REACH & RoHS: Background

REACH-/RoHS-Conformity is mainly applicable to manufacturers and importers of electrical and electronic devices. RoHs stands for "Restriction of the use of certain hazardous substances in electrical and electronic equipment" or " Restriction of certain hazardous substances" for short.

The RoHS guidelines of the European Union (Guideline 2002/95/EU) was introduced to restrict the use of certain substances in electrical or electronic devices and components that are harmful to health and for the environment. These guidelines have banned particularly problematic toxic and environmentally hazardous elements such as lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenylether (PBDE) in quantities not exceeding a maximum proportion of 0.1 percent by mass in products.

Furthermore, the guidelines have prohibited lead soldering of electronic components and flame retardants for cable production. The guideline thereby directly affects importers and other companies, trade chains and finally also the consumers. Many of the production methods used formerly are no longer permissible.

imds professional offers individual REACH consultation by an interdisciplinary team of experts. Benefit from our knowhow on the EU Chemicals Regulation and RoHs. Make an appointment for consultation!

Consequences of the Regulation for Companies

The use mainly of lead-free solder poses a challenge for the automotive industry and other sectors. The option of using solders containing silver is not only more expensive but also present problems for manufacturers quality-wise. Owing to such qualitative limitations a series of exemptions are applicable even today, inter alia in the field of medicine and military and also in automotive electronics. For example, the use of lead in starter batteries for heavy vehicles continues to be allowed and the use of lead in copper-based alloys for a maximum proportion of 4 percent by mass is valid.

The use of lead throws light on another peculiarity of RoHS: substance prohibitions can be issued without an exhaustive risk assessment for alternate substances/substitutes, the presence of a potential risk for human beings and the ecology alone is sufficient, as is the case of lead. Whether or not lead in electrical and electronic devices is actually hazardous to human health and what the risks in using lead substitutes are, have not been definitively substantiated till today. 

Exemptions and Special Provisions

What complicates implementation of RoHS also is that these exemptions are not uniformly valid across EU and there are special provisions permitted at the national level. For instance, car radios sold in shops are included in the guidelines in the Netherlands but not in other countries. Such special provisions can pose great difficulties for developers inasmuch as their products are not just sold in one EU country. They have to constantly take newly introduced exemptions into account. What's more, there can be a lapse of years between a request for exemption and its authorisation.

The WEEE Guideline

The WEEE (Directive Waste from Electrical and Electronic Equipment ) effective since 2003 is closely linked to the RoHs, which in turn is based on the EU Guideline 2002/96/EU. It is aimed at prevention, reduction and environmentally sound disposal of electrical and electronic waste by recycling at least four kilograms of electrical/electronic waste per resident per year.

Unlike REACH, RoHS covers substance restriction only for products falling under WEEE, i.e. for components of electrical and electronic devices. The area of application of the REACH Regulation is wider. REACH is also applicable to other sectors like the textile, toy or the automotive industries and does not just involve substance restrictions. However, since REACH is also applicable to the electronics industry and includes numerous chemicals also used in electronic components, REACH and RoHs share many areas of overlap.


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