Selected examples of major changes in the new directive include:
- RoHS is now a CE marking directive.
- Expanded Product Scope by phasing out permanent exemptions for medical devices, monitoring and control equipment as well as a new “open scope” category including other electrical and electronic equipment not covered by any of the other 10 categories.
- Maximum Validity period of exemptions for categories 1 to 7, 10, and 11 is up to 5 years and maximum validity period of exemptions for categories 8 and 9 is up to 7 years.
- New “obligations”
- Manufacturers or their “authorized representative”
One of the key changes here is the more stringent requirement for traceability of compliance documentation and retention of that data. The difficulty of this is that the RoHS directive requires this information for each homogenous material of the product. This requires a deep understanding and monitoring of the materials and chemicals being used throughout the supply chain. For companies who now need to check if their products are compliant to the RoHS Directive, there is more guidance and experience in the marketplace to follow including the revised IEC 62321 standard for sampling and testing products for RoHS and the harmonized EN 50581 standard for technical documentation.
Revised IEC 62321 Standard
The IEC 62321 standard, which has been revised as of May 2013, provides some general guidance on:
- Appropriate sampling strategy for testing product materials,
- Detailed disassembly procedures and examples,
- Improved sample preparation,
- XRF screening methods and “wet” chemical testing methods.
Also, IEC 62321-2 Annex B includes a list of components and the likelihood that these common components would contain the RoHS substances. The testing strategy would need to be tailored depending on the company’s final product whether it is a raw material, component, subassembly, or final product.
Harmonized EN 50581Standard
The harmonized EN 50581 standard provides more detailed information about what the expectations are for technical documentation required under RoHS II as a consequence of the CE mark.
EN 50581 covers the following aspects: content and traceability of the technical documentation, supplier and material confidence assessments (also covered in EN 62321), collection of technical documentation and evaluation of documentation for quality and trustworthiness including whether or not test reports follow IEC 62321 methods.
Information about the chemical content of components is more available than it ever was and there are methods and tools to support the collection and retention of this information that are cost effective and prevent unnecessary testing of materials and components.
RoHS II compliance strategies could include any combination of the following:
- Utilizing software to manage material information from suppliers.
- Continuous supplier training programs.
- Conducting risk assessments on suppliers and materials.
- Test where necessary per a “Smart” testing strategy.
- Implementation of a data monitoring program.
- Implementation of a supplier monitoring program.
If you are wondering what happened to WEEE, it is still around! The RoHS directive has been separated from the WEEE Directive. The WEEE Directive has also been revised.
WEEE II Directive 2012/19/EU will have a major impact on manufacturers and importers, and will require them to: register the products with respective organizations in EU Member States and provide required information;
Other countries outside the EU, are also adopting “RoHS – like” requirements. It is important to follow these legislations as well as other chemical requirements that have an impact on EEE products such as REACH (http://www.sgs.com/
About SGS Electrical and Electronics Services
SGS is committed to keeping you up to date on the latest regulations and policies concerning the use of hazardous substances in consumer products. Furthermore, through a global expertise and network of chemical labs, SGS can support you in ensuring your products comply with relevant hazardous substances or RoHS requirements (http://www.sgs.com/
Whether you are in need of hazardous substances testing or other third party verification, certification or inspection services, SGS is ideally positioned to satisfy all your business's needs.
For further information, please contact an SGS expert.
SGS Consumer Testing Services
Business Unit Manager
International Electronics & EE Chemicals
SGS North America, Inc.
t: +1 973 461 7906
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 75 000 employees, SGS operates a network of over 1 500 offices and laboratories around the world.