Approved by TaylorWessing
Overview > this assessment focuses on the RoHS (Restriction of Hazardous Substances) Directive, basically asking suppliers to provide information on compliance and conformity around certain hazardous substances that are contained in electrical and electronic equipment, where applicable.
Supplier target > any supplier that manufactures, sells or leases products that are subject to compliance under the RoHS Directive (ie electrical and electronic equipment "EEE" according to Annex I of the Directive 2011/65/EU)
Scoring > this assessment is scored based on the answers given
🚩 Red flag questions > there are red flags on false answers of the following questions:
● Do the EEEs bear a CE-marking?
● Do you have an EU Declaration of Conformity for the EEEs?
● Do you have the technical documentation of the EEEs?
● Have you assessed the conformity of your EEEs according to an applicable conformity assessment procedure?
● Is the concentration of the restricted substances below the indicated maximum concentration according to the Annex II of the Directive 2011/65/EU?
FAQ
What is ROHS?
RoHS stands for Restriction of Hazardous Substances. It’s also known as Directive 2002/95/EC and restricts the use of hazardous materials found in electrical and electronic products (EEE).
Which hazardous substances are we talking about?
The directive prohibits hazardous substances such as lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs) in EEE. These substances are harmful for the environment. They pollute landfills and are dangerous in terms of occupational exposure during manufacturing and recycling processes. See the breakdown below for more
Who needs to comply?
Any business that sells or distributes applicable EEE products, sub-assemblies, components, or cables directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilize any of the restricted materials.
What is a CE Marking?
CE mark is a mandatory conformity mark. It states that products that are being sold in the EU have met legal directives set by the EU in regards to safety, health, and environmental health.
Breakdown of Restricted Substances:
Cadmium (Cd)
Cadmium is used in electronic equipment, car batteries, metal coatings, and pigments. Known human carcinogen that affects multiple organ systems. CAS number = 7440-43-9.
Lead (Pb)
Lead is used in solder, lead-acid batteries, electronic components, cable sheathing, x-ray shielding, and in the glass of cathode-ray tubes. Known human carcinogen that affects the nervous and renal systems. CAS number = 7439-92-1.
Mercury (Hg)
Mercury is used in batteries, switches, and thermostats, and fluorescent lamps. Known human carcinogen that affects multiple organ systems. CAS number = 7439-97-6.
Hexavalent Chromium (Cr VI)
Chromium VI is used in chrome plating, dyes, and pigments. While some forms of chromium are non-toxic, chromium VI can produce toxic effects in multiple organ systems. CAS number = 18540-29-9.
Polybrominated Biphenyls (PBB)
Also known as congeners, PBBs are flame retardants found in computer monitor and TV plastic enclosures. They have been found in indoor dust and air through evaporation. Known human carcinogen that affects the endocrine system.
Polybrominated Diphenyl Ethers (PBDE)
Similar to PBBs - added to plastic enclosures to make them difficult to burn. Known human carcinogen that affects the endocrine system.
Bis(2-Ethylhexyl) phthalate (DEHP)
DEHPs are used to soften PVC and vinyl insulation on electrical wires and in medical tubing. Known human carcinogen that affects the immune and reproductive systems.
Benzyl butyl phthalate (BBP)
These are used to soften PVC and vinyl insulation on electrical wires.
Dibutyl phthalate (DBP)
DBPs are part of the di-n-phtalate family used to soften PVC and vinyl insulation on electrical wires.
Diisobutyl phthalate (DIBP
These are also used to soften PVC and vinyl insulation on electrical wires.
Useful links
RoHS explained