If you’ve ever looked at the packaging for an electronic device or other product, you may have seen the text “RoHS compliant” inside a circle, usually with a check mark above it.
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This marking signifies that a device is compliant with the RoHS Directive, or the Restriction of Hazardous Substances Directive. The RoHS Directive is a set of European Union regulations that restrict the use of hazardous substances in electrical and electronic devices.
Below, we’ve explained more about how the RoHS Directive works, as well as what it means when a product has the RoHS compliant text and mark on its packaging.
We’ve also discussed the steps you can take to achieve RoHS compliance for your device if you’re planning to sell your product in the European Economic Area (EEA).
The RoHS Directive is a set of regulations published by the European Union. The regulations set limits on the use of hazardous substances in electrical and electronic devices.
The first RoHS Directive, Directive /95/EC, entered into force in and set restrictions on the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl esters (PBDE) in electronic devices and equipment.
In , the regulations were updated as Directive /65/EU. In , the regulations were further updated, with four other substances — bis(2-ethylhexyl) phthalate (DEPH), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP) — also restricted.
Under EU RoHS regulations, these substances are only allowed in electronic equipment when they fall below the maximum concentration, defined as parts per million (ppm).
The RoHS Directive applies to a broad range of electronic devices, including:
The term “RoHS compliant” means that a device meets all of the requirements set under the RoHS Directive and complies with the regulation. In order to comply with RoHS, your device needs to undergo testing and provide documentation demonstrating its compliance.
Complying with RoHS is a multi-step process that begins with assessing your supply chain, product design and other factors, then completing lab testing for your device to verify that it doesn’t contain excessive levels of hazardous substances.
It’s also important to maintain compliance through continual monitoring and improvement of devices subject to the RoHS Directive, as well as employee training and awareness.
As specialists in product testing and regulatory compliance, we can help you understand the RoHS Directive requirements and complete testing to ensure your device complies with all of the necessary standards to go on sale in the EU.
We can also complete testing and documentation to ensure your device complies with other regulations, including FCC requirements for sale in the United States.
F2 Labs assists many manufacturers, internationally, with CE marking requirements. Regarding CE marking, primarily we test and evaluate electro-mechanical equipment for compliance with electrical safety, machinery safety, EMC and radio, medical device, and hazardous location requirements.
However, when a manufacturer completes a compliance project for Europe and places a CE marking on the equipment, that CE marking is an overt claim of compliance with the RoHS Directive /65/EU: intentional or not. This is because the CE marking on a product is a claim of compliance to any CE marking Directive that is applicable.
In other words: if your product is in the scope of RoHS then putting a CE marking on the product is a claim that it complies with the RoHS substance restrictions… for every component in and on your equipment. Including the paint and labels.
It is very common for our customers to assume that RoHS does not apply to their equipment because it is machinery. This is not a legal reason to ignore RoHS. This article will explain why.
RoHS /65/EU defines equipment within its scope as per below –
Article 2, Scope
See definition of ‘EEE’ in Article 3 (1)
Article 3, Definitions
For the purposes of this Directive, the following definitions shall apply:
(1) ‘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 1 000 volts for alternating current and 1 500 volts for direct current;
See Annex I (6.) and (9.)
ANNEX I, Categories of EEE covered by this Directive
Next, we look to the WEEE Directive /19/EU to see the indicative list of equipment matched to Annex I in RoHS /65/EU. Keep in mind that these lists are indicative, not complete. And, we also highlight that WEEE and RoHS were written as complimentary Directives and refer to each other. (link: RoHS/WEEE).
See WEEE /19/EU, Annex II (6.) and (9.)
MAYA Product Page
Next we refer to two possible exclusions in RoHS /65/EU.
See RoHS /65/EU, Article 2 (4.) (d) and (e):
Article 2, Scope
(d) large-scale stationary industrial tools;
(e) large-scale fixed installations;
Next, see the definitions of each in RoHS /65/EU, Article 3 (3) and (4):
(3) ‘large-scale stationary industrial tools’ means a large-scale assembly of machines, equipment, and/or components, functioning together for a specific application, permanently installed and de-installed by professionals at a given place, and used and maintained by professionals in an industrial manufacturing facility or research and development facility;
(4) ‘large-scale fixed installation’ means a large-scale combination of several types of apparatus and, where applicable, other devices, which are assembled and installed by professionals, intended to be used permanently in a pre-defined and dedicated location, and de-installed by professionals;
Referring next to the EU Commission published RoHS 2 FAQ, if you can not categorize your machinery as meeting ALL of the criteria below then your equipment is not excluded from RoHS.
See Q3.1 –
Q3.1 What are “large-scale stationary industrial tools” and “large-scale fixed installations”? (Articles 2(4)(d) and 2(4)(e)).
Unlike RoHS 1, RoHS 2 has an open scope. However, several product groups are excluded from the RoHS 2 scope.
Two of the exclusions listed in Article 2(4) refer to combinations of EEE in a professional context, i.e. “large-scale stationary industrial tools” (Article 2(4)(d)) and “large-scale fixed installations” (Article 2(4)(e)).
Both terms are explained in the definitions (Articles 3(3) and 3(4)), however it is not explained what “large-scale” means. Both categories are combinations of various types of items, such as machinery, components etc. for permanent use at a specific place, installed and de-installed by professionals. Therefore the two categories may overlap. However, it is important to consider that the meaning of “large-scale” in absolute terms may be a different one for tools and installations, as there are differences between tools and installations.
Tools are essentially machines, stand-alone or assemblies, often with moving parts, and used for example for the treatment or manufacturing of materials and work pieces. The Machinery Directive11 can be used as guidance.
Typical machine tools can also be part of fixed installations.
In order to benefit from either exclusion, the tool or installation must meet all the respective requirements. As stated below, it has to be:
(Tool)
(Installation) – a combination of several types of apparatus and, where applicable, other devices;
“Large-scale” is part of both sets of requirements. Evidently, this draws a line between “larger” tools and installations benefiting from an exclusion, and otherwise similar, “smaller” equipment.
“Large-scale” refers to dimensional or similar criteria as explained below, although this criterion is not specified in the RoHS 2.
The important take-away is this sentence from Q3.1: In order to benefit from either exclusion the tool or installation must meet all the respective requirements.
This means that your equipment must all of the above criteria in order to be excluded from RoHS. With that interpretation (provided by the EU) it is clear that most machinery is in the scope of RoHS, presently.
Additionally, this is added further into Section 3 of the RoHS guidelines:
As regards “large-scale”, this is especially relevant to tools such as stand-alone
industrial machines placed individually on the market. “Large-scale” can be used to
identify and differentiate between tools because of their size, weight, capacity,
throughput or other performance related criteria. It also relates to tool or installation
complexity, and to the effort needed for installing, operating, maintaining and deinstalling a tool or an installation.
One possible way of introducing a direct size criterion relates to transportation. The
following guidance metrics and qualitative criteria can be applied for installations. If the installation exceeds the minimum requirements for one of the following criteria, it can be considered large-scale:
– If, when installing or de-installing the installation, it is too large to be moved in
an ISO 20 foot container because the total sum of its parts as transported is
larger than 5,71m x 2,35m x 2,39m, it can be considered large-scale.
– The maximum weight of many road trucks is 44 tonnes. Thus if, when installing
or de-installing the installation, it is too heavy to be moved by a 44 tonne road
truck, because the total sum of its parts as transported weighs more than the
truck’s load capacity, it can be considered large-scale.
– If heavy-duty cranes are needed for installation or de-installation, the
installation can be considered large-scale.
– An installation that does not fit within a normal industrial environment, without
the environment needing structural modification, can be considered large-scale.
Examples for modifications are modified access areas, strengthened
foundations etc.
– If an installation has a rated power greater than 375 kW, it can be considered
large-scale.
F2 Labs is here to help.
The company is the world’s best RoHS compliant embroidery machine supplier. We are your one-stop shop for all needs. Our staff are highly-specialized and will help you find the product you need.