Controlling Environmentally Hazardous Substances in Electrical & Electronic Products

The European Union (UN)’s Restriction of Hazardous Substances (RoHS) is a well know directive # 2002/95EC that restricts the use of specific hazardous materials or substances contained in electrical & electronic equipment, known as (EEE). RoHS has an impact on electronic industry while manufacturing and distributing locally or worldwide.

This directive is originated in the European Union (EU) in 2002 and is related to environmental conservation activities based on 14001 standards for environmental management, thereby, reducing or eliminating the use of hazardous chemicals, materials, and substances. All applicable products in the EU market must pass the RoHS compliance directive.

The substances that are restricted or banned under the RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four different phthalates (DEHP, BBP, BBP, DIBP).

This directive is effective since July 1st, 2006 and all the applicable products in the EU market must be in compliance with the RoHS.

Directive 2011/65/EU was published in 2011 by the EU, which is known as RoHS-Recast or RoHS 2. RoHS 2 includes a CE-marking directive, with RoHS compliance now being required for CE marking of products. RoHS 2 also added Categories 8 and 9, and has additional compliance record-keeping requirements. Directive 2015/863 is now known as RoHS 3. RoHS 3 adds four additional restricted substances (phthalates) to the list of six. The RoHS 3 deadline is July 22, 2019.

The restricted materials are hazardous to the environment and pollute landfills, and are dangerous in terms of occupational exposure during manufacturing and recycling.

Products Testing for RoHS compliance

Portable RoHS analyzers, also known as X-ray fluorescence or XRF metal analyzers are used for screening and verification of the restricted metals. With the advent of RoHS 3 and the four added phthalates, different testing is needed to ascertain levels of these compounds, which are extracted with a solvent.

Companies Affected by the RoHS Directive

All businesses that sell or distributes applicable EEE products, sub-assemblies, components, or cables directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilize any of the restricted materials. RoHS-like regulations have spread to a number of other countries. RoHS also applies to the metal industry for any application of metal plating, anodizing, chromating or other finishes on EEE components, heat-sinks, or connectors.

The current RoHS 2 is applicable now the Recast RoHS 2 Directive 2011/65/EU, was published in July 2011 by the European Commission (EC).

Now, the scope of the original RoHS was expanded to cover all electrical/electronic equipment, cables, and spare parts with compliance required by July 22, 2019 or sooner depending on product category.
RoHS 3, or Directive 2015/863, adds four additional restricted substances (phthalates) to the original list of six, as cited under REACH legislation. It also adds Category 11 products. RoHS3 takes effect on July 22, 2019.

The seven additional substances being currently assessed are: Beryllium, Cobalt (dichloride and sulphate), Diantimony trioxide, Indium phosphide, Medium-Chain Chlorinated Paraffins (MCCPs), Nickel (sulphate and sulfamate), and Tetrabromobisphenol A (TBBP-A).

Understanding the REACH Regulation & RoHS

REACH is a general regulation and stands for Registration, Evaluation, Authorization, Restriction of Chemicals, and addresses the production and use of chemical substances and their potential impact on human health and the environment.

REACH is monitored by the European Chemical Agency (ECHA) and deals with 197 Substances of Very High Concern (SVHC) currently involved.

RoHS is for EEE products and restricts substances present in electrical/electronic equipment (wiring, components, circuit boards, displays, sub-assemblies, cabling) while the REACH regulations control all chemicals that might be used to manufacture the product, including enclosures, brackets, coatings, paints, solvents, and chemicals used during manufacture. It is noted here that all the RoHS restricted substances are also on the REACH restricted list. Substances on the list have been identified as being carcinogenic, mutagenic, reprotoxic, bio-accumulative and toxic, or as endocrine disruptors (study the REACH Restricted Substances List).

Waste from Electrical and Electronic Equipment (EEE)

WEEE stands for the wastes from Electrical and Electronic Equipment (EEE) under the, Directive # 2002/96/EC, that mandates the treatment, recovery and recycling of electric and electronic equipment. All applicable products in the EU market after August 13, 2006 must pass WEEE compliance and carry the “Wheelie Bin” sticker. WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS compliance dovetails or jointly marked into WEEE by reducing the amount of hazardous chemicals used in electronics manufacture.

Batteries are not covered under WEEE. All batteries, regardless of type or application, are covered under the EU’s Battery Directive (2006/66/EC and Amendment 2013/56/EU). The Battery Directive restricts the use of lead to 0.004%, mercury to 0.0005%, and cadmium to 0.002% (medical devices/equipment and alarm/emergency systems are excluded for cadmium).

The EU’s RoHS specifies maximum levels for the following 10 restricted substances. The first six applied to the original RoHS while the last four were added under the RoHS 3, effective as of July 22, 2019.

Cadmium (Cd): < 100 ppm

Lead (Pb): < 1000 ppm

Mercury (Hg): < 1000 ppm

Hexavalent Chromium: (Cr VI) < 1000 ppm

Polybrominated Biphenyls (PBB): < 1000 ppm

Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm

Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm

Benzyl butyl phthalate (BBP): < 1000 ppm

Dibutyl phthalate (DBP): < 1000 ppm

Diisobutyl phthalate (DIBP): < 1000 ppm

References:

• RoHS Guide, Web page at: https://www.rohsguide.com/
• REACH Legislation, Webpage at: https://echa.europa.eu/regulations/reach/legislation
• REACH Restricted Substances List, Webpage at: https://echa.europa.eu/substances-restricted-under-reach.

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