The New RoHS 2 Directive and its Challenges for E&E Toys

On January 2, 2013, the new RoHS 2 directive 2011/65/EU will come into force. For products that only now fall within the scope of RoHS 2, the regulation comes into force on July 22, 2019.
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Oct. 10, 2012 - PRLog -- What does this mean for toys?

The regulation applies to electrical and electronic equipment (EEE) that is defined as follows:
‘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;

Essential is the new definition of ‘dependent’ (art 3.2 in RoHS 2):
‘Dependent‘ means, with regard to EEE, needing electric currents or electromagnetic fields to fulfill at least one intended function. At least one intended function means that even if the electric function is only a minor/secondary element of the equipment, the definition still applies. The RoHS 2 guidance provides a singing teddy bear as an example of a product with minor E&E functions.

In the former directive 2002/95/EC, toys with minor/secondary E&E functions - like the example of the singing teddy bear - were not within the scope of RoHSas explained in a RoHS 1 FAQ document by the European Commission. The functionality was regarded minor/secondary as the bear still had a play value without the E&E functionality.

The scope of the RoHS 2 directive has been modified to include all toys with an E&E function.
According to RoHS 2 all toys with an additional function needing electricity will eventually need to comply with the RoHS 2 directive. This includes both toys with major/primary and minor/secondary functionalities.

Moreover, RoHS 2 introduces the requirements of an EU Declaration of Conformity and CE mark labeling. Consequently the RoHS requirements need to be considered by manufacturers when compiling the technical documentation for E&E toys.

The implementation dates for the different types of toys vary as follows:
•   E&E toys with minor/secondary functions have not been in scope of the 2002/95/EC directive. Due to this they have to be compliant to RoHS substance restrictions by July 22, 2019, as they are defined as new in the scope of RoHS 2 2011/65/EU under category 7.
•   All other EE toys need to be compliant to RoHS substance restrictions by January 2, 2013, as they have been in the scope of RoHS 2002/95/EC, category 7.

For more details, the full text of the directive 2011/65/EU can be consulted at the European Commission website ( The attached picture depicts an incomplete list of examples of E&E toys with minor/secondary functions that need to comply with RoHS 2 by July 22, 2019.

About SGS RoHS Solutions
As the world’s leader in third party testing, SGS has established procedures to cover a large variety of legal requirements related to consumer products. The global footprint of SGS will provide solutions all over the world. The SGS experts support manufacturers in product compliance with RoHS ( and many more consumer product related requirements.

Please don’t hesitate to contact the SGS experts if you need further information about RoHS compliance.

Contact details:

SGS Consumer Testing Services

Sanda Stefanovic
Senior Toy Expert
SGS Nederland BV
Malledijk 18, PO Box 200
3200 AE Spijkenisse
The Netherlands

t: +31 181 694517

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With 70,000 employees, SGS operates a network of over 1,350 offices and laboratories around the world.
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