For those of you interested in lead-free electrical and electronic equipment, there’s a big change happening in Europe this month. ROHS I (2002/95/EC) has been replaced by ROHS II, “Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (recast).”
There’s no change to the list of the six controlled substances banned under ROHS I. However, a review of Annex II (the list of restricted substances) must be done by the Commission by 22 July 2014, using a procedure based on the restriction process of the REACH Chemicals Regulation (Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals).
Also the scope of the directive has been expanded with the release of ROHS II. Covered Electrical and Electronic Equipment (EEE) now includes products dependent on electric current or electromagnetic fields for at least one intended function. ROHS I only applied to equipment that depended on electric current or electromagnetic fields for its primary function.
RoHS II also added three new categories of EEE: medical devices, monitoring and control equipment, and “all EEE not covered by any other category.” Medical devices and monitoring and control equipment are included as of 2013. The broader “other category” does not apply until 2019. This will include any electrical and electronic product that is not specifically excluded.
FYI: Permanent exclusions from RoHS include the following: military equipment, space equipment, equipment designed to be part of another piece of equipment falling outside the scope of RoHS, large scale industrial tools, large scale fixed installations, means of transport for persons or goods, non road mobile machinery, active implantable medical devices, photovoltaic panels, equipment for research and development only available business to business.
The exemptions process in ROHS II has been amended as well. Now there are three categories of exemptions: exemptions for technical applications of all categories of EEE, exemptions for medical devices, and exemptions for monitoring and control instruments. The 4-year review process has been abolished, so companies must request an exemption renewal 18 months before expiry. All exemptions (except for those applying to medical devices and monitoring and control instruments) are subject to a 5 year time limit. And there are new exemption criteria including the availability and reliability of substitutes and socio-economic impact.
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