directive sets collection, recycling, and recovery targets for electrical and electronic goods. For electronic and electrical products placed on the EU market, we can usually see the following two signs on them. The first symbol is the CE mark which represents compliance with RoHS and other EU directives. The second symbol represents the WEEE recycling symbol.
RoHS 2 Exemptions List
It isn’t technically feasible to manufacture some products without the use of RoHS 2 restricted substances. Hence, the European Commission grants time-limited exemptions for certain products until science formulates a safer alternative.
Some notable exemptions include
Note: In the EU, The RoHS 2 directive does not apply to Batteries and package materials since they are subject to different directives. However, for other countries, this might not be true. More information regarding batteries and packaging materials restrictions can see here.
RoHS 2 Vs RoHS 3
On March 31, 2015, a new directive RoHS 3 was born, known as Directive 2015/863. On 22 July 22, 2019, this directive/regulation went into effect and is an amendment to RoHS 2.
RoHS 3 added four additional restricted substances to the original list of six hazardous materials mentioned above. These four substances are all phthalates; they are Bis(2-Ethylhexyl) phthalate (DEHP), Dibutyl phthalate (DPB), Benzyl butyl phthalate (BBP), and Diisobutyl phthalate (DIBP). The RoHS 3 also adds a new product category “Category 11”, which includes 2-wheeled electric vehicles, vape pens, e-cigarettes, and other items. Failure to comply with the RoHS 3 directive will lead to huge fines and legal consequences.
The restricted substance list in the RoHS 3 directive and their limits are as follows. A limit of 0.1% refers to 1,000 ppm (parts per million):
RoHS 3 Substances List (Total 10):
How to Get Certified for RoHS Compliance?
Manufacturers, distributors, or Organizations can prove their RoHS compliance with a DoC (Declaration of Conformity). The DoC is a self-declaration that the organization meets all the requirements of RoHS. By claiming the declaration, the organization/company assumes all responsibility for compliance with the regulations. The DoC must include identifying information about the organization and the product and must be signed by one of the responsible employees of that organization.
Aside from that, there are third-party companies that can be hired to conduct tests for the company’s products to ensure compliance with regulations. The test will be conducted in a laboratory, and the product will be tested to verify levels of the ten restricted hazardous chemicals. The test results are fully documented in a certified test report so that the organization can demonstrate that its product is compliant with the RoHS directive. The product that passes the test/meets the requirements of RoHS will be considered a RoHS compliance product.
Summary
RoHS stands for Restriction of Hazardous Substances, is a directive that originated in the European Union. The RoHS restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). This directive is applicable to EEE manufacturers and product importers within the EU market. The aim of the directive is to reduce the environmental effect and health impacts of electronics.
The first RoHS directive (RoHS 1), also known as Directive 2002/95/EC, was published in 2002. This directive restricted the use of the first six hazardous substances mentioned earlier. According to this directive, all applicable electrical and electronic products sold in the EU market after July 1, 2006 must pass RoHS compliance.
The RoHS 2 directive (2011/65/EU) replaced RoHS 1 and came into effect on 21 July 2011. Like RoHS 1, this directive also restricts the use of the first six hazardous substances mentioned earlier. Also, the RoHS 2 directive expanded the scope of products covered, and imposes new obligations on EEE manufacturers to prepare EU declaration of conformity and affix CE markings on finished products. This directive also added Categories 8 and 9 for medical devices, monitoring, and control instruments and set different compliance deadlines for each category.
On March 31, 2015, a new directive RoHS 3 was born, known as Directive 2015/863. This directive is the amendment to RoHS 2. It restricts the use of the 10 hazardous substances mentioned earlier and also adds “Category 11” products. The RoHS 3 compliant products/items have been tested for the 10 restricted hazardous substances by an independent authority and are verified to fall within the acceptable limits. The product that passes the test/meets the requirements of RoHS will be considered a RoHS compliance product.
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