RoHS (Restriction of Hazardous Substances) is a European Union (EU) Directive that restricts the use of specific hazardous materials found in electrical and electronic equipment (EEE). It affects all applicable product sold in EU countries after July 1, 2006. RoHS compliance may be identified with a green RoHS label with a checkmark. The RoHS 2 Directive 2011/65/EU was published July 2011. It expands coverage of RoHS and requires manufactures to comply before products can have the CE mark.
There is a common misconception that RoHS compliant equipment does not contain Focus Materials, and therefore, does not need to be managed in conformance to R2’s Provision 5 requirements. This assumption is not always correct, and could result in a non-conformance. Important things to note about RoHS labeled equipment:
- RoHS is not synonymous with Lead Free or Mercury Free. RoHS allows a minor amount of each. The R2 Standard makes no exemption for minimal amounts of mercury. Circuit boards that contain any amount of lead must be managed as a Focus Material under the R2 Standard. While some RoHS labeled circuit boards may be lead-free, you cannot assume that all are lead-free.
- RoHS does not include batteries. Recital 29 of the Batteries and Accumulators Directive (2006/66/EC) states RoHS does not apply to batteries and accumulators used in electrical and electronic equipment. For example, phones with an integrated battery may be RoHS compliant, because they contain no lead on the circuit board, but under the R2 Standard, they still must be treated as equipment containing Focus Materials because of the integrated batteries.
- RoHS exempts some components and materials under Annex III, however, the exempted components and materials are still Focus Materials as defined by R2, and must be managed in conformance to Provision 5. Examples of RoHS exempted materials that are still R2 Focus Materials:
- Lead in glass of cathode ray tubes (CRTs).
- Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission, and network management for telecommunications.
- Mercury in cold compact fluorescent lamps.
- Do not presume that equipment manufactured after 2006 is RoHS compliant. RoHS only applies to the European Union. Therefore, equipment manufactured after July 2006 may still contain lead or mercury for use in other countries.
Bottom Line: RoHS compliant equipment does not necessarily mean free of R2 Focus Materials. Each piece of equipment should be examined to determine whether it contains a Focus Material. It is best to presume any electronic equipment contains Focus Materials and must be managed as required in Provision 5 until you can demonstrate otherwise