A RoHS-Recast (RoHS 2) Primer - Trace Laboratories

John M Radman &
Allison Jandu
Trace Laboratories, Inc
www.tracelabs.com

Understanding the RoHS Recast (RoHS 2)

Brief History
RoHS = Restriction of Hazardous Substances
RoHS 1 = Directive 2002/95/EC
RoHS 2 = Directive 2011/65/EU 100
Objective = Limit and regulate 6 hazardous substances in
electrical and electronic equipment (EEE)
Cd ≤ 0.01 wt % or 100ppm (batteries, pigments, etc.)
Hg ≤ 0.1 wt % or 1,000ppm (switches, fluorescent
lamps, etc.)
Pb ≤ 0.1 wt % or 1,000ppm (solder, batteries, etc.)
Cr-VI ≤ 0.1 wt % or 1,000ppm (surface coatings)
Polybrominated Biphenyls (PBBs) ≤ 0.1 wt % or
1,000ppm (flame retardants)
Polybrominated Diphenyl Ethers (PBDEs) ≤ 0.1 wt % or
1,000ppm (flame retardants)

Basics of RoHS 2
Restrictions
Restrictions do not apply to materials used in the
production process
Restrictions only apply to the finished EEE
Homogeneous Material
A material of uniform composition
A combination of materials that cannot be separated by
mechanical forces
Requirement
Per homogeneous material within a finished EEE
Could be 100s or 1,000s of homogeneous materials in
a finished EEE

Specifics of RoHS 2
On 02 Jan 2013, Directive 2002/95/EC was repealed and
replaced by Directive 2011/65/EU 100
RoHS-recast objective relates to controlling EEE waste
Simplest means to control waste concerns is to limit the
use of hazardous substances in the manufacturing of EEE
Intention of RoHS-recast (as reported by the EU)
Simplify and make Directive more enforceable
Harmonize with other EU legislation
Increase legal clarity (but not necessarily layman
clarity)

Preface
Preface for the remainder of the presentation
I am neither a lawyer nor politician so much of the
“Simplification” and “Clarity” has been lost on me
I will do my best to explain
This is an EU directive and it has no regard for
requirements outside of the EU

RoHS vs. RoHS-Recast
Gradual extension of RoHS requirements to all EEE by 22
July 2019, including all cables and spare parts (of course
with some exclusions)
Clarification of Definitions (which is helpful)
Mandatory review of Directive by July 2014
Clearer rules for Exemptions including expirations of
existing exemptions
New non-excluded product categories (Annex I)
Category 8, Medical Devices
Many more non-critical/home medical devices
Category 9, Monitoring and Control Instruments
Category 11, Other

RoHS vs. RoHS-Recast
Most Significant Difference
Coherence with other EU legislation
New Legislative Framework (NLF)
CE Marking
Declaration of Conformity
Effective as of 03 January 2013
Markings like below should no longer be used

Timeline
(RoHS 2 FAQ 6)
Existing EEE outside the scope of RoHS 1 but inside
scope of RoHS 2 have until 22 July 2019 to comply [Article
2(2)]

Does RoHS 2 Apply to My Product
(RoHS 2 FAQ 8)

Does RoHS 2 Apply to My Product
Is my product EEE
Must be a product that is placed on the market as a
finished EEE
A component sold for further production into an EEE is
not considered a finished EEE

Does RoHS 2 Apply to My Product
Annex I – Lists 11 Categories of EEE covered by the
Directive
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools
7. Toys, leisure and sports equipment
8. Medical devices
9. Monitoring and control instruments
10.Automatic dispensers
11.Other EEE not covered by any of the categories
above

Scope Exclusion vs. Exemptions
The Scope of the Directive lists the EEE’s to which the
Directive applies
Annex III – Lists Applications “currently” Exempt from the
Restrictions
Distinction
Exemptions can be given to specific substances used
in narrowly-defined applications
Exemptions are not given to an entire category of EEE
product
Exemptions are temporary and eventually expire
Scope Excluded products will likely never have to
comply

Scope Exclusions
Per Article 2(4), Directive does not apply to:
a) Equipment for Military use
b) Equipment sent into Space
c) Equipment installed into other Exempt Equipment
d) Large-scale Stationary Industrial Tools
e) Large-scale Fixed Installations
f) Transportation Equipment
g) Non-Road Mobile Machinery for professional use
h) Implantable Medical Devices
i) Photovoltaic Panels
j) R&D Equipment
Again, Focus is on EEE that enters the waste stream in
high volume

Exemptions
Why are some applications exempt
Exemptions give industry time to ensure that there is a
suitable replacement (i.e.: high-lead solders)
Order of precedence of compliance is based on volume
of product entering the waste stream
EEE containing an application that enters the waste
stream in high volume must comply to RoHS
EEE containing an application that does not enter the
waste stream in high volume and currently does not have
an alternate compliant application may be exempt from
RoHS
Reviewed at least every 4 years

Exemptions 1 -13
Per Annex III, Applications currently exempt include:
1) Hg in Compact Fluorescent Lamps (CFL)
2) Hg in other Fluorescent Lamps (FL)
3) Hg in Cold Cathode FL (CCFL) and External Electrode
FL (EEFL)
4) Hg in other specific lamps
5) Pb in specific glass
6) Pb in specific metal alloys
7) Pb in specific solders or EEEs
8) Cd in specific uses
9) Cr-VI or Pb in specific refrigeration applications
11)Pb in compliant pin connectors
12)Pb coating for thermal conduction module C-ring
13)Specific glass

Exemptions 14 - 26
Per Annex III, Applications currently exempt include:
14)Pb solders in microprocessors
15)Pb solders in ICs
16)Pb in specific lamps
17)Pb in high intensity discharge (HID) lamps
18)Pb in fluorescent powder
19)Pb in energy saving lamps (ESL)
20)Pb in glass of LCDs
21)Pb and Cd in specific inks
23)Pb finish on fine pitch components
24)Pb solders for planar array ceramic caps
25)Pb in surface conduction electron emitter displays
(SED)
26)Pb in black light blue lamps

Exemptions 27 - 40
Per Annex III, Applications currently exempt include:
27)Pb in solder of high-powered loudspeakers
29)Pb in crystal glass
30)Cd in solder of high-powered loudspeakers
31)Pb in solder of Hg-free fluorescent lamps
32)Pb in window assemblies of laser tubes
33)Pb in solder in power transformers
34)Pb in potentiometer elements
36)Hg in DC plasma displays
37)Pb in high voltage diodes
38)Cd on Al bonded BeO
39)Cd in specific LEDs
40)Cd in photoresistors

Complications
Additional Exemptions can be added
Annex V provides a procedure for adding, renewing, or
revoking an exemption
Dual or Multiple Use Products
Product with an Inside and Outside the Scope use
If one use is Inside the Scope, the product MUST
comply
If product is non-compliant and sold for excluded use,
seller is responsible for assuring product is only available
for use outside the scope of RoHS 2
All components within an Inside the Scope product must
comply

Specific Questions
HMP Solders (>85% Pb alloy)
Exemption 7(a) applies
Expected to expire by 20 September 2015 but not
definite
There are alternatives
Au, Au80Sn20, Au88Ge12, Au96.8Si3.2,
Sn89Sb10.5Cu0.5,etc.
Cannot to get much info from the suppliers
Large-Scale Stationary Industrial Tools (LSSIT) and Large-
Scale Fixed Installations (LSFI)
EEE must be exclusively made for LSSIT or LSFI use
Currently, there is no plan to add these to the Scope
May develop a clearer definition of “Large-Scale” based
on dimensions and weight

OK, So RoHS Applies to Me
If your product is an EEE and falls under the Scope for
RoHS 2…
It must be marked with the CE marking to display
compliance
You must generate a Declaration of Conformity (DoC)

CE Marking & Declaration of Conformity
“Blue Guide” – Guide to the Implementation of Directives
based on the New Approach and the Global Approach
118 pages
CE Marking
Only marking which symbolizes conformity to ALL
requirements of the product
Declaration of Conformity (DoC)
Document produced by the manufacturer stating that
the product complies with all relevant Directives
All or Nothing
The CE Marking and DoC show that a EEE FULLY
complies with all Directives (RoHS, EMI, Low Volt, etc.)
A product cannot have a CE Marking or DoC but only
comply with some Directives

CE Marking
Meaning of CE Marking
EU clearly wants the CE Marking and only the CE Marking
EU stand is that the CE marking is the only marking
that attests conformity of RoHS 2
EC/765-2008 – markings, signs, or inscriptions that are
likely to mislead third parties regarding the meaning or
form of the CE marking are prohibited
EU does not want a Pb-Free or other symbol but other
symbols may be acceptable if they do not mislead

Declaration of Conformity
Annex VI
Manufacturer must make a DoC when placing a product
on the market
A single DoC shall reference RoHS 2 and any other
relevant Directive
Documentation requirements are listed in Decision
768/2008/EC

What to do Next
3 Options to ensure your product complies
1. Require suppliers to provide DoCs for all parts they
supply and create a DoC for your EEE based off of
supplier DoCs
2. Test your complete EEE to verify compliance
Could be 1,000s of samples
Lot variation
3. Attain supplier DoCs and test:
Materials for which DoCs could not be attained
Materials that may logically contain restricted
substances

Testing
Screening – X-Ray Fluorescence (XRF)
Can non-destructively screen parts of a EEE
Quick and inexpensive, however:
Parts must be of sufficient size
Can give a rough idea of concentration but not
nearly as accurate as techniques inspectors will use
Cannot identify the PBBs, PBDEs, or Cr-VI

Testing
Destructive Testing
Separate EEE into homogeneous materials
This could be very difficult
Individually digest materials in acid
Individually analyze via ICP-OES and GC/MS

Post-Testing
1) Write your DoC
2) Mark your EEE with CE
3) Sell your EEE in the EU without worry
4) Make sure your suppliers do not change anything without
notifying you first

Useful Websites
National Authorities
http://ec.europa.eu/environment/waste/weee/pdf/contacts_ms_rohs.pdf
Blue Guide
http://ec.europa.eu/enterprise/policies/single-market-goods/files/blueguide/guidepublic_en.pdf
RoHS 2 Directive
http://eurlex.europa.eu/LexUriServ/LexUriServ.douri=OJ:L:2011:174:0088:0110:e
n:PDF

Questions Comments
Contact info:
John M Radman
Senior Technical Director
jradman@tracelabs.com
410.229.4384
Allison Jandu
Account Manager
ajandu@tracelabs.com
410.229.4367