What is it and why I should care
by Ray Franklin,
RoHS stands for Restriction of use of Hazardous Substances (ref. 1). The
acronym is pronounced Rose, Roz, Ross, or is spelled out, depending on
the speaker's preference. RoHS is a directive issued January 27, 2003 by
the European Commission (EC). It directs European Union (EU) member
nations to enact local legislation by August 13, 2004, which will
implement the RoHS directive as regulatory requirements before the
activation date of July 1, 2006. And that means what?
The directive is a legally binding document, for the EU member nations.
It establishes regulations at the EU level, which flow to each member
nation. Each government must pass its own laws, patterned after the RoHS
directive, and do so by a deadline.
RoHS is part of a growing wave of environmental regulations or green
initiatives. In addition to RoHS for Europe, there are similar
regulations being written in China and other Asian nations. Japanese
companies have created a non-governmental group to standardize green
procurement requirements. In the US, individual states are passing laws
restricting some substances and requiring recycling of certain classes
of products. A common theme is the so-called "take-back" feature that
requires manufacturers to accept old products from consumers and reuse
or recycle the items.
The RoHS directive requires that six hazardous substances be removed
from all electrical and electronic equipment. The substances may be
present incidentally at certain levels as long as they are declared. The
six substances are Cadmium (Cd), hexavalent Chromium (CR VI), Lead (Pb),
Mercury (Hg), polybrominated biphenyls (PBB) and polybrominated diphenyl
ethers (PBDE). The maximum concentration of Cd is 0.01% by weight of
homogeneous material, and 0.1% by weight for the other five substances.
"Homogeneous material" means a material that cannot be mechanically
disjointed into different materials (ref. 2). A substance is "present
incidentally" if it was not intentionally added.
Some exemptions are declared in the RoHS annex, such as Hg in
fluorescent lamps, Pb in certain alloys, and Pb in solder for servers
(until 2010). All the details are in the RoHS directive text, with
discussion and explanation in the dti RoHS guidance notes.
It all sounds pretty straightforward. There are, however, some kinks.
For one, the EU member nations have not followed through and produced
legislation. The August 13 deadline is long past and only a few
countries have passed legislation (ref 3). This delay is creating
uncertainty among corporations striving for compliance. Compounding the
confusion, local legislation could tighten restrictions and possibly
remove exemptions. Any company counting on a particular exemption could
run into trouble in countries that nullified the exemption. Furthermore,
the EC failed to meet its own October 2004 deadline of finalizing the
Though the regulatory climate is still unsettled, a few certainties have
popped up. Compliance is not optional. If you don't face regulation
directly, your customers probably will, and they will push the
requirements down to you. The safest strategy is to comply with the most
stringent requirements - aim for RoHS with no exemptions. You are not
alone. Every other business is in the same boat, and industry groups are
working hard to formulate standards for compliance. Use the links on the
RoHSwell home page to research RoHS in greater depth. Form your own
plan, and get compliant.
directive 2002/95/EC, of the European Parliament.
dti RoHS Regulations, Government Guidance Notes, Consultation Draft,
Perchards Report, summary of the transposition of the WEEE and RoHS
directives into law by EU member states, January 2005.