RoHS 2: The Directive Continues to Evolve

The "recast" RoHS Directive 2011/65/EU came into force on 3 January 2013, replacing the former RoHS Directive, 2002/95/EC. Many major changes have been enacted, including

  • Expanded scope
    • Medical devices and monitoring and control instruments came into scope 22 July 2014
    • In vitro medical devices came into scope as of 22 July 2016
    • Industrial monitoring and control instruments came into scope as of 22 July 2017
    • Other electrical and electronic equipment (EEE) not covered by any of the existing 10 product categories come into scope as of 22 July 2019

  • Broader definitions
    • Electrical and electronic equipment, or EEE, means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current.
    • "Dependent" means, with regard to EEE, needing electric currents or electromagnetic fields to fulfill at least one intended function.
      • A greeting card that plays a tune or a toy teddy bear that talks would now be in scope of the directive

  • More Substances
    • Delegated Directive 2015/863 adds four phthalates to the list of restricted substances in Annex II of RoHS as of July 22, 2019 for most product categories:
      • Bis(2-ethylhexyl) phthalate (DEHP)
      • Butyl benzyl phthalate (BBP)
      • Dibutyl phthalate (DBP)
      • Diisobutyl phthalate (DIBP)
    • Sweden would like to add Medium Chain Chlorinated Paraffins (MCCPs)
    • Denmark would like to add small linear and branched brominated alkyl alcohols (SBAAs)

  • Increased documentation requirements
    • Formal Declaration of Compliance - declare it
    • Conformity assessment and Technical Documentation, on file and available to enforcement agents for 10 years - prove it
    • CE marking to signify RoHS compliance required - show it

  • And More!!
    • We remain under RoHS 2; this is NOT "RoHS 3". Read Mike Kirschner's recent article on RoHS terminology in Compliance & Risks' August 2017 Quarterly Newsletter!
    • Look for more clarity on the RoHS scope soon
    • There are other RoHSes! They can and do have different requirements. Make no assumptions about regulatory requirements in other markets. Read this article for examples of when "RoHS" is not "RoHS".

What can DCA Do for You?

Work with someone who actually understands RoHS. DCA can help you learn about and manage the impact of these, and other, EU Directives and regulations as well as national and international market regulations and customer requirements, and plan your transition to compliance. From assessing your suppliers' RoHS compliance capabilities, to updating key design and procurement supplier and component-related business processes, to identifying and working with you to configure a systems solution that tracks material composition, to identifying and resolving potential and actual technical back-end risks, we can do it all. Please contact us for more information.