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RoHS – Restriction of Hazardous Substances Directive Directive 2002/95/EC. RoHS Overview. Seeks to reduce the environmental impact of Electrical and Electronic Equipment (EEE). Came into force July 1, 2006
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RoHS – Restriction of Hazardous Substances Directive Directive 2002/95/EC www.productsafetyinc.com
RoHS Overview • Seeks to reduce the environmental impact of Electrical and Electronic Equipment (EEE). • Came into force July 1, 2006 • Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated Biphenyls (PBB) and Polybrominated Diphenyl Ethers (PBDE) www.productsafetyinc.com
RoHS Overview • Lead – Solders, termination coatings, paints, pigment, PVC stabilizer, batteries • Cadmium – Coatings, solders, semiconductors, contacts, PVC stabilizers, pigments • Mercury – Fluorescent lamps, batteries, sensors, relays www.productsafetyinc.com
RoHS Overview • Hexavalent Chromium – Coatings to prevent corrosion (on zinc, aluminum or in paints). • PBB – Flame retardant in certain plastics (no longer produced) • PBDE – Flame retardant in certain plastics www.productsafetyinc.com
RoHS Overview • Exemptions = • Lead • Higher melting point solders with >85% Pb • Glass (CRTs, Fluorescent Lamps, Electronic Components) • Ceramic devices (i.e.; piezoelectric) • In certain alloys, limited concentrations • See Annex of the RoHS Directive (Attached) • Whereas: (11) – paraphrased as - Exemptions should be permitted if substitution is not possible from the scientific and technical point of view or if the substitution worsens the environmental impact. www.productsafetyinc.com
RoHS Overview • High Risk items = • PVC • Red, Orange and Yellow plastics • Components supplied soon after Supplier has changed to “lead free” but with same part number. • ABS Plastic with octa-BDE Flame Retardant • Polyurethane foam • Galvanized steel (especially if yellow) www.productsafetyinc.com
RoHS Overview • Equipment within the scope of RoHS: • Large Household Appliances • Small Household Appliances • IT, Telecom • Consumer Equipment • Lighting Equipment (except filament lamps and household luminaries) www.productsafetyinc.com
RoHS Overview • Equipment within the scope of RoHS: • Electrical tools (except large-scale stationary industrial tools) • Toys, leisure and sport • Automatic Dispensers www.productsafetyinc.com
RoHS Overview • Exempt Equipment: • Medical Devices (except implanted and infected products) • Monitoring and Control Instrumentation • Military and National Security Products www.productsafetyinc.com
RoHS Overview • Responsibility is on the “Producer” • Producer = the company that manufacturers and sells the product under its brand name. The Importer of record can be designated as the “Producer”, but whoever’s name in on the product will ultimately be responsible. www.productsafetyinc.com
RoHS Overview • New Approach Directive = • When placing product on market it’s presumed to comply with the Directive • Enforcement is done by market surveillance • No CE Mark www.productsafetyinc.com
RoHS Overview • The Directive is Vague - • Does not specify concentration limits (UK has defined limits) • How Producers comply = Due Diligence with No Standards • Requirements for market surveillance are not defined • Various Countries have different interpretations and additional/different requirements www.productsafetyinc.com
RoHS Overview • Due Diligence = • Obtain Declarations from Suppliers • Depending on product and risk of supplier not providing compliant component: • Supplier Audits • Incoming Inspections • Testing www.productsafetyinc.com
RoHS Overview • What’s at Stake? • Prove Due Diligence • Article 8 – Member States shall determine penalties applicable to breaches of the national provisions adopted pursuant to this Directive. The penalties thus provided for shall be effective, proportionate and dissuasive. www.productsafetyinc.com
RoHS Overview • Other Directives: • WEEE – Waste of Electrical and Electronic Equipment Directive • EuP – Energy Using Products, August, 2005 • Battery Recycling Directive, January, 2008 • China, Japan, California (Proposition 65), other US states www.productsafetyinc.com
Links • www.productsafetyinc.com • www.safetylink.com • www.osha-slc.gov/dts/otpca/nrtl/index.html • www.iecee.org/cbscheme/html/cbstand.htm • www.europa.eu.int/index_en.htm • www.ul.com • www.cpsc.gov • http://en.wikipedia.org/wiki/RoHS#North_America www.productsafetyinc.com