In its first iteration, the European Union (EU) Restriction of Hazardous Substances (RoHS) Directive regulated six hazardous substances across a range of electrical and electronic equipment (EEE), including microchips, household appliances, and other electronics. These substances were:

  • Lead (Pb), (≤ 0.1 percent)
  • Mercury (Hg), (≤ 0.1 percent)
  • Cadmium (Cd), (≤ 0.01 percent)
  • Hexavalent chromium (chromium VI, Cr+6), (≤ 0.1 percent)
  • Polybrominated biphenyls (PBB), (≤ 0.1 percent)
  • Polybrominated diphenyl ethers (PBDE), (≤ 0.1 percent)

Since its introduction, the RoHS Directive has undergone significant changes, including the RoHS recast (RoHS 2) in 2011 and further updates in 2015, often referred to as RoHS 3. These updates reflect the EU's commitment to managing hazardous substances while adapting to evolving technology and market demands.

The Impact of RoHS 2 on the Electronics Industry

The RoHS 2 Directive (2011/65/EU) expanded the original regulation by adding exemptions, introducing the Conformité Européene (CE) marking to demonstrate compliance, and requiring technical documentation. It also brought additional categories of electronics into scope under Category 11, which includes all other electronic and electrical equipment not previously covered.

Achieving compliance with RoHS 2 compliance requirements can be challenging due to the complexity of supply chains and the limited availability of alternative substances. Companies must adapt to these changes promptly to maintain market access in the EU and avoid penalties.

What Changed with “RoHS 3”?

In 2015, the directive was updated to include four additional restricted substances, commonly referred to as phthalates:

  • Bis(2-Ethylhexyl) phthalate (DEHP)
  • Benzyl butyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

While this update is often called RoHS 3, it remains under the legal framework of RoHS 2 Directive (2011/65/EU). These substances are now part of the RoHS restricted substances list, and compliance is essential for manufacturers to continue selling their products in the EU. An official recast to RoHS 3 Directive is anticipated in the future, which may introduce further restrictions and requirements.

Global Expansion of RoHS Compliance

Compliance with RoHS regulations is not limited to the EU. Similar legislation, such as Korea RoHS and UAE RoHS regulation, highlights the global movement toward managing hazardous substances. Companies must adapt their operations to meet the requirements of these expanding regulations.

For instance:

  • UAE RoHS mirrors the EU framework, requiring the management and reporting of hazardous substances for electronics entering the UAE market.
  • Other regions continue to implement RoHS-like regulations, broadening the scope of compliance efforts.

Steps to Achieve RoHS Compliance

Given the complexity of RoHS compliance requirements, companies should take the following steps to ensure their products meet regulatory standards:

  1. Identify In-Scope Products:

    • Determine if your products fall under the categories outlined in **RoHS 2.
    • Verify materials and components against the RoHS restricted substances list.
  2. Collect Supplier Documentation:

    • Gather material declarations and certificates of compliance from suppliers to ensure components meet RoHS standards.
  3. Implement CE Marking:

    • Products within scope must feature the CE marking to demonstrate compliance with EU directives.
  4. Leverage Compliance Tools:

    • Use software solutions to manage supplier engagement and track compliance across complex supply chains.
  5. Monitor Regulatory Updates:

    • Stay informed about changes to RoHS restricted substances and global expansions like UAE RoHS.

RoHS Compliance Solutions with Acquis

Achieving long-term compliance with RoHS directives can be challenging, especially with constantly changing regulations. Acquis Compliance Tools provide advanced solutions tailored to streamline compliance efforts:

  • Automated Data Management: Collect and manage supplier documentation efficiently.
  • Real-Time Updates: Stay ahead of changes to the RoHS substances list and other global regulations.
  • Supplier Engagement: Improve supplier collaboration to ensure accurate and timely compliance data.
  • Comprehensive Reporting: Generate compliance reports to support RoHS certification and CE marking requirements.

Conclusion

Navigating the complexities of RoHS 2 compliance and preparing for future RoHS 3 requirements is critical for businesses operating in the global electronics market. With Acquis Compliance Tools, you can maintain RoHS conformity, ensure seamless regulatory compliance, and secure your market access.

Contact us today to learn how Acquis can help you achieve RoHS compliance and adapt to evolving regulations.

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