Welcome to RoHS Guide

RoHS stands for Restriction of Hazardous Substances, and impacts the entire electronics
industry and many electrical products as well. The original RoHS, also known as Directive
2002/95/EC, originated in the European Union in 2002 and restricts the use of six
hazardous materials found in electrical and electronic products. All applicable products in
the EU market since July 1, 2006 must pass RoHS compliance.

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 recordkeeping requirements.

Directive 2015/863 is known as RoHS 3. RoHS 3 adds four additional restricted substances
(phthalates) to the list of six. RoHS 3 Deadline is 22 July 2019.

Is Your Organization RoHS 3 Compliant for 2019?

Any business that sells applicable electrical or electronic products, equipment, sub-
assemblies, cables, components, or spare parts directly to RoHS-directed countries, or
sells to resellers, distributors or integrators that in turn sell products to these countries, is
impacted if they utilize any of the restricted 10 substances.

With the rapid spread of digitization, the world's production of electrical and electronic
devices is exploding. Besides mobile devices, think about the coming wave of IoT, smart
home assistants, robots, drones, 3D printers, and home medical devices to all corners of
the planet....they are all regulated under RoHS.

EU 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 RoHS 3, which takes
effect 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

Related to RoHS is WEEE, which stands for Waste from Electrical and Electronic Equipment.
WEEE Directive 2002/96/EC mandates the treatment, recovery and recycling of electric
and electronic equipment (90% ends up in landfills). All applicable products in the EU
market must pass WEEE compliance and carry the "Wheelie Bin" sticker.

RoHS 3 (EU 2015/863)

RoHS 3 (EU Directive 2015/863) adds Category 11 (catch-all) products and adds four new
restricted substances - all phthalates. The four phthalates are mainly used as insulation
plasticizers, and are on the REACH list of SVHC (Substances of Very High Concern). The
expanded list for RoHS 3 is thus as follows:

Cadmium (0.01 %)
Lead (0.1 %)
Mercury (0.1 %)
Hexavalent chromium (0.1 %)
Polybrominated biphenyls (PBB) (0.1 %)
Polybrominated diphenyl ethers (PBDE) (0.1 %)
Bis(2-ethylhexyl) phthalate (DEHP) (0.1 %)
Butyl benzyl phthalate (BBP) (0.1 %)
Dibutyl phthalate (DBP) (0.1 %)
Diisobutyl phthalate (DIBP) (0.1 %)

Extention exemption: Of note is that medical devices have a two-year extension to meet
RoHS 3 compliance:

"The restriction of DEHP, BBP, DBP and DIBP shall apply to medical devices, including in
vitro medical devices, and monitoring and control instruments, including industrial
monitoring and control instruments, from 22 July 2021."
Category 11 products include all other electronic and electrical equipment not covered
under the other categories. Included are 2-wheeled vehicles, electronic nicotine delivery
systems (ENDS) such as e-cigarettes, cannabis vaporizers and vape pens. Also included
are electrical cables that are less than 250V working voltage.

China RoHS
The Chinese Ministry of Industry and Information Technology (MIIT) published China RoHS
2 (called the Administrative Measures for the Restriction of the Use of Hazardous
Substances in Electrical and Electronic Products on Jan 21, 2016, with it coming into effect
on July 1, 2016. China RoHS 2 restricts the same six substances as EU RoHS 2.

The original China RoHS only impacted electronic information products (EIP); with China
RoHS 2, electrical and electronic products (EEE) are impacted, similar to EU RoHS. This
applies to equipment with working voltages less than or equal to 1000VAC and 1500VDC.

On June 29, 2017, the MIIT published a (Chinese language) draft catalog of products in
12 product categories subject to compliance, as listed below. Products and parts that
contain restricted substances exceeding limits can still be sold in China but need to be
marked as such. Unlike EU RoHS, there currently are no exemptions.

China RoHS 2 Product Categories

Communication equipment, fixed or mobile

Professional broadcast and TV equipment
Computer and office equipment
Household appliances
Electronic instruments for monitoring and control applications
Industrial electrical and electronic equipment, including monitoring and control
equipment
Power tools
Medical electronics and devices
Lighting products, including electric light sources (lamps) and luminaires
Sports and entertainment products

Unlike EU RoHS, products for large commercial applications (Large Scale Industrial Tools
(LSIT) and Large Scale Fixed Installations (LSFI)) are NOT exempted.

Unlike EU RoHS, which imposes substance concentrations for a product or component,

China RoHS 2 restricts substance concentrations for to each homogenous material in the
product. These concentration limits are published in the GB/T 26572-2011 (Requirements
for concentration limits for certain restricted substances in electronic and electrical
products).

China RoHS 2 also stipulates that an Environmental Protection Use Period be listed
for each product that contains restricted substances above the prescribed limit during
which products "will not leak or mutate suddenly under normal operating conditions and
will not result in serious environmental pollution or cause serious bodily injury to the user
or damage to their assets during the normal use by the user". This Use Period starts on
the date of manufacture.

China RoHS 2 Marking:

The symbol on the left is affixed to products that pass RoHS 2 compliance for all materials,
while the symbol on the right is affixed to products containing substances above RoHS
limits, and displaying the Environment Use Period (in this example 10 years).

Along with the non-compliance mark, a Hazardous Substance table must also be supplied
with the product that lists each part that is out of compliance:
Compliance enforcement protocols and penalties for non-compliance may be included
might become part of the China Compulsory Certificate system, with testing by a 3rd-
party lab required.
RoHS Initiatives Worldwide
Your business probably will not escape RoHS compliance just because your products don't
sell in the EU market. The following countries have implemented their own version of RoHS
as well:

U.S. California RoHS (SB20/SB50) Compliance

California RoHS took effect on January 1, 2007. California Senate Bills SB 20 and SB 50
contain both RoHS and WEEE-like provisions. California RoHS is narrower in scope than
EU RoHs in that it restricts only lead, mercury, cadmium and hexavalent chromium and
not the other six substances covered under EU RoHS 3. In addition, it only applies to
"covered electronic devices" that are defined as standalone LCD, plasma, and CRT video
displays with a screen greater than four inches diagonally. Displays integrated into other
equipment do not apply.

Other U.S. states that have enacted RoHS-like and e-waste regulations include Colorado,
Illinois, Indiana, Minnesota, New Mexico, New York, Rhode Island, and Wisconsin.

China RoHS Compliance

China RoHS, known as the Administrative Measure on the Control of Pollution

Caused by Electronic Information Products (ACPEIP), took effect on 1 March 2007.

China RoHS has product marking requirements for the six EU RoHS restricted substances
for all applicable products as to whether it is compliant or non-compliant. Disclosure can
be at the component or ar the sub-assembly level, but it has to be in a prescribed format
in Chinese as detailed in "Marking for the control of Pollution Caused by Electronic
Information Products". Specifically, a sticker with the Environment Friendly Use Period
(EFUP) is applied, which lists the period of time in years before any of the RoHS substances
are likely to cause possible harm to health or the environment. China RoHS also used to
be referred to as RPCEP (Regulation for Pollution Control of Electronic Products).

The Ministry of Industry and Information Technology (MIIT) maintains the database of
products that are subject to RoHS restrictions. For more information, see China RoHS vs
EU RoHS.
Japan RoHS (J-MOSS) Compliance

Japan RoHS law combines the Japanese Recycling Law (Law for Promotion of Effective
Utilization of Resources in Japan) with the JIS C 0950 standard (marking for presence of
the specific chemical substances for electrical and electronic equipment) and is referred to
as J-MOSS. Japan RoHS restricts the same six substances in the same concentration limits
as EU RoHS 2, but for only seven product categories.

J-Moss (Japanese RoHS) August 2008. The name J-Moss is a combination of initial
of “Japan” and an acronym of JIS C 0950 title “The marking for presence of the
specific chemical substances for electrical and electronic equipment.” For more
information, see Japan RoHS vs EU RoHS.

Taiwan RoHS Compliance

Taiwan RoHS (CNS 15633) became law on December 1, 2016 by the BSMI (Bureau of
Standards, Metrology & Inspection, M.O.E.A., R.O.C.). Taiwan RoHS mirrors the original
EU RoHS for the six restricted substances, with differing effective dates.

However, unlike EU RoHS, which prohibits products that contain hazardous substances
from being placed on the market, Taiwan allows products even if their restricted
substances content is beyond the thresholds. In this case, the applicant must create
a Table of Presence Condition of Restricted Substances and add the table to the
body, packaging, stickers, and instruction manuals of these products.

Korea RoHS Compliance

On Jan 1, 2008, the Act for Resource Recycling of Electrical and Electronic Equipment and
Vehicles went into effect as Korea RoHS. It restricts the six substances with the same
limits as EU RoHS2 for electrical and electronic equipment. Vehicles under 3.5 tons are
also impacted under the first 4 substances (cadmium, mercury, lead, and chromium
(Cr6+). The definition of vehicles is adopted from Article 2(1) of the Automobile
Management Act. No mark or certification is required.

Korea's equivalent of the EU RoHS, WEEE, and ELV directives adopts an Eastern approach
by including "design for the environment" in its requirements. Implementation is geared
toward improvement in product design and recycling technology as they become
technically and economically feasible.
Norway RoHS Compliance (PoHS)

As of December 20, 2011, Norway restricted lead (at 0.01% vs. 0.1% for EU RoHS), PCP,
PFOA and MCCP, of which lead is the only common substance with EU RoHS. Also known
as PoHS, which stands for the "Prohibition on Certain Hazardous Substances in Consumer
Products", it is more of a general consumer product legislation rather than for EEE
equipment.

India RoHS Compliance

India RoHS, which took effect in May 2014, restricts the same six substances at the same
thresholds as EU RoHS, but with a differing scope of products. For more information,
see India RoHS vs EU RoHS.

Ukraine RoHS Compliance

Ukraine RoHS, also known as Technical Regulation Decree No. 139, was approved by
the Cabinet of Ministers of Ukraine on March 10, 2017. This decree supercedes the original
Decree No. 1057 from 2008. Ukraine RoHS follows EU RoHS 3 (2015/863) in the restriction
of 10 substances (6+4) in 11 EEE product categories and with the same exemptions.

Singapore RoHS Compliance (SG-RoHS)

Starting June 1, 2017, the Singapore Ministry of the Environment and Water Resources
(MEWR) adopted a regulation that prohibits the use of the six RoHS substances used in
the following products: mobile phones, laptops, flat-panel TVs, refrigerators, air
conditioners, and washing machines. For more information, see Singapore RoHS vs EU
RoHS.
UAE RoHS Compliance

UAE Cabinet Decision No. 10/2017 specifies that starting on January 1, 2018, ROHS will
be enforced in Abu Dhabi, Ajman, Dubai, Fujairah, Ras al-Khaimah, Sharjah, and Umm al-
Quwain. UAE RoHS regulations will require companies to provide a national UAE RoHS
Declaration of Compliance (DoC), associated documentation, and obtain a certificate to
put products on the UAE market. Unlike EU RoHS, this information would only be required
by regulatory agencies if there was a suspected compliance issue.

Turkey RoHS Compliance

Turkey announced the implementation of their Restriction of Hazardous Substances

(RoHS) legislation effective June 2019. The legislation was created by the Turkish
Ministry of Environment and Forestry and includes manufacturers and sellers of electronic
goods and includes products which are supplied by others under their own brand names.

Manufacturers must keep documentation showing that products they introduce to the
market meet the criteria for legislation for 5 years starting from the date the product is
released to the market. Manufacturers must also submit a Conformity Declaration Form to
the Turkish government every year.

Eurasian/Russian RoHS Compliance

The Eurasian Economic Union (EEU) member states of Armenia, Belarus, Kazakhstan,
Kyrgyzstan and Russia passed RoHS legislation on March 1, 2018, and has aligned its
regulation with the EU RoHS. This is known as CU TR 037/2016 or EAC RoHS. EEU member
states will have until March 1, 2020 to comply.

Brazil RoHS Compliance (COMING)

A working group presented a draft proposal that aligns closely with EU RoHS before the
National Environment Council (Conama) in summer, 2018.
Japan RoHS (J-MOSS)
Japan RoHS law combines the Japanese Recycling Law (Law for Promotion of Effective
Utilization of Resources in Japan) with the JIS C 0950 standard (marking for presence of
the specific chemical substances for electrical and electronic equipment) and is referred
to as J-MOSS. Japan RoHS restricts the same six substances in the same concentration
limits as EU RoHS 2.

Japan RoHS Product Categories

Personal computers
Unit-type air conditioners
Television sets
Refrigerators
Washing machines
Clothes dryers
Microwaves

All products in the above listed categories are marked with either an orange "R" mark or
a green "G" mark, depending on whether any of the six restricted substances exceed
concentration limits or not. If the content of a substance in a product exceeds its
concentration limit, it must be disclosed on the product website in Japanese in accordance
with the JIS C 0950 standard.

Japan RoHS Marking:

Also known as the J-Moss mark, the green symbol is affixed to products that pass RoHS
compliance for all materials, while the orange symbol is affixed to products containing
substances above RoHS limits.
J-Moss green mark guidelines are issued by the following industry associations that cover
the designated products: JEITA (Japan Electronics and Information Technology Industries
Association), JEMA (Japan Electrical Manufacturers Association), and JRAIA (Japan
Refrigeration and Air Conditioning Industry Association).

India RoHS
India RoHS became law in May, 2014, and restricts the same 6 substances under RoHS 2
(2011/65/EU). Unlike the EU that has separate directives for RoHS and WEEE, India
combines the requirements into a single legislation. India RoHS has differences in product
categories and products that are in scope and that are exempted:

In-Scope Categories

EU Category 1: Refrigerators, washing machines, air-conditioning units (except

centralized A/C units) only

EU Category 3: all except for calculators, printer cartridges, equipment for collecting,
storing, processing, or transmitting information electronically
EU Category 4: Television sets only

Exempted Categories

·: Products for military and national defense

·: Products where electricity is not the primary power source
·: Products where the primary function does not require electricity (e.g. talking dolls)
·: Sub-assembly or component of exempted product category
·: Products that serve small manufacturing and service businesses as defined under the
Micro, Small & Medium Enterprises Development Act of 2006
·: Batteries
·: Radioactive waste

India has a number of specific-use lead exemptions similar to that for EU RoHS Annex III
Exemptions, as well as for cadmium and mercury.

Compliance enforcement protocols and penalties for non-compliance are not specified.

Singapore RoHS (SG-RoHS)

Singapore RoHS became law on June 1, 2017 by the Singapore Ministry of the Environment
and Water Resources (MEWR), and restricts the same 6 substances as under RoHS 2
(2011/65/EU). Singapore RoHS is much more lax than EU RoHS however in products are
in scope, as follows:

In-Scope Products

Refrigerators
Washing machines
Air conditioners
Portable computers
Mobile phones
Flat-panel TVs

All other products, including spare parts for the in-scope products listed below, are
exempted.
A RoHS Declaration of Conformity (DoC) must be submitted to the National Environmental
Agency (NEA), as well as a Technical File as per EU BS EN 50581:2012. No special marking
is required for labelling products for sale in Singapore. EEE products in non-compliance
can still be manufactured for export, but the manufacturer will need to apply for a
hazardous substance licence from the NEA.

RoHS Steps to Certification

The following steps are involved for RoHS certification.

1. Testing: Either on-site or XRF testing and/or lab phthalate solvent extraction testing
is done to determine values of the ten restricted RoHS substances.

2. Process Audit: Inspect all applicable manufacturing processes used towards RoHS
compliance on-site.

3. Documentation Review: Review the Bill of Materials, Technical File, assembly

drawings, materials declarations, test reports, and conformance/compliance certificates
from all suppliers.

The Technical File must contain the following:

General product description and design structure information
Risk assessment of materials, parts and subassemblies
Conformity information on materials, parts, and subassemblies
Manufacturing documentation and records
Harmonized standards, specifications, and conformity procedures

4. Certification Statement: After a successful audit, a RoHS Certificate of Compliance

(also known as a Certificate of Conformity or Declaration of Conformity) is issued.