Editing RoHS (section)

== Details ==
Each European Union member state will adopt its own enforcement and implementation policies using the directive as a guide.

'''RoHS''' is often referred to as the "lead-free directive", but it restricts the use of the following ten substances:

# [[Lead]] (Pb)
# [[Mercury (element)|Mercury]] (Hg)
# [[Cadmium]] (Cd)
# [[Hexavalent chromium]] (Cr<sup>6+</sup>)
# [[Polybrominated biphenyls]] (PBB)
# [[PBDE|Polybrominated diphenyl ether]] (PBDE)
# [[DEHP|Bis(2-ethylhexyl) phthalate]] (DEHP)
# [[Benzyl butyl phthalate|Butyl benzyl phthalate]] (BBP)
# [[Dibutyl phthalate]] (DBP)
# [[Diisobutyl phthalate]] (DIBP)

'''Maximum Permitted Concentration: 0.1%'''<ref name="Eur-lex.europa.eu">{{cite web |url=http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOL_2015_137_R_0003 |title=EURLex – 32015L0863 – EN – EUR-Lex |date=4 June 2015 |publisher=Eur-lex.europa.eu |access-date=1 February 2016 |url-status=live |archive-url=https://web.archive.org/web/20160209151244/http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOL_2015_137_R_0003 |archive-date=9 February 2016}}</ref>

'''Max for Cadmium: 0.01%'''<ref name="Eur-lex.europa.eu"/>

DEHP, BBP, DBP and DIBP were added as part of DIRECTIVE (EU) 2015/863 which was published on 31 March 2015.<ref name="Eur-lex.europa.eu"/>

PBB and PBDE are [[flame retardant]]s used in several plastics. [[Hexavalent chromium]] is used in [[chrome plating]], chromate coatings and [[primer (paint)|primer]]s, and in [[chromic acid]].

The maximum permitted concentrations in non-[[#Restriction Exemptions|exempt products]] are 0.1% or 1000&nbsp;[[parts per million]] (ppm) (except for [[cadmium]], which is limited to 0.01% or 100&nbsp;ppm) by weight. The restrictions are on each  ''homogeneous material'' in the product, which means that the limits do not apply to the weight of the finished product, or even to a component, but to any single material that could (theoretically) be separated mechanically&nbsp;– for example, the sheath on a cable or the [[tinning]] on a component lead.

As an example, a [[radio]] is composed of a case, [[screws]], [[washer (hardware)|washers]], a circuit board, speakers, etc. The screws, washers, and case may each be made of homogenous materials, but the other components comprise multiple sub-components of many different types of material. For instance, a circuit board is composed of a bare [[printed circuit board]] (PCB), [[integrated circuit]]s (IC), [[resistors]], [[capacitors]], switches, etc. A [[switch]] is composed of a case, a lever, a spring, contacts, pins, etc., each of which may be made of different materials. A contact might be composed of a copper strip with a surface coating. A [[loudspeaker]] is composed of a permanent magnet, copper wire, paper, etc.

Everything that can be identified as a homogeneous material must meet the limit. So if it turns out that the case was made of plastic with 2,300&nbsp;ppm (0.23%) PBB used as a flame retardant, then the entire radio would fail the requirements of the directive.

In an effort to close RoHS 1 loopholes, in May 2006 the European Commission was asked to review two currently excluded product categories (monitoring and control equipment, and medical devices) for future inclusion in the products that must fall into RoHS compliance.<ref>[http://www.edn.com/article/CA6333546.html?partner=enews]  {{webarchive|url=https://web.archive.org/web/20070927174054/http://www.edn.com/article/CA6333546.html?partner=enews|date=27 September 2007}}</ref> In addition the commission entertains requests for deadline extensions or for exclusions by substance categories, substance location or weight.<ref>[http://www.reed-electronics.com/semiconductor/article/CA6333371?spacedesc=news&industryid=3026&nid=2301]  {{webarchive|url=https://web.archive.org/web/20150704234124/http://www.reed-electronics.com/semiconductor/article/CA6333371?spacedesc=news&industryid=3026&nid=2301|date=4 July 2015}}</ref> New legislation was published in the official journal in July 2011 which supersedes this exemption.

Note that batteries are not included within the scope of RoHS. However, in Europe, batteries are under the European Commission's 1991 Battery Directive (91/157/EEC<ref>{{cite web |url=http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31991L0157:EN:NOT |title=EURLex – 31991L0157 – EN – EUR-Lex |date=18 March 1991 |publisher=Eur-lex.europa.eu |access-date=3 July 2015}}</ref>), which was increased in scope and approved in the new [[battery directive]], version 2003/0282 COD,<ref>{{cite web |url=http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32006L0066:EN:NOT |title=EURLex – 32006L0066 – EN – EUR-Lex |publisher=Eur-lex.europa.eu |date=26 September 2006 |access-date=3 July 2015}}</ref> which will be official when submitted to and published in the EU's Official Journal. While the first Battery Directive addressed possible trade barrier issues brought about by disparate European member states' implementation, the new directive more explicitly highlights improving and protecting the environment from the negative effects of the waste contained in batteries. It also contains a programme for more ambitious recycling of industrial, automotive, and consumer batteries, gradually increasing the rate of manufacturer-provided collection sites to 45% by 2016. It also sets limits of 5&nbsp;ppm mercury and 20&nbsp;ppm cadmium to batteries except those used in medical, emergency, or portable power-tool devices.<ref>[http://www.conformity.com/artman/publish/printer_25.shtml] {{webarchive|url=https://web.archive.org/web/20080302101640/http://www.conformity.com/artman/publish/printer_25.shtml|date=2 March 2008}}</ref> Though not setting quantitative limits on quantities of lead, lead–acid, nickel, and nickel–cadmium in batteries, it cites a need to restrict these substances and provide for recycling up to 75% of batteries with these substances. There are also provisions for marking the batteries with symbols in regard to metal content and recycling collection information.

The directive applies to equipment as defined by a section of the WEEE directive. The following numeric categories apply:
# Large household appliances
# Small household appliances
# IT & telecommunications equipment (although infrastructure equipment is exempt in some countries)
# Consumer equipment
# Lighting equipment – including light bulbs
# Electronic and electrical tools
# Toys, leisure, and sports equipment
# Medical devices (exemption removed in July 2011)
# Monitoring and control instruments (exemption removed in July 2011)
# Automatic dispensers
#Other EEE not covered by any of the categories above.

It does not apply to fixed industrial plant and tools. Compliance is the responsibility of the company that puts the product on the market, as defined in the Directive; components and sub-assemblies are not responsible for product compliance. Of course, given the fact that the regulation is applied at the homogeneous material level, data on substance concentrations needs to be transferred through the supply chain to the final producer. An IPC standard has recently been developed and published to facilitate this data exchange, IPC-1752.<ref>[http://www.ipc.org/ipc-175x]  {{webarchive|url=https://web.archive.org/web/20060315161952/http://www.ipc.org/ipc-175x|date=15 March 2006}}</ref> It is enabled through two PDF forms that are free to use.

RoHS applies to these products in the EU whether made within the EU or imported. Certain exemptions apply, and these are updated on occasion by the EU.

===Examples of product components containing restricted substances===
RoHS restricted substances have been used in a broad array of consumer electronics products. Examples of components that have contained lead include:
* paints and pigments
* PVC (vinyl) cables as a stabiliser (e.g., power cords, USB cables)
* [[solder]]s
* printed circuit board finishes, leads, internal and external interconnects
* glass in television and photographic products (e.g., CRT television screens and camera lenses)
* metal parts
* lamps and bulbs
* batteries
* [[integrated circuits]] or microchips

Cadmium is found in many of the components above; examples include plastic pigmentation, [[nickel–cadmium battery|nickel–cadmium (NiCd) batteries]] and [[cadmium sulfide|CdS]] photocells (used in night lights). Mercury is used in lighting applications and automotive switches; examples include [[fluorescent lamp]]s and [[mercury switch|mercury tilt switches]] (these are rarely used nowadays). Hexavalent chromium is used for metal finishes to prevent corrosion. Polybrominated biphenyls and diphenyl ethers/oxides are used primarily as flame retardants.<ref>{{cite web |url=http://thor.inemi.org/webdownload/newsroom/Presentations/11.pdf |title=Elimination of RoHS Substances in Electronic Products |publisher=Thor.inemi.org |access-date=3 July 2015 |url-status=live |archive-url=https://web.archive.org/web/20160304003535/http://thor.inemi.org/webdownload/newsroom/Presentations/11.pdf |archive-date=4 March 2016}}</ref>

=== Hazardous materials and the high-tech waste problem ===
RoHS and other efforts to reduce hazardous materials in electronics are motivated in part to address the global issue of consumer electronics waste. As newer technology arrives at an ever-increasing rate, consumers are discarding their obsolete products sooner than ever. This waste ends up in landfills and in countries like China to be "recycled".<ref name=es071873x/>

<blockquote>In the fashion-conscious mobile market, 98 million U.S. cell phones took their last call in 2005. All told, the EPA estimates that in the U.S. that year, between 1.5 and 1.9&nbsp;million tons of computers, TVs, VCRs, monitors, cell phones, and other equipment were discarded. If all sources of electronic waste are tallied, it could total 50&nbsp;million tons a year worldwide, according to the UN Environment Programme.<ref name="nationalgeographic1">{{cite web |url=http://ngm.nationalgeographic.com/2008/01/high-tech-waste/carroll-text |title=High-Tech Waste – National Geographic Magazine |work=National Geographic |date=2013-04-25 |access-date=2015-07-03 |url-status=dead |archive-url=https://web.archive.org/web/20180325045021/http://ngm.nationalgeographic.com/2008/01/high-tech-waste/carroll-text |archive-date=2018-03-25}}</ref></blockquote>

American electronics sent offshore to countries like Ghana in West Africa under the guise of recycling may be doing more harm than good. Not only are adult and child workers in these jobs being poisoned by heavy metals, but these metals are returning to the U.S. "The U.S. right now is shipping large quantities of leaded materials to China, and China is the world's major manufacturing center," [[Jeffrey Weidenhamer|Dr. Jeffrey Weidenhamer]] says, a chemistry professor at Ashland University in Ohio. "It's not all that surprising things are coming full circle and now we're getting contaminated products back."<ref name=es071873x>{{cite journal |doi=10.1021/es071873x |title=Heavy Metals Concentrations of Surface Dust from e-Waste Recycling and Its Human Health Implications in Southeast China |year=2008 |last1=Leung |first1=Anna O. W. |last2=Duzgoren-Aydin |first2=Nurdan S. |last3=Cheung |first3=K. C. |last4=Wong |first4=Ming H. |journal=Environmental Science & Technology |volume=42 |issue=7 |pages=2674–80 |pmid=18505015|bibcode=2008EnST...42.2674L |doi-access=}}
*{{cite news |author=Martin LaMonica |date=15 April 2008 |title=Study: E-waste recycling poisons people with heavy metals |work=CNET News |url=http://news.cnet.com/8301-11128_3-9919304-54.html}}</ref>

=== Changing toxicity perceptions ===
In addition to the high-tech waste problem, RoHS reflects contemporary research over the past 50 years in biological toxicology that acknowledges the long-term effects of low-level chemical exposure on populations. New testing is capable of detecting much smaller concentrations of environmental toxicants. Researchers are associating these exposures with neurological, developmental, and reproductive changes.

RoHS and other environmental laws are in contrast to historical and contemporary law that seek to address only acute toxicology, that is direct exposure to large amounts of toxic substances causing severe injury or death.<ref>{{cite web |url=http://www.rohswell.com/News/Genl037-New-Toxicity.php |title=Archive |publisher=Rohswell.com |access-date=3 July 2015 |url-status=dead |archive-url=https://web.archive.org/web/20131125233538/http://rohswell.com/News/Genl037-New-Toxicity.php |archive-date=25 November 2013}}</ref>

=== Life-cycle impact assessment of lead-free solder ===
The [[United States Environmental Protection Agency]] (EPA) has published a [[life-cycle assessment]] (LCA) of the environmental impacts of lead-free and tin–lead [[solder]], as used in electronic products.<ref name="EPALifecycle">[http://www.epa.gov/opptintr/dfe/pubs/solder/lca/index.htm] {{webarchive|url=https://web.archive.org/web/20140314205628/http://www.epa.gov/opptintr/dfe/pubs/solder/lca/index.htm|date=14 March 2014}}</ref> For bar solders, when only lead-free solders were considered, the tin/copper alternative had the lowest (best) scores. For paste solders, [[bismuth]]/[[tin]]/silver had the lowest impact scores among the lead-free alternatives in every category except [[non-renewable resource]] consumption. For both paste and bar solders, all of the lead-free solder alternatives had a lower (better) LCA score in toxicity categories than tin/lead solder. This is primarily due to the toxicity of lead, and the amount of lead that leaches from printed wiring board assemblies, as determined by the leachability study conducted by the partnership. The study results are providing the industry with an objective analysis of the life-cycle environmental effects of leading candidate alternative lead-free solders, allowing industry to consider environmental concerns along with the traditionally evaluated parameters of cost and performance. This assessment is also allowing industry to redirect efforts toward products and processes that reduce solders' environmental footprint, including energy consumption, releases of toxic chemicals, and potential risks to human health and the environment. Another life-cycle assessment by IKP, University of Stuttgart, shows similar results to those of the EPA study.<ref>{{cite web |url=http://leadfree.ipc.org/files/RoHS_15.pdf |title=IKP, Department of Life-Cycle Engineering |publisher=Leadfree.ipc.org |access-date=3 July 2015 |url-status=dead |archive-url=https://web.archive.org/web/20090225155540/http://leadfree.ipc.org/files/RoHS_15.pdf |archive-date=25 February 2009}}</ref>

===Life-cycle impact assessment of BFR-free plastics===
The ban on concentrations of [[brominated flame retardant]]s (BFR) above 0.1% in plastics has affected plastics recycling. As more and more products include recycled plastics, it has become critical to know the BFR concentration in these plastics, either by tracing the origins of the recycled plastics to establish the BFR concentrations, or by measuring the BFR concentrations from samples. Plastics with high BFR concentrations are costly to handle or to discard, whereas plastics with levels below 0.1% have value as recyclable materials.

There are a number of analytical techniques for the rapid measurement of BFR concentrations. [[X-ray fluorescence spectroscopy]] can confirm the presence of bromine (Br), but it does not indicate the BFR concentration or specific molecule. [[Ion attachment mass spectrometry]] (IAMS) can be used to measure BFR concentrations in plastics. The BFR ban has significantly affected both upstream (plastic material selection) and downstream (plastic material recycling).{{citation needed|date=March 2014}}

=== {{anchor|RoHS 2}}2011/65/EU (RoHS 2) ===
The RoHS 2 directive (2011/65/EU) is an evolution of the original directive and became law on 21&nbsp;July 2011 and took effect on 2&nbsp;January 2013. It addresses the same substances as the original directive while improving regulatory conditions and legal clarity. It requires periodic re-evaluations that facilitate gradual broadening of its requirements to cover additional electronic and electrical equipment, cables and spare parts.<ref name="HP-RoHS2">{{cite web |author=United States |url=http://www.hp.com/hpinfo/globalcitizenship/environment/pdf/RoHS2Addendum.pdf |title=Living Progress &#124; HP® Official Site |publisher=Hp.com |access-date=3 July 2015 |url-status=live |archive-url=https://web.archive.org/web/20120917032105/http://www.hp.com/hpinfo/globalcitizenship/environment/pdf/RoHS2Addendum.pdf |archive-date=17 September 2012}}</ref> The CE logo now indicates compliance and RoHS 2 declaration of conformity is now detailed (see below).{{Citation needed|date=May 2017}}

In 2012, a final report from the [[European Commission]] revealed that some EU Member States considered all toys under the scope of the primary RoHS 1 Directive 2002/95/EC, irrespective of whether their primary or secondary functions were using electric currents or electromagnetic fields. From the implementation of RoHS 2 or RoHS Recast Directive 2011/65/EU on, all the concerned Member States will have to comply with the new regulation.

The key difference in the recast is that it is now necessary to demonstrate conformity in a similar way to the LVD and EMC directives.  Not being able to show compliance in sufficiently detailed files, and not ensuring it is implemented in production is now a criminal offence.  Like the other CE marking directives it mandates production control and traceability to the technical files.  It describes two methods of achieving presumption of conformity (Directive 2011/65/EU Article 16.2), either technical files should include test data for all materials or a standard accepted in the official journal for the directive, is used.  Currently the only standard is EN IEC 63000:2018 (based on IEC 63000:2016 superseded EN 50581:2012), a risk based method to reduce the amount of test data required (Harmonised Standards list for RoHS2, OJEU C363/6).

One of the consequences of the requirement to demonstrate conformity is the requirement to know the exemption use of each component, otherwise it is not possible to know compliance when the product is placed on the market, the only point in time the product must be 'compliant'.  Many do not understand that 'compliance' varies depending on what exemptions are in force and it is quite possible to make a non-compliant product with 'compliant' components.  Compliance must be calculated on the day of placing on the market.  In reality this means knowing the exemption status of all components and using up stock of old status parts before the expire date of the exemptions (Directive 2011/65/EU Article 7.b referring to Decision 768/2008/EC Module A Internal production control).   Not having a system to manage this could be seen as a lack of diligence and a criminal prosecution could occur (UK Instrument 2012 N. 3032 section 39 Penalties).

RoHS 2 also has a more dynamic approach to exemptions, creating an automatic expiration if exemptions are not renewed by requests from industry.  Additionally new substances can be added to the controlled list, with 4 new substances expected to be controlled by 2019.  All these mean greater information control and update systems are required. {{citation needed|date=October 2015}}

Other differences include new responsibilities for importers and distributors and markings to improve traceability to the technical files.  These are part of the NLF for directives and make the supply chain a more active part of the policing (Directive 2011/65/EU Articles 7, 9, 10).

There has been a recent additional amendment 2017/2102 to 2011/65

=== 2015/863 (RoHS 2 amendment) ===

The RoHS 2 directive (2011/65/EU) contains allowance to add new materials and 4 materials are highlighted for this attention in the original version, the amendment 2015/863 adds four additional substances to Annex II of 2011/65/EU (3/4 of the new restrictions are recommended for investigation in the original directive, ref Para 10 of preamble).   This is another reason that simple component RoHS compliance statements are not acceptable as compliance requirements vary depending on the date the product is placed on the market (ref IEC 63000:2016).   The additional four substances restriction and evidence requirements shall be applied for products placed on the market on or after 22 July 2019 except where exemptions permit as stated in Annex III.,<ref name="Eur-lex.europa.eu"/> although at the time of writing no exemptions exist or have been applied for, for these materials.   
The four additional substances are
# Bis(2-Ethylhexyl) phthalate (DEHP)
# Benzyl butyl phthalate (BBP)
# Dibutyl phthalate (DBP)
# Diisobutyl phthalate (DIBP)
The maximum permitted concentrations in non-exempt products are 0.1%.

The new substances are also listed under the REACH Candidate list, and DEHP is not authorised for manufacturing (use as a substance) in the EU under Annex XIV of REACH.<ref>{{cite web |url=https://echa.europa.eu/candidate-list-table |title=Candidate List of substances of very high concern for Authorisation – ECHA |publisher=Europa (web portal) |url-status=live |archive-url=https://web.archive.org/web/20170712130156/https://echa.europa.eu/candidate-list-table |archive-date=12 July 2017}}</ref>