RoHS & REACH in Assessing a Product

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FAQ on RoHS and REACH

We are living in a world that we have new manufactures producing new products every day that affect our lives in different ways. Although these products help us to improve our quality of life, they can have some effects on the environment. To avoid these issues, we have some specific requirements applied on these products to make them compliant with the environment.

#1 - What are the most common requirements for a product to be compliant with environmental regulations?

The top requirements in product environmental compliance of electrical and electronic devices are RoHS and REACH

#2 - Which parts of a product must be RoHS / REACH compliant?

Simply all parts of the product such as solder, finishes, paste, cables, connectors, etc. However, few exclusions apply, for example batteries and packaging under RoHS. 

Most common requirement for electronic equipment

For example, an electronic board that will be used as a part of the motherboard in a computer. This electronic board should be analyzed to check if all single parts of the board are compliant with RoHS or REACH based on the request. All the environmental data is gathered from their manufacturer to confirm their compliance with RoHS and REACH.

# 3 - When is a product RoHS compliant?

RoHS stands for Restriction of Hazardous Substances. The current Europe RoHS applicable regulation is Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment and amendments.

 

The first RoHS directive was 2002/95/EC and the second RoHS which was Directive 2011/65/EU replaced the first one. In the latest update, 4 restricted phthalate substances were added to the list, making Directive 2011/65/EU known as RoHS 3 (China RoHS does not include these 4 substances).

 

It should be noted that the concentration of these substances is regulated at the level of homogeneous materials, not at the component level. You may now have this question how we define homogeneous material.

 

Homogeneous material is defined as a material that can not be separated into different materials by mechanical actions while it consists of various materials.

Substance Name Concentration limit
Lead (Pb) and lead compounds  < 0.1% or 1000 ppm
Cadmium (Cd) and cadmium compounds < 0.01% or 100 ppm
Mercury (Me) and mercury compounds < 0.1% or 1000 ppm
Hexavalent Chromium (Cr6+) and hexavalent chromium compounds < 0.1% or 1000 ppm
Polybrominated biphenyls (PBBs) < 0.1% or 1000 ppm
Polybrominated diphenyl ethers (PBDEs) < 0.1% or 1000 ppm
Butyl benzyl phthalate (BBP) - CAS # 85-68-7 < 0.1% or 1000 ppm
Di-n-butyl phthalate (DBP) - CAS # 84-74-2 < 0.1% or 1000 ppm
Di(2-ethylhexyl) phthalate (DEHP) - CAS # 117-81-7 < 0.1% or 1000 ppm
Diisobutyl phthalate (DIBP) - CAS # 84-69-5 < 0.1% or 1000 ppm

RoHS Compliant product under exemptions

#4 - Are there any exemptions for products to be compliant with RoHS?

Yes! There are some exemptions for a certain group of products which allows them to use the restricted substances more than the limited amount but most of these exemptions are set to expire.


#5 - What is the REACH regulation?

REACH stands for Registration, Evaluation, Authorization, and restriction of Chemicals, and this regulation is defined to protect humans and the environment in the European Union.

 

As we defined RoHS, REACH is also applicable to a wide range of products such as equipment, hardware, and electronic devices.

#6 - What are the REACH SVHCs?

Under this regulation, we have REACH SVHCs which stands for Substances of Very High Concern as they can be commonly used in different products such as electronic products. 

 

There is a list of substances that is updated every six months called the candidate list. When there is at least one substance from this list present in 0.1% or greater than 0.1% by weight, it should be declared. As this list is updated every 6 months, manufacturers must keep their technical files up to date.

REACH regulation and scope

Producer declaring SVHCs

#7 - When are producers supposed to declare the presence of SVHCs in their products?

Producers should declare any SVHC above 0.1% weight in every article that composes a product.

 

An article is defined as ''an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition'' article 3(3) of EU REACH.


What do we do at Enviropass to assess a product?

As we talked about REACH and RoHS, we can explain how we help our customers in assessing a product.

Enviropass product assessment
  • In the first step, clients should provide BOM (Bill Of Materials) related to the specific product which includes all components used in manufacturing that product. We can find different information such as the name of the supplier, part number, and description of each component in the BOM. Based on this information, we can start the research on each component. This step is done by using the information that the client may provide such as the drawing related to electronic boards. The research is mainly done by finding the environmental documents of each part through the website of each supplier. These documents can be found by searching the part number on their website or by submitting an online request and asking for the environmental data of specific part numbers.
  • To get the information faster, we also email the suppliers and their customer service representatives by providing the information regarding those part numbers.
  • After archiving the environmental documents, we should check if the RoHS certificate includes all 10 hazardous substances (6 Hazardous substances if we are checking for China RoHS) and check if there is an exemption. After finding the relative exemption we must check if that specific exemption is still valid based on the list of exemptions available on Enviropass website.
  • In the next step, we check for compliance with REACH regulation. We should see if there is any SVHC above 0.1% and what is the CAS number of that chemical component. Finally, we must check whether the product is compliant with REACH Annex XVII. This information may also be found in the SDS (Safety Data Sheet) of the related product in both sections related to Hazardous substances and regulatory information.

 

Still having a myriad of questions on RoHS or REACH?  Contact Enviropass!

Enviropass Expertise Inc. 

Tel: +1 (514) 887-7871

Email: Contact@getenviropass.com