Beginning July 1st, 2006, EU Directive 2002/95/EC, known as " Restriction of Hazardous Substances (ROHS)," will forbid after July 1st, 2006 the importation of any electrical and/or electronic equipment of six hazardous substances into the European Union. These substances include materials containing more than 100 parts per million (ppm) of cadmium (Cd), or more than 1000 ppm each of mercury (Hg), lead (Pb), hexavalent chromium (Cr+6), polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs).

The term ROHS compliant has often been referred to as “lead-free” because lead is one the most prominent elements in the directive. It is important to understand that “lead-free” does not necessarily mean ROHS. A device may be free of lead but may contain the other five elements that are not compliant per the directive. China, Japan, Canada, and individual states within the US also have studies and plan to pass similar legislation to the EU’s Directive.

From a ROHS perspective, it is the responsibility of the producer to prove that the six substances restricted by the directive are not present in the components, or homogeneous elements of the equipment you produce. Within the ROHS articles, a ‘producer’ is defined as:

  • Any manufacturer that sells electrical and electronic equipment under its’ 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 documented in the above point, or
  • Imports or exports electrical and electronic equipment on a professional basis into a Member State.

Also, there is no ‘grandfather’ clause within the legislation. That is, there is no distinction between new products or legacy devices. The legislation states that it is the act of when a product is placed on the market that determines a need for conformity.

What does this mean to you and your company? Any components, assemblies, or subassemblies must be verified and documented to be free of these materials to protect your company from violating the directive. This also applies to electronic component suppliers and/or manufacturers who are shipping material into the EU States. To date, there has been no standardized component marking identifying which material is ROHS compliant, and to add to the confusion, many manufacturers haven’t even changed their part numbers to differentiate compliant parts vs. non-compliant items.

ECR electronics has a solution to the address the issue and ensure that your material is ROHS compliant.


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