The EU RoHS Directive: Part One — Scope, Substances, and Thresholds

Overview of the RoHS Directive

The current version of the EU RoHS Directive (2011/65/EU) restricts the use of ten hazardous substances in the manufacture of various types of electrical and electronic equipment (EEE). The legislation was designed to address the rapidly growing waste stream generated by electrical and electronic products.

RoHS is closely linked to the Waste Electrical and Electronic Equipment (WEEE) Directive, which sets collection, recycling, and recovery targets for electrical goods and forms part of a broader legislative effort to tackle the growing problem of toxic e-waste. Together, the objective of RoHS and WEEE is to minimize the impact of electronic manufacturing, use, treatment, and disposal on human health and the environment—in effect, to promote environmentally friendly materials and manufacturing processes. The root cause of the underlying problem lies in the disposal of electronic waste in landfills, where hazardous substances can leach into groundwater supplies, eventually reaching municipal water systems and posing risks to human health.

Scope and Industry Impact

The RoHS Directive has a significant impact on industry. It covers not only EEE products directly, but also products containing components or sub-assemblies that depend on electric currents or electromagnetic fields—making the scope of RoHS considerably broad. Any producer, reseller, or distributor placing such products on the EU market will be affected if it uses any of the restricted substances above the maximum permitted level.

Restricted Substances and Maximum Permitted Levels

Table 1. Substances Restricted Under RoHS (2011/65/EU) and Their Maximum Permitted Levels

The maximum permitted level is expressed as a percentage by weight of a "homogeneous material." This term has caused some confusion regarding its precise definition. The directive states that a homogeneous material is a unit that cannot be mechanically disjointed into separate materials. In other words, a homogeneous material is either:

1. A material with a uniform composition throughout, or
2. A material consisting of a combination of materials that cannot be separated by mechanical actions such as unscrewing, cutting, crushing, grinding, or abrasive processes.

Product Categories Covered by RoHS

The RoHS Directive (2011/65/EU) applies to electrical and electronic equipment that depends on electric currents or electromagnetic fields to function properly. The restricted substances listed above apply across the following product categories:

1. Large household appliances (refrigerators, washers, stoves, air conditioners, etc.)
2. Small household appliances (vacuum cleaners, hair dryers, coffee makers, irons, etc.)
3. IT and telecommunications equipment (printers, copiers, phones, etc.)
4. Consumer equipment (TVs, DVD players, stereos, video cameras, etc.)
5. Lighting equipment (lamps, lighting fixtures, lightbulbs, etc.)
6. Electrical and electronic tools (drills, saws, nail guns, sprayers, lathes, trimmers, blowers, etc.)
7. Toys, leisure, and sports equipment (video games, electric trains, treadmills, etc.)
8. Medical devices (CT scanners, defibrillators, pulmonary ventilators, infusion pumps, etc.)
9. Monitoring and control instruments, including industrial monitoring and control instruments (smoke detectors, heating regulators, thermostats, etc.)
10. Automatic dispensers (vending machines, ATMs, etc.)
11. Other EEE not covered by the categories above (two-wheeled vehicles, e-cigarettes, etc.)

It should be noted that the RoHS Directive does not apply to batteries and accumulators used in electrical and electronic equipment.

RoHS and Related Legislation: The ELV Directive

While transportation applications are generally exempt from RoHS, cars fall under the scope of the EU's End of Life Vehicles (ELV) Directive (2000/53/EC). The ELV Directive aims to make vehicle dismantling and recycling more environmentally friendly, to set clear, quantified targets for the reuse, recycling, and recovery of vehicles and their components, and to encourage manufacturers to design new vehicles with recyclability in mind from the outset.