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).

Limits on Hazardous Substances under the UAE RoHS Regulation

The following is a list of restricted substances and their respective maximum threshold limits:

  1. Lead (Pb): 0.1%
  2. Mercury (Hg): 0.1%
  3. Cadmium (Cd): 0.01%
  4. Hexavalent chromium (Vi): 0.1%
  5. Polybrominated biphenyl (PBB): 0.1%
  6. Polybrominated biphenyl ethers (PBDE): 0.1%
  7. Bis (2-ethylhexyl) phthalate (DEHP): 0.1%
  8. Butyl benzyl phthalate (BBP): 0.1%
  9. Dibutyl phthalate (DBP): 0.1%
  10. Diisobutyl phthalate (DIBP): 0.1%

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.

Scope of UAE RoHS Regulation

  • RoHS applies to companies importing EEEs into the UAE market.
  • The regulation covers a range of products including household appliances, IT and telecommunication equipment, lighting equipment, medical devices, and more.
  • The regulations aim to control the presence of hazardous substances such as lead, mercury, cadmium, and others mentioned above in EEEs.
  • Exemptions: Some products are exempt from the requirement to obtain registration, including equipment for military/security, research and development, and general lighting.
  • Suppliers' Obligations: The authorized representative or supplier is responsible for ensuring that the EEEs meet the requirements of the technical regulation.

Who is Impacted by UAE RoHS?

UAE RoHS affects various stakeholders within the supply chain:

  • Manufacturers: Responsible for ensuring their products meet the RoHS requirements.
  • Authorized Representatives: Those who act on behalf of manufacturers to ensure compliance.
  • Retailers: Must verify that the products they sell comply with UAE RoHS.
  • Importers: Need to ensure that imported products adhere to the regulations.
  • These stakeholders must assess their products and supply chains to understand the material composition and ensure compliance with the specified standards.

Categories of Electrical and Electronic Equipment (EEE) Covered under UAE RoHS

  • Large Household Appliances
  • Small Household Appliances
  • IT and Telecommunications
  • Consumer Equipment
  • Lighting Equipment
  • Electrical and Electronic Tools
  • Toys, Leisure, and Sports Equipment
  • Medical Devices
  • Monitoring & Controlling Instruments (including industrial monitoring and control instruments)
  • Automatic Dispensers
  • Other EEE Not Covered By Other Categories

Conformity Assessment Options for UAE RoHS Requirements

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:

  • Submit a risk assessment if the full product assessment is not completed.
  • Execute a Declaration of Conformity (DoC) using ESMA's template, including only critical components.
  • Submit a full RoHS test report of the complete product, or test reports of at least three critical components.
  • ESMA will verify compliance and issue a Certificate of Conformity (CoC).

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:

  • Execute a DoC.
  • Submit risk assessment documents based on IEC 63000, IEC 62476, and IEC 62474.
  • ESMA will conduct a technical audit and verification by visiting the manufacturing facility.
  • ESMA will verify compliance and issue approval for the use of the EQM on the products manufactured by the facility. Under this option, the manufacturing facility itself is evaluated for compliance. EQM approvals are valid for three years.

emirates-quality-mark-logo.png

Steps to Achieve UAE RoHS Compliance

Identify Applicable Products:

  • Determine whether your products fall within the 11 categories of EEE covered by UAE RoHS.

Assess Substance Content:

  • Evaluate the material composition of your products to identify the presence of restricted substances.

Compile Technical Documentation:

  • Create a technical file according to IEC 63000, documenting compliance with UAE RoHS requirements. This file should include test reports, risk assessments, and supplier declarations.

Choose Compliance Path:

  • Decide whether to pursue ECAS certification or an EQM license based on your product and market strategy.

Apply for Certification:

  • Submit your technical documentation and application to ESMA or the relevant authority to obtain the necessary certification.

Maintain Compliance:

  • Continuously monitor your supply chain and product changes to ensure ongoing compliance with UAE RoHS.

Penalties for UAE RoHS Non-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.

Speak to Our Compliance Experts

Share