ROHS TESTING: COMPLIANCE & CERTIFICATION

You have to verify whether your products are RoHS compliant. It can be one product intended for the EU market, multiple models, or even your entire production. Your designs can have a dozen or thousands of different components, depending on their complexity. Nevertheless, whatever the scope is, you are considering to test electrical or electronic equipment again the RoHS requirements.*

To help you build sufficient technical documentation, the International Electrotechnical Commission (IEC) has issued the 63000 Standard for technical documentation for the assessment of electrical and electronic products concerning the restriction of hazardous substances. Here is what the IEC 63000 Standard states in its introduction:

For those restrictions that apply at the ‘homogeneous material’ level, it is impractical for manufacturers of complex products to undertake their (…) testing of all materials contained in the final assembled product.

Instead, manufacturers work with their suppliers to manage compliance and compile technical documentation as evidence of compliance.

What is at Stake with RoHS

Let’s briefly recap what RoHS is. RoHS stands for:

Restriction

Of certain

Hazardous

Substances.

RoHS applies to electrical and electronic equipment (EEE). Tens of countries, especially in Europe and in Asia, even some US states, have voted RoHS regulations. The European Union EU RoHS has been the pioneer in this sector and remains a reference.

RoHS usually targets these six substances:

Four heavy metals: chromium hexavalent, lead, mercury, cadmium, and their compounds
Two brominated families: Polybrominated biphenyls (PBBs) and Polybrominated diphenyl ethers (PBDEs)

Some countries have added there four phthalates to the RoHS list:

Butyl benzyl phthalate (BBP)
Di-n-butyl phthalate (DBP)
Di(2-Ethylhexyl) phthalate (DEHP)
Diisobutyl phthalate (DIBP)

Different compliance rules apply, depending on the RoHS regulation. For example, the scope varies a lot from a market to another. But what remains the same is that the restrictions apply at the homogeneous material level, and are reasonably low, either 0.1% or 0.01%. Additionally, various applications and materials benefit from RoHS exemptions. For example, lead in some copper alloys can exceed the general concentration limit of 0.1% under certain conditions. Since these exemptions are regularly revised, you should monitor the RoHS exemptions that apply to your products and make sure that they remain compliant.

Two Possible RoHS Testing Approaches

How to test your products and verify their compliance against the RoHS substances? In other words: What kind of information is necessary and sufficient to perform valuable RoHS conformity assessments?

You essentially have two options: either you do the test yourself, or you benefit from tests that a stakeholder in your supply chain has already conducted. Then you use the gathered information to make your technical file.

In essence, you would either perform RoHS analytical tests or prepare a documentary assessment.

#1: Analytical Testing Against RoHS Substances

With the analytical testing approach, you will do physical testing on samples. We can find various types of analytical testing on the market, depending on the chemicals to be analyzed. Here are some of the main ones.

XRF Spectrometry Method

Probably the most popular analytical testing method is the XRF one. XRF means X-Ray Fluorescence.

With this method, it is possible to identify a material composition by bombarding it with high-energy X-rays. Then, the emission of “secondary” (or fluorescent) X-rays gives the nature of the atoms that have been excited. The XRF method is particularly useful when it comes to detecting the presence and the concentration of heavy metals like lead into a homogeneous material. XRF is one of the least expensive analytical testing methods.

Chromatography

Chromatography consists of chemically separating the elements of a dissolved mixture. As a result, chromatography allows us to identify and quantify these elements.

Gaz chromatography enables to detection of the presence of PBB, PBDEs, or phthalates and find out their concentration in a given material.

Should I Use the Analytical Testing Approach?

Generally speaking: No. At least not as a primary approach to test complex products like electronic equipment. Why not? Because it would be:

Too costly as a lab would have to conduct many tests. Remember: RoHS applies at the level of homogeneous materials, such as materials of uniform composition. If your product contains 100 different components, then there may be 500 homogeneous materials to test. If you want to verify the presence of the 10 RoHS substances, then it is 5 000 tests that the lab will do in total. It will cost your dozens of thousands of dollars!

Destructive. You will have at least to have one product dismantled to get every homogeneous material. If every sample does not have sufficient materials, then the lab may have to request and dismantle additional units.

Insufficient. Despite your investment in such testing, you will not get a guarantee from your suppliers that the parts will remain compliant with RoHS. You would only have the RoHS information of one specific sample. Should you then do multiple testing overtime to make sure your product remains RoHS compliant? A design or a sourcing revision will trigger the need to update your analytical testing. It would reveal even more expensive!

What you ideally want is that your supply chain commits to compliance, regardless of design and material modifications.

#2: Verification of the RoHS Documentation from your Supply Chain

Since it is not realistic to do comprehensive analytical testing on your products, another option is available: the Documentary approach.

Here, you will perform a risk analysis based on your product bill of materials and use the information your suppliers have already collected from their suppliers to confirm compliance with RoHS.

Manufacturers Certificates of Compliance

What Enviropass recommends is to gather as much relevant RoHS information as possible from your supply chain, build a robust technical file, and demonstrate due diligence. As a rule of thumb:

your manufacturing suppliers know their parts better than you do;
their products are not as complex as yours; and
they deal directly with their suppliers of components or materials.

Therefore, they are more likely to commit to the RoHS compliance of their parts.

When available, their certificates of compliance (CoC) are significant pieces of information, as long as they:

are up-to-date in terms of listed RoHS substances and exemptions. You should be able to find out whether RoHS exemptions are granted, with valid references;
cover the parts under investigation;
are consistent with the anticipated likelihood of RoHS substances in a given component.

CoC can be of different formats. Feel free to use the Enviropass EPEC form to gather the needed environmental information from your supply chain.

Other documents, such as specifications and harmonized safety data sheets (SDS) may also enable you to determine the RoHS status of certain materials.

Likewise, you can use testing reports as proof of compliance. However, test reports of samples don’t give you any guarantee that all of the supplied parts remain compliant over time. Therefore, the supplier of parts should accompany its test report by a CoC.

Should I Follow the RoHS Documentary Approach?

For complex products like electronic devices, with more than ten different homogeneous materials, the quick answer is yes.

Instead, manufacturers work with their suppliers to manage compliance and compile technical documentation as evidence of compliance.

Therefore, IEC 63000 promotes the technical documentation with a documentary review for complex products. Both industry and most enforcement authorities recognize this approach.

Along with IEC, CENELEC (European Committee for Electrotechnical Standardization) strongly recommends the documentary approach when it comes to RoHS compliance.

Indeed:

It is a comprehensive method. You will assess the documents of every component and every homogeneous material of a product.

It is heavily reliable because it is comprehensive, and it relies on suppliers’ statements.

Based on quality control of the collected information, you can rely on the statements you receive.

Importantly, it is cost-effective. The tests themselves are much less expensive than for chemical analyses.

It is not destructive. There is no need to waste one or more prototypes. Besides, because you rely on analysis that has already been performed by your suppliers, you can cut costs. Why would you do over costly tests that your supply chain has already completed? Reuse them instead!

There aren’t product shipping costs.

It is a more sustainable method because it avoids product transportation and destruction.

To update your technical file, you will only need to gather the missing information for the additional parts and according to the latest applicable regulatory changes.

To conclude, it is an efficient approach which you can easily update for new product versions.

Does it Mean that Analytical Testing is Useless?

Not necessarily. Analytical testing may be necessary at the last resort, for medium to high-risk homogeneous materials without sufficient RoHS compliance guarantee from the suppliers. Here is why:

For a part without sufficient RoHS information and that is found risky according to your IEC 63000 type assessment, you can try to find a replacement, like an alternative part, that is deemed compliant. However, in rare cases, it is impossible to replace that part because there is no alternative. Then you have no other choice than initiating an analytic testing plan on the risky homogeneous materials of that same part.

If the suspected restricted substance is indeed present in the risky homogeneous material, then corrective actions must be taken to make the product compliant. For instance, it may be changing the design to bypass this part.

Then How do I Assure RoHS Compliance?

Here are some takeaways:

Have a compliance plan that you will detail in an internal RoHS procedure enabling you to show how you perform due diligence. Get organized and follow a PDCA (Plan-Do-Check-Act) strategy for continuous improvement of your RoHS testing endeavor;
Include in your procedure a risk analysis approach per the well-recognized IEC 63000 standard.

Checking that suppliers are RoHS compliant is not sufficient. Some other details must be collected, such as the claimed exemptions. The documentary method and quality control enable a demonstration of due diligence;
You ideally want a commitment from your suppliers that your parts are and will remain EU RoHS compliant, either with or without exemption. These statements are certificates of compliance (CoC);
Make sure the CoCs are up-to-date and enable you to confirm RoHS compliance. For example, does the CoC cover the four RoHS phthalates?

Verify the exemption status. Are the exemptions still valid? If not, then the part is no longer RoHS compliant. If no exemptions are expressly stipulated, are you able to reasonably assume that the part does not or can’t benefit from any exemption?
You are free to use our to-date EPEC form to scan your suppliers and gather their statements;
Execute analytical testing on specific homogeneous materials as a last resort, when you have no other choice before modifying your product design.

Then, you should be able to prepare your product declaration of compliance.

Ask Enviropass for a free online consultation to see a RoHS technical file.

*Note: This article is based on the current understanding of Enviropass Expertise Inc. It is developed solely for information purposes and can not replace official legislation.

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