EU Environmental Regulation: What Is the Difference Between RoHS, REACH and WEEE?

Since the early 2000s, the European Union has passed several directives that aim to create products that are not only safer for human health, but also more environmentally friendly. These directives include RoHS, REACH, and WEEE. All three of these regulations must be taken into account when placing products on the EU market.

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What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

RoHS defines EEE as: “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” (Directive 2011/65/EU). All EU directives that focus on EEE (such as WEEE) use the same definition.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. The current restrictions are the result of one original directive and two additions known as RoHS II and RoHS III.

Substances Restricted by RoHS

The ten hazardous materials currently included in RoHS can only be used in electronic equipment under the maximum levels laid out by the directive. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

Read more: What is RoHS?

Who Is Subject to RoHS Regulation?

Any manufacturer, importer, or distributor of electronic and electrical equipment (EEE) sold in the EU market must be compliant with RoHS. Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

It is the manufacturer’s responsibility to ensure their product complies with RoHS. The manufacturing and testing requirements necessary for RoHS compliance may also increase costs for manufacturers. 

Read more: What is ‘RoHS Compliant’?

What is REACH?

REACH stands for Registration, Evaluation, Authorisation, and Restriction of Chemicals, and is an EU regulation that manages and restricts the use of hazardous chemicals in products manufactured and sold in the EU. Like RoHS, REACH restricts hazardous chemicals, but is not specific to electronics, as RoHS is.

The regulation entered into force on June 1, 2007. 

REACH is designed to protect human health and the environment from the effects of harmful chemicals. The regulation also helps the European Chemicals Agency (ECHA) gather information about chemical substances used in products on the EU market. Ultimately, the goal of REACH is to encourage companies to research and use safer alternatives.

All EU manufacturers and importers must register any substances used (above a specific yearly amount) with ECHA. This helps to:

  • Identify risks that these substances pose to human health
  • Prove to ECHA that the company is managing that risk
  • Create guidelines for safe use of their product to protect public health of consumers

Products Restricted by REACH

REACH has an extremely widespread impact, as it applies to all chemical substances used in products manufactured, imported and sold on the EU market. This does not include only industrial processes, but also products we use every day, such as clothes or cleaning products.

REACH also applies to chemicals used in electronic products. When a substance that is restricted by RoHS is added to the list of REACH restricted chemicals, RoHS and REACH may overlap. Usually RoHS is given priority when it comes to regulating EEE, but authorities often try to ensure that REACH and RoHS are compatible.

There are several products that have total exemption from REACH regulation, such as radioactive materials. There are also partial exemptions, products that are exempt from certain restrictions. For example, substances used in food or medicinal products are exempt from the registration and authorisation requirements. For a full list of total and partial exemptions, visit the European Chemicals Agency website.

Substances Restricted by REACH

Chemicals that are regulated by REACH are known as SVHCs, Substances of Very High Concern. SVHCs include chemicals that are carcinogenic or mutagenic, cause reproductive problems, or bioaccumulate. 

SVHCs include several substances also restricted by RoHS, such as phthalates, cadmium, lead, and mercury.

REACH requires companies to disclose and report SVHCs used in their products or packaging.

If a chemical’s risk is viewed to be unmanageable, its use can be banned entirely, restricted, or require prior authorization from the ECHA before use in production. Companies must ensure that their products do not contain substances in amounts exceeding REACH thresholds.

A full list of restricted SVHCs can be found on the ECHA website. 

Who is Subject to REACH Regulation?

REACH affects companies in almost every sector of industry. Companies are responsible for complying with REACH regulation. This includes:

  • Manufacturers in the EU, both of chemicals and finished products
  • Importers in the EU, both of chemicals, chemical mixtures, and finished products
  • Downstream companies: If you handle chemicals in a professional or industrial setting, you may be subject to REACH regulation.

Unlike RoHS and WEEE, companies established outside the EU are not obligated to comply with REACH, even if their products are imported into the EU market. Instead, it is the importers that lie within the EU who are responsible for ensuring REACH compliance.

Regulation and compliance differs by the type of product placed on the market. However, all companies must identify the risks of the substances they manufacture or use in manufacturing, and then demonstrate to ECHA how they are safely and effectively managing that substance’s use. Additionally, information on how to manage risk when using that product must be communicated to consumers.

What is WEEE?

WEEE, Waste Electrical and Electronic Equipment Regulation, is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use.

The directive works to:

  • Reduce the amount of e-waste that ends up in landfills
  • Encourage redesign of EEE so that it can be dismantled and properly disposed of
  • Increase re-use of WEEE and its components and materials

To achieve these goals, WEEE requires Member States to set specific targets for the amount (by weight) of EEE collected, recycled, and recovered. These targets differ by country.

Products Restricted by WEEE

As of 2018, all EEE is included under WEEE, as every EEE device becomes WEEE at the end of its use.

EEE subject to WEEE regulation is classified under six categories:

  1. Temperature exchange equipment
  2. Screens, monitors, and equipment containing screens with a surface larger than 100 cm2.
  3. Lamps
  4. Large equipment (any dimension larger than 50cm)
  5. Small equipment (no dimension larger than 50cm)
  6. Small IT and telecommunication equipment

Read more: What is WEEE?

Who is Subject to WEEE Regulation?

All producers of EEE must comply with WEEE requirements. The directive defines producers as anyone who:

  • Manufactures and sells EEE under his/her own brand
  • Resells EEE produced by other suppliers under his/her own brand
  • Imports or exports EEE into an EU Member State
  • Sells EEE by “distance” (for example, over the internet) to Member States, even if this seller is in a different country.

The directive sets out specific requirements producers must follow to be WEEE compliant, such as reporting the amount of EEE placed on the market and providing e-waste recycling services to customers. 

Read more: WEEE Compliance

Similar Objectives: Goals of RoHS, REACH, and WEEE

RoHS, REACH, and WEEE all share a similar objective: to protect the environment and human health. 

RoHS- The RoHS directive restricts the use of toxic materials in EEE. RoHS aims not only to protect the health of users of EEE devices, but also to reduce occupational health hazards for manufacturers of EEE. RoHS also keeps hazardous materials from accumulating in the environment after EEE is thrown out.  

REACH- REACH aims to protect human health from the effects of dangerous chemical substances used in products we use in our everyday lives, ranging from clothing to furniture. REACH also seeks to protect the environment by keeping large amounts of dangerous chemicals out of manufacturing, and out of landfills when products are disposed of.

WEEE- WEEE aims to safeguard human health from the effects of EEE at the end of its lifecycle. By improving recycling of e-waste, WEEE keeps hazardous materials used in EEE out of landfills, and thus, out of soil, water, and air. This protects the environment, animals, and human health against toxic materials contained in EEE.

Read more about each regulation’s protection of human health and the environment below.

All three regulations seek to protect the environment and human health by placing requirements on manufacturers and producers of potentially harmful products, rather than on consumers. 

Different Methods: Requirements of RoHS, REACH, and WEEE

While RoHS, REACH, and WEEE all aim to protect the environment and human health, each regulation works to achieve this goal through a different method or set of requirements. 

RoHS, REACH, and WEEE create requirements that fall into three categories, based on where in a product’s life cycle the requirements are focused: during a product’s manufacturing, during a product’s use, or upon a product’s disposal. Even requirements that target the same stage in a product’s life cycle vary greatly by directive.

Product Manufacturing Requirements

Each regulation creates requirements that manufacturers or importers must follow either before placing the product on the market or upon placing the product on the market.

RoHS- RoHS requires that manufacturers of EEE do not exceed the allowable limits of restricted substances. 

Manufacturers must follow a series of steps to confirm compliance and demonstrate compliance to authorities and the public, including testing the product and compiling documentation about the product’s manufacturing. These steps must be taken prior to the product’s placement on the market.

Read more: What is ‘RoHS Compliant’?

REACH- Like RoHS, REACH works to keep dangerous chemicals out of products sold on the EU market. 

Manufacturers and importers are required to research and report on the chemicals used in their products in order to prove the company is able to safely manage the chemical’s risk. Companies must register with the European Chemical Agency before manufacturing a product using potentially toxic chemicals.

REACH requirements emphasize information gathering, as all data is reported to the European Chemical Agency, who compiles data and makes decisions about requirements for chemical use on a case by case basis.

WEEE- Under WEEE, producers must take several steps upon placing EEE products on the market. Producers must:

  • Register and report the volume of EEE placed on the EU market to the correct governing body (which varies by country). 
  • Provide recyclers with the necessary information on how to recycle the EEE product or prepare the product to be re-used.

Read more: WEEE Compliance

Product Use Requirements

Each regulation requires manufacturers to create a marking or messaging that is intended to educate the buyer.

RoHS- RoHS requires manufacturers to put a CE marking on RoHS compliant EEE products. This shows authorities and the public that the product has been carefully evaluated and documented, and does not exceed allowable amounts of hazardous substances restricted by RoHS.

REACH- REACH requires manufacturers and importers of products that use dangerous chemicals to provide guidelines to consumers for how to use the products safely and properly.

WEEE- WEEE requires that all compliant EEE be marked with the “WEEE symbol,” a recycling bin that is crossed out. This helps customers to properly dispose of their EEE products.

Product Disposal Requirements

Only WEEE creates requirements related to disposal of products at the end of their lifecycle.

WEEE- Producers of EEE must create or finance a system for customers to recycle old EEE. This may entail a collection service or a drop-off location. This recycling program must be free of charge to the customer. 

Customers are not penalized for improper disposal, but still benefit from recycling of e-waste. Read more: What is WEEE?

Impacts of ROHS, REACH, and WEEE

EU environmental regulation’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. RoHS, REACH, and WEEE all impact the cost of relevant products for sellers and buyers and work to protect the natural environment and human health.

1) The Market

All three regulations raise costs for sellers, as they must use new materials or create new compliance programs. This in turn raises costs for buyers, who pay increased prices for their devices. 

RoHS- RoHS raises costs for sellers and buyers of EEE alike. 

EEE manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing EEE products and ensuring RoHS compliance may be costly.

Buyers also experience increased prices of electronics in order to offset costs faced by manufacturers.

REACH- Like RoHS, REACH may increase costs for sellers and buyers. Manufacturers face increased expenses related to registering with the ECHA. Additionally, using substitute chemicals may be costly.

Buyers may experience increased costs as a result of REACH requirements on manufacturers.

WEEE-  Prices may increase for producers as a result of WEEE requirements, such as the creation of new recycling programs.  However, WEEE allows companies to save costs on materials, as companies can begin to use reused, and thus cheaper, materials. 

Buyers may also face higher prices for their electronic devices due to WEEE. As producers pay increased costs to produce WEEE-compliant products and recycling programs, consumers often offset these costs by paying more for their devices

WEEE has wider-spread market impact as well; a central goal of WEEE is to create a circular economy, an economy in which industry reuses and recycles raw materials. The circular economy minimizes waste and addresses resource scarcity in a world of finite raw materials.

2) The Environment

All three regulations work to keep hazardous materials out of landfills, and thus out of water, soil, and air. This protects the environment and other species from the toxic effects of hazardous materials.

RoHS- The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

REACH- REACH reduces the amount of toxic chemicals used in everyday products. Not only does this make the manufacturing process safer, but it also keeps those hazardous chemicals out of the environment when products are disposed of. 

SVHCs restricted by REACH can have far reaching environmental effects, such as river acidification and injury to wildlife. By requiring prior authorization for use of these chemicals, or by outright banning them, REACH works to ensure companies are effectively managing environmental risks.

WEEE- Many electronic devices contain materials such as heavy metals and chemicals that have large environmental consequences upon becoming e-waste. WEEE protects against improper disposal of EEE, which creates environmental pollution, destroys habitats, and impacts the health of other species.

When e-waste is improperly disposed of, toxins and particles are released into the air, causing pollution. These toxic materials can also leech into the soil or groundwater, which can impact crops and drinking water. 

Lastly, WEEE takes up land area when it sits in landfills. By increasing proper recycling measures and encouraging reuse of materials, the WEEE directive helps reduce the amount of space landfills use globally. 

3) Consumer Health

All three regulations protect human health, either by keeping toxic materials out of the manufacturing process or by reducing human exposure to toxic materials in product waste.

RoHS- Several materials restricted by RoHS create toxic waste and occupational hazards that negatively impact human health. EEE that uses higher than allowed amounts of restricted substances cause health problems not only for workers manufacturing the products, but also for recyclers of the products. 

Manufacturing products that use restricted substances also negatively impacts the health of communities located near manufacturing plants.

Lastly, RoHS works to protect human health during the use of products. For example, toys whose paint contains lead, a toxic heavy metal, are not RoHS compliant.

REACH- REACH protects human health by managing the use of dangerous chemicals in products we use every day. SVHCs restricted by REACH can cause extreme damage to human health, such as reproductive harm and cancer. 

REACH helps gather information on dangerous chemicals and ensures that the risks to human health are being managed.  If the ECHA determines that a chemical’s risk cannot be managed and will harm manufacturers or consumers, then the chemical will no longer be used in products sold on the EU market.

WEEE- The WEEE directive works to reduce risks to human health caused by exposure to e-waste. 

E-waste can contain toxic substances such as lead, mercury, sulfur and cadmium. If these materials are not disposed of properly, the buildup of contamination in water and soil can cause health problems.

A 2013 WHO study found that exposure to e-waste can cause severe health impacts, including adverse birth outcomes, changes in thyroid function and cell function and decreased lung function (Grant et al. 2013). By creating proper and accessible recycling pathways, WEEE reduces human exposure to e-waste.

RoHS, REACH, and WEEE at a Glance: Comparison Table

RoHSREACHWEEE
Scope: Restricted ProductsRoHS applies to all EEE sold on the UK market, with some exemptions, listed in Article 2 of RoHS 2 (Directive 2011/65/EU).

Read more: What is ‘RoHS Compliant’?
REACH applies to all parts and products sold on the EU market, with some exemptions, listed on the European Chemicals Agency website.WEEE applies to all EEE products sold on the EU market at the end of their life-cycle, with some exemptions.

Read more: WEEE Exemptions.
Restricted SubstancesRoHS includes 10 restricted hazardous substances that are restricted by ppm.
These substances are evaluated at the homogenous materials level.
REACH restricts a list of over 200 SVHCs (Substances of Very High Concern) that are subject to registration, restriction, or prior authorization. The full list can be found on the ECHA website.WEEE does not include restricted substances.
Party Responsible for ComplianceAll manufacturers of EEE sold on the EU market.Manufacturers, importers, and downstream users of chemicals and products restricted by REACH.All producers of EEE sold or distributed on the EU market.

Read more: WEEE Compliance
Relevance to Companies Outside the EUAll companies who sell or import their products in the EU must comply, even if they are established outside of the EU.Companies that are not based in the EU are not subject to REACH regulation. Instead, importers based in the EU must ensure compliance.All producers who sell or import their products in the EU must comply, even if they are established outside of the EU.
EnforcementRoHS is a directive, so each Member State must put it into law separately, and is responsible for enforcement.REACH is a regulation, so it is legally binding across all Member StatesWEEE is a directive, so each Member State must put it into law separately, and is responsible for enforcement.
NoncompliancePenalties may include financial and legal consequences, such as fines and orders to stop shipping or selling a product. Penalties differ across Member States.Penalties may include financial and legal consequences, such as fines and orders to stop shipping or selling a product. Legal consequences may include imprisonment. Penalties differ across Member States.Penalties may include financial and legal consequences, such as fines or prosecution. Companies are often provided with a warning letter following inspection before further steps are taken. Penalties differ across Member States.

What Is the Function of Heavy Metals in Electronics?

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Devices that consumers use every day, such as televisions and computers, contain heavy metals. This article explores why heavy metals are used in electronics and, as well as the toxic effects of those heavy metals.

What Are Heavy Metals?

There is no agreed upon definition of heavy metals. Instead, heavy metals have two definitions.

  1. Heavy metals are metals that have a high density (particles are packed closely together). 

Most heavy metals under this definition have a high atomic number (the number of protons in the nucleus of an atom) and a high atomic weight (the total weight of the atoms making up an element).

  1. Heavy metals are metals with relatively high density that are toxic at low concentrations, meaning even a small amount of the metal is toxic.

To be considered a heavy metal, the material must meet either of these definitions, but does not need to meet both. Some metals, such as mercury or lead, are both high density and toxic at low concentrations. Other metals may simply fit one of the definitions.

Many of the metals you’ve heard of, such as iron, copper, platinum, and gold, are heavy metals due to their high density. Some of these high density heavy metals, such as iron, cobalt, and zinc act as nutrients. Others, such as silver, are not toxic in small amounts, but can be toxic in higher amounts or different states.

Other heavy metals, such as hexavalent chromium and cadmium, are highly toxic in low concentrations and can cause severe health problems when a human is exposed.

Which Heavy Metals are Found in Electronics?

Heavy metals are necessary to create many of the electronic devices an average consumer uses every day. The following heavy metals, while not the only heavy metals used, perform important functions in a wide variety of electronics. 

Cadmium

Cadmium is a heavy metal used in electronics, and is popular due to its malleability. Cadmium selenide, a cadmium compound, is an easily shaped metal that is most often used as semiconductors. 

Semiconductors can conduct electricity in high heat, but not in low heat. Cadmium is a good semiconductor because it is highly resistant to high temperatures. Semiconductors like cadmium selenide have a conductivity (ability to conduct electricity) that lies in between a conductor (like metal) and a non-conductive insulator (like ceramic). As temperature rises, the conductivity of the semiconductor increases, and the cadmium material can act as a conductor. At low temperatures, the same material blocks the flow of electricity. 

Semiconductors are found in most electronic devices today. Semiconductors have an extremely wide variety of functions, but generally they work to amplify signals in a circuit, convert energy, and pass current in a specific direction.

Cadmium also is resistant to corrosion. This makes it a popular metal to use as a protective shield against corrosion in electronics.

Read more about cadmium in electronics: Cadmium

Mercury

Mercury is a heavy metal commonly used in LCD (liquid crystal display) screens. LCD screens use cold-cathode fluorescent lamps (CCFLs) that contain mercury. CCFLs include fluorescent tubes that work to backlight an LCD TV or monitor screen. The light is produced when electricity is used to excite (add energy to) mercury vapor. The vapor is discharged, which creates a fluorescent coating on the inside of the tube that emits light.

Mercury is also used in some laptop screen shutoffs. In a mercury tilt switch used in some laptops, mercury moves to the other side when the laptop is opened or closed. This shift turns the screen on or off.

Mercury was also used to create switches in televisions that were produced before 1991.

Read more about mercury in electronics: Mercury


Lead

Lead is considered one of the most important metals in electronic production. Lead is malleable, does not break easily, and, when combined with tin, has a low melting point, which means it can be worked with at a lower temperature and is less sensitive to variations in temperature.

The main use of lead in electronics is lead soldering. Lead-tin soldering is used to attach electronic components. The lead solder connects two metals securely, allowing an electric signal to pass through. For example, lead solder could attach a wire to a circuit board

Lead is also used in alloys (a mixture) with other metals, such as copper and steel, which expands the use of these metals. Lead alloy in steel is often used in electronic products.

Read more about lead in electronics: Lead

Nickel

Nickel is a heavy metal used in a variety of electrical equipment and devices. Pure nickel conducts electricity well, is magnetic, and is resistant to corrosion. Nickel is often used in electronic wiring. 

Nickel is often used in electronics in alloy form, particularly in heating coils of electric appliances like irons, toaster ovens, and grills. Nickel is also used in powder form in cell phone capacitors, a device that stores electrical energy. Nickel powder may also be mixed in with a non-conductive substance, such as silicone and rubber, to allow for conductivity through the substance. This technique is most frequently used in cell phone microphones.

Hexavalent Chromium

Hexavalent chromium is a form of the heavy metal chromium that is not found in nature, and is thus manmade. Hexavalent chromium is commonly used in anticorrosive coatings on metal parts in electronics or as a pigment or paint.

The process of protecting metal from corrosion using hexavalent chromium is called chromating or passivation. In passivation, a thin layer of chromium salts are added to a metal in an electronic device. Chromium-coated metal is used in many components, including nuts and bolts, electric switches, and antennae.

Read more about chromium in electronics: Hexavalent Chromium

Exposure to Heavy Metals

Some heavy metals used in electronics are toxic. Exposure to heavy metals used in electronics can cause serious environmental and health problems. 

Most people are not exposed to heavy metals when using electronics. For example, it is unlikely that you are frequently exposed to your phone’s circuit board or the inner workings of your LCD television screen. However, exposure may occur either during manufacturing of electronics or during recycling, when the parts are broken down and heavy metals are exposed.

According to a paper published at Stanford University in 2011, heavy metals can harm not only workers in the production and recycling phases, but also communities located near manufacturing plants (Nimpuno et al. 2011).

Additionally, if electronics are not recycled and are instead allowed to break down in a landfill, it is likely that heavy metals will eventually leak out. This not only creates a risk of toxic exposure for humans, but also has severe environmental impacts. Toxic substances can leach into water, soil, and air, harming not only human health, but other species.

Negative Impacts of Heavy Metals

Cadmium

Exposure to cadmium is most famous for causing a degenerative bone disease, Itai-itai disease. This disease was caused by cadmium poisoning contracted as a result of mining. Cadmium is highly water soluble, and so as mining byproducts, including cadmium, were released into a nearby river, cadmium pollution occurred. Eventually, cadmium was absorbed into crops irrigated by the river, causing widespread disease.

Cadmium can also soften the bones and cause kidney damage.

Mercury

Mercury exposure at high levels can cause a host of health impacts, including damage to the brain, heart, lungs, kidneys, central nervous system, and immune system. 

Mercury can be released into the air a number of ways, one of which is through burning of electronic products containing mercury. Mercury can be transported in the air for great distances before it is deposited in soil and water.

While mercury exposure is most common by eating seafood containing mercury, exposure to mercury vapor is also possible if an electronic device containing mercury breaks. For example, if an LCD screen containing cold-cathode fluorescent lamps (which contain mercury) breaks, toxic mercury dust or powder can be released.

Mercury can also cause significant environmental damage. When animals are exposed to mercury at high levels, death and reproductive damage can occur.

Lead

There is no safe exposure level to lead. When lead is swallowed or breathed in, or enters the body another way, it gets stored in blood, which can cause long-term harm.

 Lead exposure, particularly in children, can cause damage to the brain and nervous system, slowed growth, and problems with hearing and speech. Long term exposure in adults can also cause fertility problems, heart disease, and kidney disease.

Nickel

Industrial use of nickel has led to environmental pollution and has increased human exposure to the toxic heavy metal.

Nickel has a wide variety of health impacts caused by exposure, including allergy, headaches, cardiovascular and kidney diseases, lung fibrosis, lung and nasal cancer. While research is ongoing as to the mechanism for these diseases (how nickel acts in the body to cause the disease), inhalation is the clear route of exposure that causes respiratory tract cancer.

Hexavalent Chromium

Hexavalent chromium is carcinogenic and causes a wide range of health problems, particularly in people exposed to the metal in manufacturing.

If hexavalent chromium is breathed at high levels, it can cause lung cancer, damage to the respiratory tract, and damage to the eyes and skin (dermatitis). Prolonged exposure, such as working in a factory that uses hexavalent chromium to produce anti-corrosive coatings, is especially dangerous.

Solutions: Reducing the Risk of Heavy Metals in Electronics

Several countries have enacted legislation that aims to reduce the risks, both to the environment and human health, associated with heavy metals. The most impactful legislation in this area comes from the EU, in the form of RoHS and WEEE directives.

RoHS: Restriction of Hazardous Substances

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). 

Manufacturers may not use restricted substances in amounts above 1000ppm (cadmium’s limit is 100ppm). Restricted substances include heavy metals Cadmium (Cd), Mercury (Hg), Lead (Pb), and Hexavalent Chromium (Cr VI).

RoHS restrictions help reduce the risk of exposure to toxic heavy metals in electronics. For example, if those electronic devices were to break or be put in landfill, it is less likely that high amounts of toxic metals will leak out.

Read more: What is RoHS?

WEEE: Waste Electrical and Electronic Equipment

Waste Electrical and Electronic Equipment (WEEE) is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use. WEEE helps reduce the amount of electronic waste that ends up in landfills, and helps ensure proper, safe disposal of electronic waste.

Read more: What is WEEE?

What is RoHS? Understanding Restriction of Hazardous Substances in Electronics

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What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. The current restrictions are the result of one original directive and two additions known as RoHS 2 and 3.

RoHS 1 – The original directive, Directive 2002/95/EC, was issued in 2002, and included six materials deemed to be hazardous to human health and the environment. 

RoHS 2 – In 2011, the original directive was superseded by Directive 2011/65/EU, known as RoHS 2. RoHS 2 included additional requirements for assessment of electronic products in the EU, as well as additional categories of appliances subject to RoHS.

RoHS 3 – The directive was amended in 2015 when Directive EU 2015/863, or RoHS 3, added 4 new restricted phthalates. RoHS 3 is simply an amendment to its predecessor, and businesses must still comply with all requirements of RoHS 2.

Read more: The Difference Between RoHS 1, 2 and 3

Which Hazardous Substances Are Restricted by RoHS?

The ten hazardous materials included in RoHS can only be used under the maximum levels laid out by the directive. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

Which Products Are Restricted?

EEE regulated under RoHS includes a wide variety of products separated into eleven categories, ranging from large household appliances to medical devices. The eleventh category is all-encompassing, as it includes any EEE not covered in the previous ten categories. 

It is important that manufacturers determine whether their product fits the definition of EEE, because all EEE is subject to RoHS compliance requirements. RoHS defines EEE as: “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” (Directive 2011/65/EU). 

Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

Who Does RoHS Impact?

RoHS has widespread impact, but directly affects sellers of EEE and buyers of EEE.

1) Sellers of EEE: Manufacturers, Importers, and Distributors

Any manufacturer, importer, or distributor of electronic and electrical equipment (EEE) sold in the EU market must be compliant with RoHS.

It is the manufacturer’s responsibility to ensure their product complies with RoHS. The manufacturing and testing requirements necessary for RoHS compliance may also increase costs for manufacturers. 

Read more: What is ‘RoHS Compliant’?

EEE regulated under RoHS includes a wide variety of products separated into eleven categories ranging from large household appliances like dishwashers to medical devices. 

Rules similar to RoHS have spread to other regions, including India, China, South Korea, the UAE, Vietnam, Japan, and the United States, including California and New Jersey. It is important for electronic companies to remain aware of shifting hazardous substance legislation in markets around the world.

2) Buyers of EEE: Consumers

Buyers may be impacted by higher prices of EEE due to RoHS. These increased prices, however, come in exchange for better protection of human health and the environment. 

RoHS often increases the cost of manufacturing EEE, as more testing and regulation is required. These increased manufacturing costs are then reflected in increased prices for consumers.

RoHS requires many EEE manufacturers to use new or different processes in order to remain below the allowable limits for hazardous materials. While these alternative methods and materials do have environmental benefits, they often cost more to implement, especially at first. Increased consumer prices act to offset these costs.

3) Other: The General Public

Ultimately, RoHS affects everyone, as RoHS works to protect the health of our environment and communities. Read more about the environmental impact of RoHS below.

Even the rare person who does not buy or use any electronic equipment may be affected by the negative environmental and health effects of improper disposal of electronic waste, commonly referred to as e-waste. 

Additionally, the restriction of certain levels of hazardous substances protects human health during the use of products. For example, toys whose paint contains lead, a toxic heavy metal, are not RoHS compliant.

Why is RoHS Important?

RoHS’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. While RoHS creates increased costs for sellers and buyers of EEE, the directive also protects the natural environment and human health.

1) The Market

As discussed previously under “Buyers of EEE,” RoHS raises costs for sellers and buyers of EEE alike. 

EEE manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing EEE products and ensuring RoHS compliance may be costly.

Buyers also experience increased prices of electronics in their day to day lives as a result of RoHS.

Of course, these increased prices come hand in hand with safer, more environmentally friendly devices.

2) The Environment

The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

RoHS works in tandem with WEEE, an e-waste directive, to minimize the negative environmental impacts of e-waste. 

Learn more: Waste Electrical and Electronic Equipment (WEEE).

3) Consumer Health

RoHS works to protect consumers of EEE and broader communities from the harmful health effects of hazardous materials. RoHS aims to minimize health impacts caused by EEE in every stage of a product’s lifecycle, from production to use to disposal.

Several materials restricted by RoHS create toxic waste and occupational hazards that negatively impact human health. According to a paper published at Stanford University in 2011, the materials restricted by RoHS can harm not only workers in the production and recycling phases, but also communities located near manufacturing plants (Nimpuno et al. 2011).

RoHS Category 11: The Catchall Category

Understanding Restriction of Hazardous Substances in Electronics

Table of Contents

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. 

The ten hazardous materials included in RoHS must be used in electronics only below specific thresholds. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

Which Products Does RoHS Restrict?

It is important that manufacturers determine whether their product fits the definition of EEE, because all EEE, including smaller components, is subject to RoHS compliance requirements. RoHS defines EEE as: “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” (Directive 2011/65/EU). 

RoHS breaks down restricted EEE into 11 categories. The current categories are the result of one original directive and two additions known as RoHS 2 and 3. Read more: The Difference Between RoHS 1, 2 and 3

The current categories are:

  • Category 1: Large household appliances (eg. refrigerators)
  • Category 2: Small household appliances (eg. hair dryers)
  • Category 3: Computing & communications equipment (eg. computers)
  • Category 4: Consumer electronics  (eg. televisions)
  • Category 5: Lighting (eg. lamps)
  • Category 6: Power tools (eg. electric drills)
  • Category 7: Toys, leisure and sports equipment (eg. electronic dolls)
  • Category 8: Medical devices and equipment, such as in-vitro diagnostic devices, known as IVDs
  • Category 9: Monitoring and control instruments, such as thermostats and smoke detectors
  • Category 10: Automatic dispensers (eg. vending machines)
  • Category 11: Any EEE not covered in the previous ten categories. 

Categories 8 and 9 were added by RoHS 2 (Directive 2011/65/EU), and Category 11 was added by RoHS 3 (Directive EU 2015/863). The other categories were included in the original RoHS directive. As of July 22, 2021 all EEE under every category must comply with RoHS.

What Is Included in RoHS Category 11?

RoHS Category 11 acts as a ‘catchall’ category, as it includes all EEE that is not covered in the previous ten categories. The inclusion of category 11 in RoHS greatly expanded the scope of RoHS, as any product that falls under the definition of EEE must comply with RoHS.

Products that are not included in the previous categories but are added by category 11 include, but are not limited to:

e-bike - rohs category 11
Electric bike covered under RoHS category 11
  • Two-wheeled electric vehicles
  • Electronic nicotine delivery systems (ENDS) such as e-cigarettes and vapes
  • Electrical cables of less than 250 volts
  • Non-finished cables such as cable reels without plugs

This list is not exhaustive, and manufacturers must assess their EEE on a case by case basis to determine if it is within the scope of products regulated by RoHS.

Exemptions

While RoHS Category 11 technically expands RoHS to all EEE, the directive still includes several exemptions.

RoHS Exemption Categories

RoHS includes categories of EEE that are exempt from regulation:

  • Equipment necessary for security, including arms, munitions and material intended for military purposes
  • Equipment designed to be sent into space
  • Large -scale stationary industrial tools
  • Large-scale fixed installations
  • Means of transport for people or goods
  • Non-road mobile machinery exclusively for professional use
  • Active implantable medical devices
  • Permanently installed photovoltaic panels to produce solar energy
  • Equipment designed for business-business research
  • Equipment that is designed to be installed in another type of equipment that is excluded under RoHS.

Any EEE that falls under one of these definitions is not subject to RoHS regulation.

It is important that manufacturers are certain that their non-compliant product is included under one of the exempt categories, as placing a non-exempt, non-RoHS compliant product on the market can result in penalties. 

Restricted Substances with No Safe Substitutions

RoHS also includes exemptions to allow use of hazardous substances only in specific applications, such as in specific types of devices. Manufacturers can apply for these exemptions when no safe alternative to the restricted substance can be found and the product cannot be made otherwise.

For example, the use of hexavalent chromium above 1000ppm is permitted in specific devices, such as spare parts for x-ray systems placed on the EU market.

A full list of substances exempt from restrictions when used in specific applications can be found on the European Chemicals Agency website.

The RoHS directive pushes companies to search for alternative substances and processes that are RoHS compliant, even while using the original, exempted material. If a viable alternative is not found, extension of the exemption is possible.

To encourage innovation, these specific exemptions are temporary and expire on a set date. Manufacturers must remain aware of exemption expiration dates so as not to continue use of a material or application that is no longer exempt.

Impact of RoHS Category 11

Because of its wide scope, category 11 has widely spread impacts. Category 11 greatly expanded the reach of RoHS regulations to include products and manufacturers that may not have been previously affected. 

Increased Price of Production

The inclusion of category 11 may increase prices for EEE, as manufacturers must take steps to ensure RoHS compliance. Manufacturers of this equipment must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing products and ensuring RoHS compliance may be costly.

Buyers of EEE may also face increased prices as a result of increased production costs.

Increased Scientific & Technological Innovation

However, increased costs come hand in hand with increased innovation. RoHS pushes scientific and technological progress in the electronics industry, as EEE products and production processes are redesigned to exclude restricted substances.

Decreased Risk to the Environment and Human Health

By expanding RoHS to all EEE, Category 11 reduces the amount of hazardous substances used in manufacturing of electronics. The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

Exposure to RoHS-restricted substances can also harm human health. By expanding the scope of products included under RoHS, category 11 works to reduce the chance of exposure to harmful substances, both when using EEE products and when EEE products are manufactured or recycled.

Read more about the impact of RoHS: What is RoHS?

RoHS Category 9: Monitoring and Control Equipment

Understanding Restriction of Hazardous Substances in Electronics

Table of Contents

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. 

The ten hazardous materials included in RoHS must be used in electronics only below specific thresholds. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

Which Products Does RoHS Restrict?

It is important that manufacturers determine whether their product fits the definition of EEE, because all EEE, including smaller components, is subject to RoHS compliance requirements. RoHS defines EEE as: “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” (Directive 2011/65/EU). 

RoHS breaks down restricted EEE into 11 categories. The current categories are the result of one original directive and two additions known as RoHS 2 and 3. Read more: The Difference Between RoHS 1, 2 and 3

The current categories are:

  • Category 1: Large household appliances (eg. refrigerators)
  • Category 2: Small household appliances (eg. hair dryers)
  • Category 3: Computing & communications equipment (eg. computers)
  • Category 4: Consumer electronics  (eg. televisions)
  • Category 5: Lighting (eg. lamps)
  • Category 6: Power tools (eg. electric drills)
  • Category 7: Toys, leisure and sports equipment (eg. electronic dolls)
  • Category 8: Medical devices and equipment, such as in-vitro diagnostic devices, known as IVDs
  • Category 9: Monitoring and control instruments, such as thermostats and smoke detectors
  • Category 10: Automatic dispensers (eg. vending machines)
  • Category 11: Any EEE not covered in the previous ten categories. This includes EEE products such as two-wheeled electric vehicles, e-cigarettes and vapes, and electrical cables of less than 250 volts.

Categories 8 and 9 were added by RoHS 2 (Directive 2011/65/EU), and Category 11 was added by RoHS 3 (Directive EU 2015/863). The other categories were included in the original RoHS directive. As of July 22, 2021 all EEE under every category must comply with RoHS.

What Is Included in Category 9?

Category 9 includes all EEE that falls under the definition of monitoring and control equipment. While some categories are limited to household devices, category 9 includes monitoring and control equipment designed for industrial or professional use as well.

Monitoring and control devices are intended to control settings remotely, with some automation. Often, a monitoring and control device will receive information (for example, from a sensor) and make adjustments accordingly. Monitoring devices may also work to alert people to a specific event, such as machinery malfunction or the release of carbon monoxide.

Monitoring and control devices may be used in individual households (for example, a household thermostat) or in professional settings (for example, to monitor or control operations in an industrial factory).

Monitoring and control equipment that falls within the scope of RoHS include, but are not limited to:

x ray machine - rohs category 9
X-ray machine, an example of EEE covered by RoHS Category 9
Source: Medical Equipment MSL
  • Smoke detectors
  • Thermostats (used in buildings or individual rooms)
  • Carbon monoxide detectors
  • Weighing equipment, excluding household scales
  • Light meter
  • pH and conductivity meters, excluding those used for educational purposes
  • Chromatograph
  • Equipment used to calibrate other products
  • Test instruments
  • Portable digital thermometers
  • Surveying instruments
  • Voltmeters and ammeters when they are not used as a component in another product
  • X-ray imager
  • Spectrum analyzers
  • Oscilloscopes
  • Network cable tester
  • Semiconductor parameter tester
  • Signal generator
  • Waveform monitor
  • Optical power meter
  • Roadside traffic warning beacons
  • Traffic lights
  • Veterinary products used for measurement, monitoring or control
  • Burglar alarm systems
  • Laboratory ovens that control temperature
  • Some types of CCTV monitoring equipment if they monitor only (included in category 3 if they display images)

This list is not exhaustive, and manufacturers must assess their EEE on a case by case basis to determine if it is within the scope of products regulated by RoHS.

Exemptions

RoHS includes some general exemptions that may apply to monitoring and control equipment.

Monitoring and Control Equipment that Falls under Other RoHS Exemption Categories

RoHS includes categories of EEE that are exempt from regulation. Monitoring and control equipment that falls under the following exempted categories is also exempt.

  • Equipment necessary for security, including arms, munitions and material intended for military purposes
  • Equipment designed to be sent into space
  • Large -scale stationary industrial tools
  • Large-scale fixed installations
  • Means of transport for people or goods
  • Non-road mobile machinery exclusively for professional use
  • Active implantable medical devices
  • Permanently installed photovoltaic panels to produce solar energy
  • Equipment designed for business-business research
  • Equipment that is designed to be installed in another type of equipment that is excluded under RoHS.

For example, x-ray machines for luggage that are used specifically for national security are exempt from RoHS regulation. Another example is traffic lights that meet the criteria of large-scale fixed installation.

It is important that manufacturers are certain that their non-compliant product is included under one of the exempt categories, as placing a non-exempt, non-RoHS compliant product on the market can result in penalties. 

Read more about RoHS exemptions: What is RoHS Compliant?

Restricted Substances in Monitoring and Control Equipment with No Safe Substitutions

RoHS also includes more focused exemptions for hazardous substances whose use is permitted only in specific applications, such as in specific types of devices. Manufacturers can apply for these exemptions when no safe alternative to the restricted substance can be found and the product cannot be made otherwise.

For example, mercury can be used above 1000ppm if it is being used in high frequency RF switches and relays (which route high frequency signals) in monitoring and control instruments (although mercury is still limited to 20mg of mercury per switch per day). This exemption exists because a safer alternative has not been found.

A full list of substances exempt from restrictions when used in monitoring and control equipment can be found in Annex IV of RoHS 2 (Directive 2011/65/EU).

The RoHS directive pushes companies to search for alternative substances and processes that are RoHS compliant, even while using the original, exempted material. If a viable alternative is not found, extension of the exemption is possible.

To encourage innovation, these specific exemptions are temporary and expire on a set date. Manufacturers must remain aware of exemption expiration dates so as not to continue use of a material or application that is no longer exempt.

Impact of RoHS Category 9

RoHS may have several impacts on monitoring and control equipment included in category 9.

Increased Price of Production

RoHS restrictions on category 9 products may increase prices for monitoring and control equipment, as manufacturers must take steps to ensure RoHS compliance. Manufacturers of this equipment must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing products and ensuring RoHS compliance may be costly.

Buyers of monitoring and control equipment may face increased prices as a result of increased production costs.

Increased Scientific & Technological Innovation

However, increased costs come hand in hand with increased innovation. RoHS pushes scientific and technological progress forward, as monitoring and control equipment and production processes are redesigned to exclude restricted substances.

Read more about the impact of RoHS: What is RoHS?

RoHS Category 8: Medical Devices

Understanding Restriction of Hazardous Substances in Electronics

Table of Contents

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. 

The ten hazardous materials included in RoHS must be used in electronics only below specific thresholds. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

Which Products Does RoHS Restrict?

It is important that manufacturers determine whether their product fits the definition of EEE, because all EEE, including smaller components, is subject to RoHS compliance requirements. RoHS defines EEE as: “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” (Directive 2011/65/EU). 

RoHS breaks down restricted EEE into 11 categories. The current categories are the result of one original directive and two additions known as RoHS 2 and 3. Read more: The Difference Between RoHS 1, 2 and 3

The current categories are:

  • Category 1: Large household appliances (eg. refrigerators)
  • Category 2: Small household appliances (eg. hair dryers)
  • Category 3: Computing & communications equipment (eg. computers)
  • Category 4: Consumer electronics  (eg. televisions)
  • Category 5: Lighting (eg. lamps)
  • Category 6: Power tools (eg. electric drills)
  • Category 7: Toys, leisure and sports equipment (eg. electronic dolls)
  • Category 8: Medical devices and equipment, such as in-vitro diagnostic devices, known as IVDs
  • Category 9: Monitoring and control instruments, such as thermostats and smoke detectors
  • Category 10: Automatic dispensers (eg. vending machines)
  • Category 11: Any EEE not covered in the previous ten categories. This includes EEE products such as two-wheeled electric vehicles, e-cigarettes and vapes, and electrical cables of less than 250 volts.

Categories 8 and 9 were added by RoHS 2 (Directive 2011/65/EU), and Category 11 was added by RoHS 3 (Directive EU 2015/863). The other categories were included in the original RoHS directive. As of July 22, 2021 all EEE under every category must comply with RoHS.

What Is Included in Category 8?

Category 8 includes all EEE that falls under the definition of medical devices and equipment. Also included are in-vitro diagnostic devices (IVDs), which are devices used to test human biological samples like blood or tissue. Note that RoHS does not apply to all medical devices, only electronic and electrical medical devices and equipment.

Medical devices that are within the scope of RoHS include, but are not limited to:

rohs category 8 - medical devices
  • Blood pressure meters
  • Blood analyzers (eg. to measure cholesterol or blood sugar) (IVD)
  • Electrical self-test kits (IVD)
  • Respiration monitors
  • Immunoassay analyzers (IVD)
  • Endoscope
  • Ultrasound
  • CT scanner
  • PET (Positron Emission Tomography)
  • X-ray imaging
  • Medical thermometer
  • Dialysis equipment
  • Medical freezers
  • Gamma camera
  • Intravenous drug infusion pumps
  • Ventilators
  • External defibrillators and pacemakers (not implanted)
  • Hearing aids
  • Surgical microscope
  • Electrical hospital beds
  • Electrical surgical tools
  • Medical lasers
  • ECG
  • Electrical anaesthesia equipment
  • Electrical operating theater equipment
  • Electrical dental equipment

This list is not exhaustive, and manufacturers must assess their EEE on a case by case basis to determine if it is within the scope of products regulated by RoHS.

Exemptions to RoHS Category 8

RoHS includes some general exemptions that may apply to medical equipment. There are also several exemptions that are specific to medical equipment.

Active Implantable Medical Devices

pacemaker - category 8 rohs
Cardiac pacemaker
Source: Steven Fruitsmaak

Any active implantable medical devices (AIMDs) are not subject to RoHS regulation. AIMDs are devices that are implanted in the human body, intended to remain in place after the procedure, and dependent on an energy source outside the human body to function.

Active Implantable Medical Devices include, but are not limited to:

  • Cardiac pacemakers
  • Neurostimulator systems
  • Brachytherapy systems
  • Cochlear implants
  • Glucose monitors
  • Defibrillators
  • Leads, electrodes, and adaptors for pulse generators
  • Ventricular Assist Devices
  • Infusion pumps
  • Micro Electro-Mechanical Systems (MEMS)

Further information on the definition of AIMDs can be found in EU Regulation 2017/745.

Read more about RoHS exemptions: What is RoHS Compliant?

Medical Devices that Fall under Other RoHS Exemption Categories

RoHS includes categories of EEE that are exempt from regulation. Medical devices that fall under the following exempted categories are also exempt.

  • Equipment necessary for security, including arms, munitions and material intended for military purposes
  • Equipment designed to be sent into space
  • Large -scale stationary industrial tools
  • Large-scale fixed installations
  • Means of transport for people or goods
  • Non-road mobile machinery exclusively for professional use
  • Active implantable medical devices
  • Permanently installed photovoltaic panels to produce solar energy
  • Equipment designed for business-business research
  • Equipment that is designed to be installed in another type of equipment that is excluded under RoHS.

Examples that may be considered exempt under one of the above categories include electric scooters used by disabled persons, as these may be considered a form of transport. Another example is a proton therapy facility that includes a particle accelerator, as this may be considered a large-scale fixed installation. 

It is important that manufacturers are certain that their non-compliant product is included under one of the exempt categories, as placing a non-exempt, non-RoHS compliant product on the market can result in penalties. Read more: RoHS Noncompliance Penalties

Hazardous Substance Exemptions for Specific Types of Medical Devices

RoHS also includes more focused exemptions for hazardous substances that may only be used in specific applications, such as in specific medical devices. For example, while lead is restricted above 1000ppm in all EEE, it is allowed to be used above this level as lead bearings in X-ray tubes.

A full list of substances exempt from restrictions when used in specific medical applications can be found in Annex IV of RoHS 2 (Directive 2011/65/EU).

The directive pushes companies to search for alternative substances and processes that are RoHS compliant, even while using the original, exempted material. If a viable alternative is not found, extension of the exemption is possible.

To encourage innovation, these specific exemptions are temporary and expire on a set date. Manufacturers must remain aware of exemption expiration dates so as not to continue use of a material or application that is no longer exempt.

Medical Devices with No Safe Substitutions

In order to be RoHS compliant, medical devices must use substitutes for restricted hazardous materials. However, these substitutions must be deemed safe before the medical device can be placed on the market. If substitutions are deemed unsafe, then the manufacturer can apply for an exemption. If the exemption is granted, the manufacturer can continue using substances restricted by RoHS above allowable limits.

While manufacturers can apply for exemptions for any substance for which there is no safe alternative, medical devices are mentioned specifically in the directive, as they must undergo a more extensive review process.

RoHS states that placing a medical device on the market requires a conformity assessment procedure according to several other EU directives concerning medical devices (Council Directive 93/42/EEC and Directive 98/79/EC). Through this process, a notified body (an official conformity assessment organization) must certify that the potential substitute for a hazardous substance also has negative socioeconomic, health, and consumer safety impacts. The manufacturer can then apply for an exemption for that medical device. (Note: The notified body is appointed by the Member State, and varies across countries.)

These exemptions are also subject to expiration dates, so manufacturers must remain aware of changing exemptions.

Impact of RoHS Category 8

RoHS may have several impacts on medical devices included in category 8.

Increased Price of Production

RoHS restrictions on medical devices may increase prices for medical devices, as manufacturers must take steps to ensure RoHS compliance. Electrical medical device manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing electrical medical devices and ensuring RoHS compliance may be costly.

Increased Scientific & Technological Innovation

However, increased costs come hand in hand with increased innovation. RoHS pushes scientific and technological progress in the medical field forward, as medical devices and production processes are redesigned to exclude restricted substances.

Shifting Technologies for Patients

Lastly, RoHS may impact hospitals, doctors, and patients who rely on electronic medical devices. Costs may increase initially as a result of increased manufacturing and compliance costs. Additionally, the use of new devices or technologies may be required if manufacturers create new solutions to comply with RoHS.

However, RoHS will not make it difficult for patients to get necessary medical devices. The RoHS exemption rules described above were created to ensure that if no safe substitutions are available, no one goes without a necessary device, even if it uses higher than allowed restricted substances.

Read more about the impact of RoHS: What is RoHS?

Exemptions from the Waste Electrical and Electronic Equipment (WEEE) Directive

Table of Contents

What Is WEEE?

WEEE, Waste Electrical and Electronic Equipment Regulation, is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use. Manufacturers of EEE must be compliant with WEEE.

The WEEE directive was created to address the negative environmental and human health impacts caused by waste electrical and electronic equipment (WEEE), also known as e-waste, and to encourage proper recycling and re-use of EEE. 

Since WEEE’s creation in 2002, the directive has been updated to expand its scope.

Original WEEE Directive – The original directive, Directive 2002/96/EU, includes requirements companies must follow to comply with WEEE, and includes eleven categories of EEE regulated under WEEE.

WEEE Recast – The directive was updated in 2012, when Directive 2012/19/EU recategorized EEE into six categories

2018 Expansion – The scope of products regulated under WEEE was expanded in 2018 to include all EEE.

Objectives of WEEE

The overall goals of the WEEE directive are to reduce the negative environmental and health impacts of e-waste disposal and to increase sustainable use of resources. 

The directive works to:

  • Reduce the amount of e-waste that ends up in landfills
  • Encourage redesign of EEE so that it can be dismantled and properly disposed of
  • Increase re-use of WEEE and its components and materials

To achieve these goals, WEEE requires Member States to set specific targets for the amount (by weight) of EEE collected, recycled, and recovered. These targets differ by country.

All producers of EEE must comply with WEEE requirements. Read more: WEEE Compliance

Which Products Are Restricted by WEEE?

As of 2018, all EEE is included under WEEE (except for those specifically exempted, listed below), as every EEE device becomes WEEE at the end of its use. 

EEE is defined as “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” (Article 3 of Directive 2012/19/EU).

EEE subject to WEEE regulation is classified under six categories:

  1. Temperature exchange equipment (eg. refrigerators and freezers)
  2. Screens, monitors, and equipment containing screens with a surface larger than 100 cm2 (eg. televisions, laptops, LCD photo frames)
  3. Lamps (Straight fluorescent lamps, Compact fluorescent lamps, Fluorescent lamps, High intensity discharge lamps – including pressure sodium lamps and metal halide lamps, Low pressure sodium lamps, LED)
  4. Large equipment (any dimension larger than 50cm) (eg. washing machines, large copiers and printers)
  5. Small equipment (no dimension larger than 50cm) (eg. vacuum cleaners, microwaves, musical instruments)
  6. Small IT and telecommunication equipment (eg. cell phones, GPS devices)

Which Products Are Exempt from WEEE?

The Directive exempts several EEE types from WEEE requirements, including:

  1. Equipment that’s necessary to national security and defense, including arms, munitions and war material intended for specifically military purposes
  2. Equipment that is crucial to the functioning of another type of EEE exempt from WEEE
  3. Filament bulbs
  4. Equipment designed to be sent into space
  5. Large-scale stationary industrial tools
  6. Large-scale fixed installations, except any equipment which is not specifically designed and installed as part of those installations (eg. HVAC or robotic equipment)
  7. Vehicles used to transport goods or people, excluding electric two-wheel vehicles
  8. Non-road mobile machinery exclusively for professional use (eg. construction machinery)
  9. Equipment specifically designed solely for the purposes of research and development that is only made available on a business-to-business basis
  10. Active implantable medical devices, as well as medical devices and in vitro diagnostic medical devices that are considered ‘infective’ (capable of causing infection) before their end-of-life

This list of exempted EEE is mainly the same as the RoHS directive’s list of exempted products, although WEEE does not exempt photovoltaic panels. Read more: RoHS vs. REACH vs. WEEE

These exemptions are subject to change with the implementation of new regulations, should that occur. As stated in the WEEE directive, the goal of the regulation is to remain in line with scientific progress. As more substitutions for hazardous materials contained in these exempted products are found, the list of products exempted from WEEE regulation may change. Producers must remain aware of shifting exemptions so they can ensure full compliance with WEEE.

A Guide to Compliance with the Waste Electrical and Electronic Equipment (WEEE) Directive

Table of Contents

What Is WEEE?

WEEE, Waste Electrical and Electronic Equipment Regulation, is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use. Manufacturers of EEE must be compliant with WEEE.

The WEEE directive was created to address the negative environmental and human health impacts caused by waste electrical and electronic equipment (WEEE), also known as e-waste, and to encourage proper recycling and re-use of EEE. 

Since WEEE’s creation in 2002, the directive has been updated to expand its scope.

Original WEEE Directive – The original directive, Directive 2002/96/EU, includes requirements companies must follow to comply with WEEE, and includes eleven categories of EEE regulated under WEEE.

WEEE Recast – The directive was updated in 2012, when Directive 2012/19/EU recategorized EEE into six categories

2018 Expansion – The scope of products regulated under WEEE was expanded in 2018 to include all EEE.

Objectives of WEEE

The overall goals of the WEEE directive are to reduce the negative environmental and health impacts of e-waste disposal and to increase sustainable use of resources. 

The directive works to:

  • Reduce the amount of e-waste that ends up in landfills
  • Encourage redesign of EEE so that it can be dismantled and properly disposed of
  • Increase re-use of WEEE and its components and materials

To achieve these goals, WEEE requires Member States to set specific targets for the amount (by weight) of EEE collected, recycled, and recovered. These targets differ by country.

Read more: What is WEEE?

Which Products Are Restricted by WEEE?

As of 2018, all EEE is included under WEEE, as every EEE device becomes WEEE at the end of its use. EEE is defined as “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” (Article 3 of Directive 2012/19/EU).

EEE subject to WEEE regulation is classified under six categories:

  1. Temperature exchange equipment
  2. Screens, monitors, and equipment containing screens with a surface larger than 100 cm2.
  3. Lamps
  4. Large equipment (any dimension larger than 50cm)
  5. Small equipment (no dimension larger than 50cm)
  6. Small IT and telecommunication equipment

Several specific types of EEE are exempt from WEEE regulation. Read more: WEEE Exemptions.

Who Has to Ensure WEEE Compliance?

All producers of EEE must comply with WEEE requirements. The directive defines producers as anyone who:

  • Manufactures and sells EEE under his/her own brand
  • Resells EEE produced by other suppliers under his/her own brand
  • Imports or exports EEE into an EU Member State
  • Sells EEE by “distance” (for example, over the internet) to Member States, even if this seller is in a different country.

WEEE places the responsibility of compliance on producers, not customers. While customers should still recycle their e-waste, they have no legal obligation.

Steps to Comply with WEEE

There are several steps producers must take to ensure they comply with WEEE.

1. Register with the Appropriate Authority

Producers must register and report the volume of EEE placed on the EU market to the correct governing body (which varies by country).

Producers of EEE must meet the recycling targets determined by each Member State. Reporting the volume of EEE placed on the market allows Member States to track WEEE compliance.

A list of information to be included in the registration can be found in Annex X of the WEEE directive (Directive 2012/19/EU).

EEE producers that place more than 5 tonnes of EEE on the EU market must register with a WEEE compliance scheme, often referred to as a Producer Compliance Scheme (PCS). The producer pays a fee to the PCS, and in turn, the PCS helps ensure proper collection and recycling of EEE.

Producers that place less than 5 tonnes of EEE on the market can register with a PCS or simply register with the local Environmental Agency.

The amount of all WEEE collected must also be reported annually.

2. Provide Information to Customers

Proper labeling and information helps customers to properly dispose of their EEE products. WEEE requires that all compliant EEE be marked with the “WEEE symbol,” a recycling bin that is crossed out. If the product is too small to show the symbol, then it should be included in the device’s user manual. 

In some countries, the following information is also required:

  • Information on which take back recycling service the producer provides
  • Information on how the customer can reuse or recycle the product
  • Why WEEE must be separated from other types of waste
  • The negative impacts of not recycling EEE

3. Provide Information to Recyclers

Producers must provide recycling processors with the necessary information on how to recycle the EEE product or prepare the product to be reused. As many EEE products are composed of multiple materials, it is important for producers to provide information to recyclers on how to properly dispose of all the product’s components as well.

Information to be provided to recyclers includes:

  • Tools needed to dismantle the product
  • How to dismantle the product
  • How to remove batteries
  • How to process the metals included to be reused or recycled
  • Recommendations on how materials used in the EEE should be recovered or reused

4. Create an E-waste Recycling Program

Producers must offer their customers a method to recycle EEE at the end of its lifecycle, which includes creating or financing a system for customers to recycle old EEE. These programs are often referred to as Compliance and Take Back schemes. 

The take back scheme may entail a collection service or a drop-off location for used electronics. The recycling program must be free of charge to the customer. The producer can collect WEEE itself or can contract a collection company.

Producers must report the weight of all WEEE recycled through their take back system to the relevant authority. This can be done directly by the producers, or through the collection company. This reporting helps governing bodies track the success of WEEE, as they can compare the amount of EEE a producer puts on the market to how much of it gets recycled.

Penalties of WEEE Noncompliance

Manufacturers will face penalties for noncompliance with RoHS. These penalties may include financial and legal consequences, as well as the larger costs associated with noncompliance.

Financial Consequences

Manufacturers may face fines for placing EEE on the market that does not comply with the WEEE directive. The amount of the fine differs by member state, with some countries having higher maximum fines than others. 

Producers that do not comply with WEEE may also face legal consequences such as criminal prosecution or even imprisonment. This legal process is time consuming and costly, and can also have negative impacts on the brand’s reputation. 

Larger Costs

Failure to comply with WEEE allows for harmful e-waste to enter landfills and create negative impacts on the environment and human health. WEEE works to protect against environmental harm and disease by keeping e-waste out of landfills, and ensuring products are recycled safely and effectively.

As of January 2021, Regulation (EU) 2019/1020 created stronger controls to enforce the WEEE directive and other EU laws. The new Regulation increases penalties for noncompliance and creates more stringent enforcement. The Regulation is particularly focused on making sure enforcement is extended to EEE sold online. The Regulation also aims to increase cooperation between Member State market surveillance authorities in order to let fewer noncompliant producers fall through the cracks.

What is WEEE? Understanding The Waste Electrical and Electronic Equipment Directive

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What Is WEEE?

WEEE, Waste Electrical and Electronic Equipment Regulation, is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use.

e-waste - what is WEEE directive
Electronic waste
Source: Muntaka Chasant

The United Nations Environment Program estimates that by 2030, over 74 million metric tonnes of WEEE, also known as e-waste, will be discarded globally (Forti et al. 2020). This represents a doubling in under two decades. 

The WEEE directive was created to address the negative environmental and human health impacts caused by e-waste, and to encourage proper recycling and re-use of EEE. 

Since WEEE’s creation in 2002, the directive has been updated to expand its scope.

Original WEEE Directive – The original directive, Directive 2002/96/EU, includes requirements companies must follow to comply with WEEE, and includes eleven categories of EEE regulated under WEEE.

WEEE Recast – The directive was updated in 2012, when Directive 2012/19/EU recategorized EEE into six categories

2018 Expansion – The scope of products regulated under WEEE was expanded in 2018 to include all EEE.

Objectives of WEEE

The overall goals of the WEEE directive are to reduce the negative environmental and health impacts of e-waste disposal and to increase sustainable use of resources. 

The directive works to:

  • Reduce the amount of e-waste that ends up in landfills
  • Encourage redesign of EEE so that it can be dismantled and properly disposed of
  • Increase re-use of WEEE and its components and materials

To achieve these goals, WEEE requires Member States to set specific targets for the amount (by weight) of EEE collected, recycled, and recovered. These targets differ by country.

Which Products Are Restricted by WEEE?

what is weee - electronics

As of 2018, all EEE is included under WEEE, as every EEE device becomes WEEE at the end of its use. EEE is defined as “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” (Article 3 of Directive 2012/19/EU).

EEE subject to WEEE regulation is classified under six categories:

  1. Temperature exchange equipment
  2. Screens, monitors, and equipment containing screens with a surface larger than 100 cm2.
  3. Lamps
  4. Large equipment (any dimension larger than 50cm)
  5. Small equipment (no dimension larger than 50cm)
  6. Small IT and telecommunication equipment

Several specific types of EEE are exempt from WEEE regulation. Read more: WEEE Exemptions

Who Does WEEE Impact?

WEEE has widespread impact, but directly affects producers and buyers of EEE.

1) Producers of EEE: Manufacturers, Importers, Distributors, and Distance Sellers

All producers of EEE must comply with WEEE requirements. The directive defines producers as anyone who:

  • Manufactures and sells EEE under his/her own brand
  • Resells EEE produced by other suppliers under his/her own brand
  • Imports or exports EEE into an EU Member State
  • Sells EEE by “distance” (for example, over the internet) to Member States, even if this seller is in a different country.

Compliance Requirements for Producers

The directive aims to place the responsibility of proper recycling of WEEE on producers. Under WEEE, producers must:

  1. Register and report the volume of EEE placed on the EU market to the correct governing body (which varies by country).

Producers of EEE must meet the recycling targets determined by each Member State. Reporting the volume of EEE placed on the market allows Member States to track WEEE compliance.

EEE producers that place more than 5 tonnes of EEE on the EU market must register with a WEEE compliance scheme, an organization that helps ensure proper collection and recycling of EEE. Producers that place less than 5 tonnes of EEE on the market must register with the local Environmental Agency.

  1. Offer their customers a method to recycle EEE at the end of its lifecycle.

Producers must create or finance a system for customers to recycle old EEE. This may entail a collection service or a drop-off location. This recycling program must be free of charge to the customer.

  1. Provide recycling services with the necessary information on how to recycle the EEE product or prepare the product to be re-used.

As many EEE products are composed of multiple materials, it is important for producers to provide information to recyclers on how to properly dispose of the product and its components.

  1. Label products with the “wheelie bin” symbol.

WEEE requires that all compliant EEE be marked with the “WEEE symbol,” a recycling bin that is crossed out. This helps customers to properly dispose of their EEE products.

Read more: WEEE Compliance

Prices may increase for producers as a result of these requirements, such as compliance scheme fees or the creation of new programs. 

However, WEEE allows companies to save costs on materials, as companies can begin to use reused, and thus cheaper, materials. The use of recycled materials also works against resource scarcity and supply chain issues, which can save companies money in the long run.

2) Buyers of EEE: Consumers

Most individuals today buy and use EEE, as do many businesses, and are thus impacted by WEEE.

Buyers may face higher prices for their electronic devices due to WEEE. As producers pay increased costs to produce WEEE-compliant products and recycling programs, consumers often offset these costs by paying more for their devices. However, all disposal programs offered by producers must be free of charge for the buyer. 

While consumers do not face the same legal requirements as producers, consumers still play a role in ensuring proper disposal of WEEE. It is important that consumers avoid throwing used electronics in the landfill, and rather, take steps to ensure proper disposal, such as returning the EEE to a producer.

Proper disposal of EEE also helps keep sensitive data stored on a device such as a phone or computer secure. If a consumer wishes to protect their information, the process laid out by WEEE for proper disposal is a crucial step.

3) Other: The General Public

Ultimately, WEEE affects everyone, as the directive works to protect the health of our environment and communities. WEEE helps keep dangerous materials out of the air, soil, and water. Read more about the environmental and health impacts of WEEE below.

The WEEE directive benefits the general public as it allows for increased resource efficiency. WEEE ensures that more products are created using reusable and recycled materials and components. 

This resource efficiency also pushes innovation in EEE products. In order to use recycled materials or to allow for proper disposal, producers must create new design processes for EEE.

Why is WEEE Important?

In the long run, WEEE will help create more sustainable products and a healthier environment. WEEE’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. While WEEE creates increased costs for sellers and buyers of EEE, the directive also increases sustainability and protects the natural environment and human health.

1) The Market

As discussed previously under “Buyers of EEE,” WEEE raises costs for producers and buyers of EEE alike. 

EEE producers must create or finance recycling programs for their consumers. Additionally, steps to ensure WEEE compliance may be costly.

Buyers also experience increased prices of electronics in their day to day lives as a result of WEEE.

However, these increased prices come hand in hand with a more sustainable economy. A central goal of WEEE is to create a circular economy, an economy in which industry reuses and recycles raw materials. The circular economy minimizes waste and addresses resource scarcity in a world of finite raw materials.

2) The Environment

Many electronic devices contain materials such as heavy metals and chemicals that have large environmental consequences upon becoming e-waste. Improper disposal creates environmental pollution, destroys habitats, and impacts the health of other species.

When WEEE is improperly disposed of, such as through shredding or melting, toxins and particles are released into the air that can cause air pollution. This pollution may have larger environmental consequences, and can damage human lungs.

Additionally, improper disposal of WEEE allows hazardous materials to enter groundwater and soil. This contamination has widespread effects, as toxic materials may impact crops or drinking water, leading to negative health outcomes for animals and humans. Chemicals found in WEEE can also cause acidification of rivers and other waterways.

Lastly, WEEE takes up land area when it sits in landfills. By increasing proper recycling measures and encouraging reuse of materials, the WEEE directive helps reduce the amount of space landfills use globally. 

3) Consumer Health

The WEEE directive works to reduce risks to human health caused by exposure to e-waste. 

E-waste can contain toxic substances such as lead, mercury, sulfur and cadmium. If these materials are not disposed of properly, the buildup of contamination in water and soil can cause health problems.

A 2013 WHO study found that exposure to e-waste can cause severe health impacts, including adverse birth outcomes, changes in thyroid function and cell function and decreased lung function (Grant et al. 2013).

WEEE works in tandem with the RoHS directive, which restricts the use of hazardous materials in EEE manufacturing. If fewer hazardous materials are used in manufacturing electronic devices, then, when those products become e-waste, negative impacts are lower.

Read more: RoHS vs. WEEE

RoHS in China: Understanding Global Restriction of Hazardous Substances in Electronics

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What Is China RoHS?

RoHS stands for Restriction of Hazardous Substances and restricts the use of several hazardous materials in electronic and electrical equipment. The RoHS directive was originally issued in the European Union but similar laws have been passed in other countries, including China.

China RoHS, also known as Administrative Measure on the Control of Pollution Caused by Electronic Information Products (EIP), works to reduce the negative environmental and health effects of hazardous substances by restricting their use in electronics.

china flag - rohs china

All electronic products sold on the Chinese market, including imported products, must comply with China-RoHS.

China RoHS 1 – The original legislation included six materials deemed to be hazardous to human health and the environment. 

China RoHS 2 – The original legislation was superseded by China RoHS 2 or Restriction of the Use of Hazardous Substances in Electrical and Electronic Products Regulation. China RoHS 2 expanded the scope of the regulation to include more devices, described below.

Which Hazardous Substances Are Restricted by China RoHS?

China RoHS restricts six hazardous materials that must be used below a specific threshold. Each material except cadmium may only be used in amounts lower than 1000ppm. Cadmium’s limit is 100ppm.

The materials include:

Products Restricted by China RoHS

The original China RoHS included only products listed as an Electronic Information Product (EIP).

Any listed products require an assessment of conformity with China RoHS. Products include:

  1. Refrigerators
  2. Air conditioners
  3. Washing machines
  4. Electric water heaters
  5. Printers
  6. Photocopiers
  7. Fax machines
  8. Televisions
  9. Monitors
  10. Microcomputers
  11. Mobile communication devices
  12. Telephones

The passage of China RoHS 2 greatly expanded the scope of the legislation to include any product that falls under the definition of electronics. This expansion worked to bring China RoHS regulations in line with the EU’s RoHS 3, which also expanded the categories of products restricted by RoHS to include all electrical and electronic equipment (EEE).

Compliance with China RoHS

Who is Responsible for Compliance?

Any manufacturer, importer, or distributor of electronic and electrical products sold in China must be compliant with China RoHS. Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

It is the manufacturer’s responsibility to ensure their product complies with China RoHS. 

Steps for Compliance with China RoHS

Manufacturers of electronic products have two options to prove their compliance: self-declaration and/or third-party testing.

  1. Self Declaration: Similar to the EU RoHS directive, companies that manufacture electronic products must create a declaration of conformity. This declaration is a legal document that states the manufacturer has taken all the necessary steps to comply with China RoHS.

The manufacturer must sign the declaration before the product is put on the market. By doing so, the manufacturer takes responsibility for ensuring compliance.

  1. Third-party Testing: The product and its components are tested by an outside laboratory in China. This step also involves a factory inspection. After the testing process, the certification must be approved by an authority agency. The manufacturing company will then receive a China RoHS Certificate that is valid for five years.

The testing process also includes follow-up testing and inspection, often at least once a year, to ensure continued compliance.

China RoHS Labeling Requirements

Products that are compliant with China RoHS are marked with a different label than products that do not comply. 

efup label - china rohs

Only products that will be used by an end-user, and not components, must be labeled. However, suppliers of components must pass along the relevant compliance information to manufacturers.

Products that contain restricted substances below the allowable thresholds (and are therefore China RoHS compliant) receive a green label, sometimes referred to as a Green eLabel. The green label is optional.

Products that contain toxic substances above the allowed thresholds must be marked with an orange label. These are called EFUP labels, as they include the product’s environmental protection use period (EFUP). The EFUP is the number of years the product can be used safely before hazardous substances begin to leak out.

The orange EFUP label features a circle with the EFUP number inside. For example, a product that will become unsafe in fifty years will feature a large number “50” in the label.

Why is RoHS Important?

RoHS’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. While China RoHS creates increased costs for sellers and buyers of electronics, the law also protects the natural environment and human health.

1) The Market

RoHS raises costs for sellers and buyers of electronic products alike. 

Manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, hiring a third-party laboratory to ensure RoHS compliance may be costly. This is equally true for manufacturers in China or who are importing their products into China.

Buyers also experience increased prices of electronics in their day to day lives as a result of China RoHS.

Of course, these increased prices come hand in hand with safer, more environmentally friendly devices.

2) The Environment

The restricted materials listed in China RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of electronics that can be recycled safely.

RoHS works in tandem with China’s recycling law, ​​Regulations for the Administration of the Recovery and Disposal of Waste Electric and Electronic Products (Order No. 551). This law is concerned with the proper recycling of waste electric and electronic products (WEEP). China’s WEEEP law is very similar to the EU’s WEEE law.

Read more: What is WEEE?

3) Consumer Health

RoHS works to protect consumers of EEE and broader communities from the harmful health effects of hazardous materials. RoHS aims to minimize health impacts caused by EEE in every stage of a product’s lifecycle, from production to use to disposal.

Several materials restricted by RoHS create toxic waste and occupational hazards that negatively impact human health. Restricted substances not only harm workers in production and recycling phases, but also can create health concerns for users of end products.

Comparison Table: How Does China RoHS Differ from EU RoHS?

ChinaEuropean Union
Restricted SubstancesCadmium (Cd), Mercury (Hg), Lead (Pb), Hexavalent Chromium (Cr VI), Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE)All six restricted in China, plus four more: Bis(2-Ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), Diisobutyl phthalate (DIBP)
Scope: Restricted ProductsAnything that falls under the definition of an electronic productAnything that falls under the definition of electrical and electronic equipment (EEE)
LabelingProducts using restricted substances below the threshold may affix a green label to the outermost packaging. Products using restricted substances above allowed thresholds must affix an orange EFUP label to the outermost packaging.A CE marking is required on all RoHS-compliant products.

Read more: What is the CE Marking?
ExemptionsNo exemptions exist for any products included in the list of Electronic Information Products (EIP) listed above.Exemptions exist for several types of products, such as active implantable medical devices. A full list is available in Article 2 of RoHS 2 (Directive 2011/65/EU).
Conformity: Proving ComplianceCompliance with China RoHS may be self-declared or confirmed by a Chinese laboratoryCompliance with EU RoHS can be self-declared

Read more about RoHS in the EU: What is RoHS?

Rules similar to RoHS have spread to many other regions, including India, South Korea, the UAE, Vietnam, Japan, and the United States including California and New Jersey. It is important for electronic companies to remain aware of shifting hazardous substance legislation in markets around the world.