RoHS 1 vs. RoHS 2 vs. RoHS 3: A Comparison

Restriction of Hazardous Substances: The Difference Between RoHS 1 vs. RoHS 2 vs. RoHS 3

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). 

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, RoHS 1, and two additions known as RoHS 2 and 3. This article will describe RoHS 1 vs RoHS 2 vs RoHS 3, helping you to understand the similarities, differences, and regulatory requirements for each.

RoHS regulation has evolved over the years to fit ever-increasing concerns about the effects of toxic materials. Each RoHS directive works to restrict the use of hazardous substances in order to protect both the environment and human health.

What is EEE?

It is important that manufacturers, importers and distributors determine whether their product fits the definition of EEE, because all EEE sold in the EU is subject to RoHS compliance requirements. 

All three directives define EEE in the same way: “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 2002/95/EC).

Who Is Responsible for Compliance?

All three iterations of the RoHS directive are directed at any manufacturer, importer, or distributor of electronic and electrical equipment (EEE) sold in the EU. Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

Under RoHS, it is the manufacturer’s responsibility to ensure their product complies with RoHS. 

Read more: What is ‘RoHS Compliant’?

RoHS 1: Directive 2002/95/EC

The original directive RoHS 1 was issued in 2002, and limits the use of six materials within EEE deemed to be hazardous to human health and the environment. 

Why Was RoHS 1 Created?

In 2002, the European Council commissioned research on hazardous substances found in electronics. These substances not only proved to be harmful to human health, but also caused environmental problems when EEE was disposed of.

As efforts to increase recycling of electronic products started in the EU, regulators found that materials such as cadmium and mercury could not be recycled safely, even if proper recycling methods were used. The RoHS directive’s method to keep these substances out of landfill is to simply restrict their use in products in the first place.

RoHS 1 aims to reduce risks to human health and the environment by taking hazardous substances out of electronic products, and instead, requiring the use of alternative, safer materials. 

Restricted Substances and Products Under RoHS 1

Manufacturers of EEE products must not exceed 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:

  • Cadmium (Cd)
  • Mercury (Hg)
  • Lead (Pb)
  • Hexavalent Chromium (Cr VI)
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE)

RoHS 1 focused on eight categories of EEE. The categories were taken from the original WEEE directive, a related directive focused on EEE recycling. EEE categories regulated under RoHS 1 include:

  • 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 10: Automatic dispensers (eg. vending machines)

RoHS 2: Directive 2011/65/EU

In 2011, the original directive was superseded by Directive 2011/65/EU, known as RoHS 2 or RoHS Recast. RoHS 2 created additional categories of EEE subject to regulation and created new compliance requirements for manufacturers and importers.

Why Was RoHS 2 Created?

As scientific research progresses, more manufacturing substances are found to be hazardous. However, new substitutes for restricted substances are also discovered. RoHS 1 takes scientific progress into account by mandating the directive be updated, if necessary, in order to better address and implement new manufacturing methods and materials. 

RoHS 2 was created to ensure that the RoHS directive was up to date with scientific progress made since the passage of RoHS 1. This included expanding the scope of the restricted products and creating new compliance requirements.

RoHS 2 was also created to bring the RoHS directive better in line with other environmental regulations in the EU, such as WEEE and REACH. 

Restricted Products Under RoHS 2

All categories in RoHS 1 are also regulated under RoHS 2, in addition to two new categories of EEE added by RoHS 2. This includes:

  • Category 8: Medical devices and equipment, such as in-vitro diagnostic devices, known as IVDs. Read more: RoHS Category 8
  • Category 9: Monitoring and control instruments, such as thermostats and smoke detectors. Read more: RoHS Category 9

RoHS 2 also included a list of product types that are exempt from compliance. For example, military equipment and active implantable medical devices are not restricted by RoHS. Exempt products are listed in Article 2 of RoHS 2 (Directive 2011/65/EU)

Read more about RoHS exemptions: What is ‘RoHS Compliant’?

Compliance Requirements under RoHS 2

RoHS 2 created new compliance requirements for manufacturers and importers of EEE. This includes a declaration of conformity and a CE marking.

The declaration of conformity (sometimes known as a certificate of compliance) is the final step in RoHS compliance. This is a legal document that contains information about the product and the measures taken to ensure compliance. The manufacturer signs the declaration of conformity before the product is put on the market to certify that the product is RoHS compliant. 

The CE marking is a visible mark on the product that demonstrates that the manufacturer has taken the proper steps to ensure the product meets RoHS requirements. 

RoHS 3: Directive EU 2015/863

RoHS 3 was passed in 2015 as an amendment to RoHS 2. As RoHS 3 is merely an amendment, companies that are RoHS compliant must comply with all of RoHS 2 as well as updates included in RoHS 3. RoHS 3 added new types of restricted products, as well as four new hazardous substances.

Why Was RoHS 3 Created?

The main purpose of RoHS 3’s creation was to add a new class of restricted chemicals, phthalates. The amendment was passed partly in response to research showing that these chemicals, mainly used as insulation plasticizers, can have serious adverse health and environmental impacts.

Restricted Substances under RoHS 3

In addition to the previously restricted substances, RoHS 3 adds four phthalates. These substances may not be used in EEE at amounts above 1000 ppm:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP) 

Restricted Products under RoHS 3

RoHS 3 greatly expanded the scope of the RoHS directive by introducing a new category of restricted EEE products that serves as a “catch all” category. 

Category 11 includes any EEE not covered in the previous ten categories. For example, this includes EEE products such as two-wheeled electric vehicles, e-cigarettes and vapes, and electrical cables of less than 250 volts.

Read more: RoHS Category 11

Global RoHS Legislation

While RoHS 1, 2, and 3 apply only in the EU and its Member States, rules similar to RoHS have spread to other regions, including India, the UAE, China, South Korea, Vietnam, Japan, and U.S. states California and New Jersey. It is important for electronic companies to remain aware of shifting hazardous substance legislation in markets around the world.

Why Is RoHS Important?

RoHS has important impacts on the market, and also helps reduce environmental and health risks resulting from hazardous substances.

The Market: Increased Costs

RoHS increases costs for both sellers and buyers of EEE. All three RoHS directives increase costs for sellers due to new manufacturing and testing requirements necessary for compliance. Buyers often face higher prices for their devices as a result of these increased costs of manufacturing.

The Environment: Reduced Pollution

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.

Human Health: Reduced Disease

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 occupational hazards during manufacturing and toxic waste upon product disposal, both of which negatively impact human health. 

Additionally, 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.

Now that you know the difference between RoHS 1 vs. RoHS 2 vs. RoHS 3, learn more about the impact of RoHS: What is RoHS?

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