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Restriction of Hazardous Substances EU Directive

27 October 2006
by eub2 -- last modified 27 October 2006

RoHS is the acronym for Restriction of Hazardous Substances, the European Union (EU) directive (Directive 2002/95/EC) which bans new electrical and electronic equipment from being placed on the EU market if they contain more than agreed levels of certain hazardous substances.


What is RoHS?

The objective of the EU Restriction of Hazardous Substances Directive is to provide incentives for designing electrical and electronic equipment in an environmentally more efficient way, which takes waste management aspects fully into account.

Who exactly does RoHS effect?

The RoHS directive applies to any manufacturer of electrical and electronic equipment (EEE) to be released on the EU market. This applies to manufacturers inside the EU member states and manufacturers outside of Europe wishing to export their products to the EU market.

Article 3.a – Definitions

“’electrical and electronic equipment’ or ‘EEE’ means equipment which is dependent on electrical currents or electro magnetic fields in order to work properly and equipment for the generation, transfer or measurement of such currents and fields set out in the Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current…”

Article 3.b – Definitions

“’producer’ means any person who, irrespective of the selling technique used, including by means of distance communication according to Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997 on the protection of consumers in respect of distance contracts:

  • manufactures and sells electrical and electronic equipment under his own brand;
  • resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the ‘producer’ if the brand of the producer appears on the equipment, as provided for in subpoint (i); or
  • imports or exports electrical and electronic equipment on a professional basis into a Member State.”

    When did the directive take effect?

    The RoHS directive came into force on 1st July 2006, to which all end products sold on the European market must comply.

    What are the restricted substances in the directive, and what are their accepted levels?

    Directive 2002/95/EC restricts the use of six homogenous materials. Of these four are heavy metals (lead, mecury, cadmium, and hexavalent chromium) and two are brominated flame retardants (polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE)).

    Article 4.1 of the RoHS Directive specifically states:
    “Member States shall ensure that, from 1st July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). National measures restricting or prohibiting the use of these substances in electrical and electronic equipment which were adopted in line with Community legislation before the adoption of this Directive may be maintained until 1 July 2006.”

    Although net yet officially finalized, expected Maximum Concentration Values (MCV) set for each homogenous material are given below:

    Material MCV
    Lead 0.1%
    Mercury 0.1%
    Cadmium 0.01%
    Hexavalent Chromium 0.1%
    Polybrominated Biphenyl (PBB) 0.1%
    Polybrominated Diphenyl Ether (PBDE) 0.1%

    What products are affected by this directive?

    Electrical and electronic equipment belonging to one of the eight product categories listed below, and placed on the market after 1st July 2006.

    Small Household Equipment Large Household Equipment
    IT & Telecoms Equipment Consumer Equipment
    Lighting Equipment Electrical & Electronic Tools
    Toys, leisure & Sports Equipment Automatic Dispensers

    A number of exemptions have been made to the RoHS Directive, granted solely on technical grounds. These include large-scale industry tools, spare parts used for the repair, capacity expansion or upgrade of electronic or electrical equipment (EEE) put on the market before 1st July 2006 and the re-use of EEE placed on the market before 1st July 2006. Furthermore certain exemptions have been made for each of the six restricted elements. These are detailed below:
    Lead: HMP, glass for CRTs, components and fluorescent tubes, electronic ceramic parts, steel alloys (<0.35%) aluminium alloys (<0.4%) and copper alloys (<4%).
    Mercury: Lamps (within specific limits)
    Cadmium: Certain electrical contacts
    Hexavalent Chromium: may be used on non-EEE components (eg. Screws, fittings, etc.)
    PBB and PBDE: none

    What does “placed on the market” actually mean?

    The definition proposed by the European Commission is that a “product is placed on the Community market when it is made available for the first time. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution or use on the community market.” It is important to note however that the phrase “for the first time” does not imply that the product is new, for example used products traded outside the EU may still enter the market for the first time and be subject to RoHS compliance. The term transferred is also key for clarifying that no financial transfer is necessary for a product being placed on the European market to be subject to RoHS compliance, for example donations or sample prototypes are not exempt.

    What is the definition of the “market” for which this directive applies?

    EU directives apply to not only the European single market, but also the European Economic Area (EEA), which includes Iceland, Norway and Lichtenstein. All EEE products entering the ‘market’ within the scope of these regions would therefore require RoHS compliance.

    What is a homogenous material?

    A homogenous material is a material of uniform composition throughout that cannot be mechanically disjointed into different substances, for example through mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. A simple electronic cable can be used to highlight the definition of a homogenous material. The example cable may be composed of several elements, such as the tinned copper conductors, a foil shield and PVC jacket. The cable is not homogenous as it can be mechanically broken down into these different components, however the conductors, which may be comprised of an alloy of several elements, cannot be mechanically separated into these elements, therefore is considered homogenous. The same principle applies to the foil shield and PVC coating, therefore each of these homogenous materials must comply individually with RoHS directive requirements.

    Is there a special Mark or stamp that must be used to identify RoHS compliant products?

    No. All products entering the market after July 1st 2006 will be considered to be declared as compliant.

    How can I obtain a copy of the documentation of the RoHS directive?

    RoHS directive (pdf)