The UAE Restriction of Hazardous Substances (RoHS) Regulation is a law that restricts the use of harmful materials in electronic and electrical equipment (EEE). It is inspired by the European Union's RoHS Directive governed by UAE Cabinet Order No. 10/217, a critical framework designed to control the use of hazardous materials in electrical and electronic equipment (EEE). It became effective on January 1, 2018, with initial requirements. Companies that are covered by the regulation must survey their supply chains and provide declarations for products that contain restricted substances above a specific threshold at the homogenous level. UAE RoHS also presents unique challenges and requirements for manufacturers, importers, and distributors operating in the UAE market.
Note- To place electrical and electronic products on the UAE market, companies must obtain a Certificate of Conformity under the Emirates Conformity Assessment Scheme (ECAS).
The following is a list of restricted substances and their respective maximum threshold limits:
It's important to note that these limits are set as a percentage of the total weight of the EEEs, and they apply to all parts, components, and materials that make up the EEEs.
UAE RoHS affects various stakeholders within the supply chain:
There are two ways for companies to achieve UAE RoHS compliance. Those that have risk assessment documentation and can demonstrate full compliance with UAE RoHS requirements can apply for a three-year certificate from the Emirates Authority for Standardisation and Metrology (ESMA). They can then place an Emirates Quality Mark on their product. Companies that have not completed a full product assessment can submit product testing reports and a Declaration of Conformity to apply for a one-year certification.
Option 1: Emirates Conformity Assessment Scheme (ECAS) Under ECAS, businesses are required to follow the following steps to comply with RoHS requirements:
Critical components are those that, if they fail, could lead to a breach of electrical safety (e.g. electrical plug, motor, insulation/body, etc.). These components can be identified by the manufacturer based on their own risk assessment procedure and the justification used to identify them must be indicated in the DoC form. It is important to note that ESMA only accepted internal test reports for applications made up until December 31, 2018. The CoC is valid for one year only. If there are changes to components during the validity of the certificate, the certificate holder must ensure continued compliance of the certified product and update the changes in the technical file during the certificate renewal process.
Option 2: Emirates Quality Mark (EQM) scheme Under the EQM scheme, businesses must follow these steps to comply with RoHS requirements:
Identify Applicable Products:
Assess Substance Content:
Compile Technical Documentation:
Choose Compliance Path:
Apply for Certification:
Maintain Compliance:
Companies that fail to comply with the RoHS regulations face penalties. Such penalties include fines, a halt to the importation of EEEs, or both. Furthermore, suppliers are also liable to withdraw products from the market if they do not comply with the regulation.
In conclusion, it is crucial for companies to understand and comply with the RoHS regulations in order to avoid penalties. Companies must consider the conformity assessment options and determine the best course of action for their specific needs. By taking the necessary steps to comply with the regulations, companies can ensure that their products are safe and acceptable for use in the UAE market.
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