Preparing for ROHS 2019 Compliance (Part 1 - Sourcing)

Changes to Restriction of Hazardous Substances (RoHS) Effective 22 July 2019

18 December 2018

Restriction of Hazardous Substances (RoHS), also known as Directive 2002/95/EC, originated in the European Union and restricts the use of specific hazardous materials found in electrical and electronic products. RoHS 2, or the Recast RoHS 2 Directive 2011/65/EU, was published in July 2011 by the European Commission (effective 22 July 2019, RoHS 2 will be superseded by (EU) 2015/863).

All businesses that sell applicable electronic products, sub-assemblies or components directly to EU countries, or sell to resellers, distributors or integrators that are intended for the EU market, must comply with RoHS requirements if they utilize any of the restricted materials. As per RoHS 2019, four new phthalates will be added to the substances list for RoHS compliance:

  1. Bis(2-Ethylhexyl) phthalate (DEHP)
  2. Benzyl butyl phthalate (BBP)
  3. Dibutyl phthalate (DBP)
  4. Diisobutyl phthalate (DIBP)

As per the current requirements for RoHS, the maximum permitted concentration will be 0.1% w/w, except for Cadmium which has a maximum concentration of 0.01% w/w.

In the coming weeks and months, as part of a 10-part series on RoHS and RoHS Compliance, Intertek will publish additional blogs, which will identify and highlight some of the challenges currently faced by companies as they attempt to analyze their Bill of Materials (BOM) for substance compliance.

Part 1 – Sourcing

"It's not where you buy the parts for your products, what matters is what you buy"

Typically, when a finished product has its' BOM reviews, from a substance compliance perspective, many of the line items which are combined to produce the product have the distributors listed as the manufacturer or supplier, instead of the actual manufacturer of the product.  The issue with this is that while many of the industry distributors of Electrical and Electronic Equipment (EEE) can provide broad statements as to RoHS compliance, they are unable to provide the required supporting documentation to support of the claim.  Ultimately, the product steward/compliance officer will be unable to substantiate the claim and will be unable to contact and collect compliance documentation from the actual manufacturer of the component being used in the product.  As a result, the data provided will not support the Technical Documentation requirement for the CE mark.

Updating the finished product's BOMs to clearly identify proper manufacturer and Part Number, instead of having distributors information, will improve the response and completion rates significantly, not only for the collection of RoHS documentation, but for other substance Legislation/Regulations/requirements (REACH, Conflict Minerals, Proposition 65), as well.

So, ask yourself, "What are you building your product with, and who makes it?" The answers to these questions are what you should be documenting within your BOM. By completing the BOM in this manner, it will support the effective and efficient collection of compliance documentation.

With over 10 years' experience at Intertek, Robbie is our resident expert for environmental compliance regarding EEE product supply chains and Bill of Materials review.