Producer responsibility

In addition to a range of health and safety regulations relating to all electrical and electronic equipment (EEE), there are two important environmental regulations that must be considered: RoHS (details below) and the Waste Electrical and Electronic Equipment regulations. Furthermore, depending on the type of EEE involved, there may be additional requirements relating to energy efficiency and marking.

Does RoHS apply to my business?

If you produce – directly or using a third party – import or sell electrical and electronic equipment (EEE) in the EU, then RoHS applies to you.

RoHS stands for the Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment and the current Regulations have been in force since 2 January 2013. They set maximum limits for Lead, Mercury, Cadmium, Polybrominated Biphenyls, Polybrominated Diphenyl Ethers and Hexavalent Chromium used in EEE and require EEE products to be correctly marked.

By 2019, all non-exempted EEE will be covered by the regulations with products being phased in over a 6.5 year period. Furthermore, from 22 July additional material restrictions apply.

Material thresholds

Lead – <1000 parts per million. Commonly found in solder, lead-acid batteries, electronic components, cable sheaths and cathode ray tubes.

Mercury – <100 parts per million. Commonly found in batteries, switches, thermostats and fluorescent lamps.

Cadmium – <100 parts per million. Commonly found in electrical devices, pigments and printing inks and car batteries.

Hexavalant Chromium – <1000 parts per million. Commonly found in pigments, anti-corrosive coatings and some plastics.

Polybrominated Biphenyls (PBB) – <1000 parts per million. Commonly used as a flame retardant, particularly in plastics.

Polybrominated Diphenyl Ethers (PBDE) – <1000 parts per million. Commonly used as a flame retardant,  often in plastics, but also in printed circuit boards.

bis(2-ethylhexyl) phthalate (DCEHP) from 22/7/2019. <1000 parts per million. Commonly used in PVC products.

butyl benzyl phthalate (BPP) –  from 22/7/2019. <1000 parts per million. Commonly used in vinyl foams.

dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP) – from 22/7/2019. <1000 parts per million. Commonly used in inks and lacquers respectively.

Products already covered by RoHS

Category 1 – Large household appliances such as kitchen white goods, air conditioners, massage chairs etc;

 Category 2 – Small household appliances such as torches, plug in air fresheners, massage pads for chairs etc;

Category 3 –  IT and telecomms equipment such as phones, tablets, computers and associated chargers and leads etc;

Category 4 – Consumer equipment, including cameras, stereos and televisions etc;

Category 5 – Lighting equipment such as bulbs, light fittings and ornamental lighting etc;

Category 6 – Electrical and electronic tools such as drills, saws, lathes etc;

Category 7 – Toys, leisure and sports equipment such as powered treadmills, racing sets and video games etc;

Category 8 – since 22 July 2016, medical devices (including in-vitro) such as blood pressure monitors. electronic thermometers, centrifuges and blood gas analysers etc;

Category 9 – since 22 July 2014, non-industrial monitoring and control instruments such as domestic smoke detectors, domestic cctv systems etc;

Category 10 – Automatic dispensers such as vending and cash machines etc.

Products yet to be covered by RoHS

From 22 July 2017Category 9 – Industrial monitoring and control panels such as control panels and fire alarm systems etc;

From 23 July 2019

Category 11 – all other electrical and electronic equipment not covered elsewhere or specifically excluded, including two wheeled electric vehicles which are not type approved. Specific exclusions apply equipment designed solely for use in national security or military applications and for equipment designed only to be sent into space. There are also exemptions for some ‘large scale’ industrial tools and fixed installations, active implantable medical devices, professional non-road mobile machinery, R&D equipment only available business-to-business and ‘means of transport for persons or goods’ not otherwise included.

We can help you to understand exactly how RoHS affects you and what you must do to remain compliant. Contact us today and talk to an expert about your needs.