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  1. How can RoHS compliance be demonstrated / proven?
  2. What is the RoHS Directive?
  3. Where are the restricted substances found?
  4. What is the definition of electrical and electronic equipment used by RoHS?
  5. Will all RoHS compliant products be identified with a new part number?
  6. How can I test components for RoHS compliance?
  7. Can I still manufacture non-compliant products?
  8. Is there a difference between "lead-free", "green" and "RoHS compliant"?
  9. Does RoHS apply only to newly designed products?
  10. What is the definition of an "Homogeneous Material"?
  11. Will I still be able to buy and use non-compliant components?
  12. Which countries are affected by RoHS? Where does the RoHS Directive apply legally?
  13. Does the RoHS Directive specify how compliant products should be marked?
  14. Who is affected by RoHS
  15. What is the definition of RoHS compliance?
  16. What is the reason for implementing the RoHS Directive?
  17. What is the objective of the RoHS Directive?
  18. How will RoHS & WEEE be implemented?
  19. What types of equipment (EEE) are affected by RoHS?
  20. What alternatives are available to the restricted substances?
  21. How does RoHS affect maintenance and repair?
  22. What are the maximum permitted concentrations of the restricted substances?
  23. I have heard that cutting and welding materials containing Chromium can create Hexavalent Chromium. Is this a problem?

 How can RoHS compliance be demonstrated / proven?

The RoHS Directive restricts the use of the six substances but does not specify how producers can comply or the requirements for market surveillance; this will be specified in national law.
Two key principles of the Directive are:
  • Products "placed on the market" after 1st July 2006 will be presumed to comply with RoHS. This "self declaration" is consistent with a number of other EU Directives (e.g. those requiring the CE mark). The authorities in each member state will introduce their own surveillance regime and conduct checks where appropriate.
  • Producers will be expected to be able to demonstrate that they have shown "due diligence" in ensuring that their products are RoHS compliant. This principle has been used for other legislation, but it is unclear what "due diligence" actually means.
The requirements of "due diligence" may vary between countries and also between products. There are a number of potential methods of demonstrating due diligence; the following steps may be helpful in defining a suitable method:
  • Does my product need to comply?
  • If so, contact component / material suppliers to obtain compliance declarations (unfortunately there is no agreed standard for these)
  • Identify any part number changes and update purchasing systems
  • Retain compliance declarations in a "technical file"
  • Am I confident in the information provided?
  • Undertake a risk analysis to determine the level of confidence
  • How likely is the product to contain any of the restricted substances?
  • Is compliance indicated on paperwork and / or product packaging?
  • Has the manufacturer or another party in the supply chain provided the compliance information?
  • Has previous information been reliable?
  • Is this product part of a range / family which is already compliant?
  • If changing suppliers review compliance implications
  • If compliance is in doubt consider testing / other methods of confirming compliance
  • Testing can be difficult and costly, target its use on high risk components / suppliers
  • Request a test report from the supplier
  • Consider sharing compliance information with business partners
  • Maintain "technical files" for at least 4 years as evidence of "due diligence"
Customers may also request proof of compliance. This might range from a "Declaration of Compliance" for specific products to a "material control plan" describing the processes used to determine and maintain compliance.

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 What is the RoHS Directive?

RoHS stands for the "Restriction of the use of Certain Hazardous Substances in Electrical and Electronic Equipment" and applies to equipment put on the market from 1st July 2006. The Directive (2002/95/EC) restricts the use of 6 substances (lead, mercury, cadmium, hexavalent chromium and the 2 brominated flame retardants, PBB & PBDE). RoHS is closely linked to the WEEE Directive and takes its scope from it.

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Where are the restricted substances found?

The restricted materials can be found in a variety of different applications, including the following:

Lead (Pb)
Potential usage
Termination coatings
Paint (pigment or drier)
PVC (stabiliser)
Cadmium (Cd)
PVC (stabiliser)
Mercury (Hg)
Fluorescent lamps
Hexavalent Chromium ((Cr(VI))
Anti corrosion coating (on zinc or aluminium)
Corrosion resistant paints
Flame retardants used in plastics (PBB no longer manufactured)

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 Apa definisi peralatan listrik dan elektronik yang digunakan oleh RoHS?

RoHS mempengaruhi jenis tertentu dari EEE (Peralatan Listrik dan) dan didefinisikan dalam WEEE Directive sebagai: "Peralatan yang tergantung pada arus listrik atau medan elektromagnetik untuk bekerja dengan baik dan peralatan untuk generasi, transfer dan pengukuran arus tersebut dan bidang jatuh di bawah kategori yang ditetapkan dalam Lampiran IA dan dirancang untuk digunakan dengan tegangan tidak melebihi 1000 Volt untuk arus bolak-balik dan 1500 Volt untuk arus searah "

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 Apakah semua produk yang mematuhi RoHS akan diidentifikasi dengan nomor komponen baru?

A variety of different approaches have been taken to RoHS and part numbering:
  • some manufacturers identify RoHS compliant products with a new part number
  • some add a suffix to the existing part number (e.g. the compliant version of part number 1234 becomes1234-G, or 1234PBF etc.)
  • others are not planning to change the part number at all
This all adds to the complexity of managing the RoHS transition.

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 Bagaimana saya dapat menguji komponen untuk kepatuhan RoHS?

There are various ways of testing for RoHS compliance, ranging from fairly simple methods to highly complex chemical analysis. Whichever technique is chosen it is important to ensure that it tests the "homogeneous material" and not the entire component or assembly.

One of the most cost-effective methods of RoHS screening is a technique known as ED-XRF (electro dispersive x-ray fluorescence). In this technique the sample is excited with an x-ray beam and the resultant emissions collected and analysed. The emissions spectra can identify the presence and concentration of materials present.

The technique does have some limitations, including
  • Some understanding of the sample is required before testing, otherwise the results may be misleading
  • It can only detect elements in the periodic table from Aluminium to Uranium
  • It cannot detect organic materials like plastics
  • It can detect the presence of bromine and chromium, but it cannot distinguish between the specific compounds

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 Masih dapatkah saya memproduksi produk yang tidak mematuhi?

Jika produk termasuk dalam lingkup Petunjuk RoHS, maka masih legal untuk memproduksi versi yang tidak mematuhi, namun tidak dapat dijual di UE setelah 1 Juli 2006. Pada praktiknya permintaan produk yang tidak memenuhi syarat cenderung sangat kecil.

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 Apakah ada perbedaan antara "bebas timbal", "hijau", dan "mematuhi RoHS"?

Beberapa istilah ini sering digunakan bergantian, tetapi artinya mungkin tidak sama. Dari sudut pandang produsen ada dua aspek kepatuhan komponen:
  • Zat yang dibatasi: apak
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     Does RoHS apply only to newly designed products?

    No, RoHS applies to the manufacture and import of the 8 specified categories of EEE (electrical and electronic equipment) from 1st July 2006. It affects designs already in existence at this time as well as new equipment.

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     What is the definition of an "Homogeneous Material"?

    An homogeneous material has been defined as a material which can be mechanically separated from another material (e.g. through scraping or abrasion), without chemical separation. The "tinning" on a component lead is therefore an homogeneous material as it can be separated from the copper wire, whereas the Lead (Pb) contained in a ceramic cannot be separated from the ceramic by mechanical means. Another example of an homogeneous material is the plastic sheath on a cable.

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     Will I still be able to buy and use non-compliant components?

    Non-compliant components may still be used for the repair of "historic" electrical equipment (i.e. put on the market before 1st July 2006). They may also be used in the manufacture and repair of products outside the scope of RoHS.

    The availability of non-compliant components will be dictated by the demand for them. For economic reasons component manufacturers will generally only produce one version of a component. If a significant proportion is used in the manufacture of new electrical equipment then the component is likely to be available only as "RoHS compliant". Certain components are only manufactured as spare parts for existing equipment and will therefore never be made compliant.

    Distributors may stock supplies of non-compliant components to support applications outside the scope of RoHS. This is likely to be a short-term situation as supplies will be limited.

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     Which countries are affected by RoHS? Where does the RoHS Directive apply legally?

    RoHS is an EU Directive and therefore only legally applies within the EU member states. However RoHS has a wider impact for 2 main reasons:

    • Similar legislation exists or is being considered in a number of other countries (including USA & China)
    • The market for Electronics is global and Europe is a major part of it. RoHS compliant products can continue to be sold worldwide, whereas non-compliant products will not be permitted to be "put on the market" in Europe after 1st July 2006. Electronics manufacturers are therefore moving to RoHS compliant production.
    Consequently RoHS is becoming a global "standard" even though it is not a legal requirement outside of the EU.

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     Does the RoHS Directive specify how compliant products should be marked?

    Unlike the WEEE Directive, RoHS does not specify a "compliance mark". A number of manufacturers now indicate compliance on product packaging by using symbols or a suffix to their part number (e.g. PBF, LF, or G).

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     Who is affected by RoHS?

    The effects of RoHS are widespread. Legally it affects anyone who:
    • Manufactures EEE in Europe
    • Imports EEE into Europe>
    • Applies their brand to EEE in Europe
    EEE = Electrical & Electronic Equipment (RoHS restricts 8 of the 10 categories specified in the WEEE Directive).

    However the real impacts are far wider, RoHS has implications for many other parts of the supply chain including:
    • Raw material manufacturers
    • Component manufacturers
    • PCB and sub-assembly manufacturers
    • Distributors
    • Retailers
    • Design engineers
    • Etc.

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     What is the definition of RoHS compliance?

    A RoHS compliant product is defined as not containing any of the restricted materials in concentrations exceeding the maximum permitted levels. i.e. 0.1% by weight for Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr [VI]), and the 2 brominated flame-retardants (PBB & PBDE) and 0.01% for Cadmium (Cd) in an homogeneous material.

    The RoHS Directive applies only to the specified categories of electrical products; it does not apply to the manufacture and sale of components. However, in order to manufacture compliant equipment, "compliant" components and lead-free solders will be required. It is important that the components used do not exceed these limits and (where necessary) are able to withstand the higher process temperatures required by lead-free solders.

    RS Components has obtained compliance information from its suppliers and taken all reasonable steps to confirm this before making it available to customers.

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     What is the reason for implementing the RoHS Directive? What is the objective of the RoHS Directive?

    RoHS should be considered in association with the WEEE Directive. Their objectives are jointly to improve environmental performance at all stages in a product's life cycle. Some of the materials used in electronics can present environmental and health hazards during manufacturing or at "end of life" disposal. The EU has therefore taken steps to restrict the use of these materials (RoHS) and encourage the safe disposal or re-use of electrical equipment (WEEE).

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     How will RoHS & WEEE be implemented?

    There is a key difference between the WEEE and RoHS Directives. WEEE specifies minimum standards that each member state must implement but may exceed. RoHS is a single market Directive, which means it must be implemented identically by each member state.

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     What types of equipment (EEE) are affected by RoHS?

    The RoHS Directive takes its scope from Annex 2 of the WEEE Directive, but excludes 2 categories (Monitoring & Control and Medical devices). The range of affected products is listed below, further guidance is expected to be issued by national bodies responsible for implementing and enforcing the directives on a country by country basis (e.g the Department of Trade & Industry and National Weights and Measures Laboratory in the UK)

    Large Household appliances:
    - Large cooling appliances
    - Refrigerators & Freezers
    - Other large appliances used for refrigeration, conservation and storage of food
    - Washing machines
    - Clothes dryers
    - Dish washing machines
    - Cooking
    - Electric stoves
    - Electric hot plates
    - Microwaves
    - Other large appliances used for cooking and other processing of food
    - Electric heating appliances & electric radiators
    - Other large appliances for heating rooms, beds, seating furniture
    - Electric fans & air conditioner appliances
    - Other fanning, exhaust ventilation and conditioning equipment

    Small household appliances:
    - Vacuum cleaners
    - Carpet sweepers
    - Other appliances for cleaning
    - Appliances used for sewing, knitting, weaving and other processing for textiles
    - Irons and other appliances for ironing, mangling and other care of clothing
    - Toasters
    - Fryers
    - Grinders, coffee machines and equipment for opening or sealing containers or packages
    - Electric knives
    - Appliances for hair-cutting, hair drying, tooth brushing, shaving, massage and other body care appliances
    - Clocks, watches and equipment for the purpose of measuring, indicating or registering time
    - Scales

    IT and telecommunications equipment:
    - Centralised data processing: Mainframes, Minicomputers, Printer units
    - Personal computing: Personal computers (CPU, mouse, screen and keyboard included), Laptop computers (CPU, mouse, screen and keyboard included), Notebook and Notepad computers
    - Printers
    - Copying equipment
    - Electrical and electronic typewriters
    - Pocket and desk calculators and other products and equipment for the collection, storage, processing, presentation or communication of information by electronic means
    - User terminals and systems
    - Facsimile
    - Telex
    - Telephones, pay telephones, cordless telephones,
    - cellular telephones, answering systems and other products or equipment of transmitting sound, images or other information by telecommunications

    Electrical and electronic tools (with the exception of large-scale stationary industrial tools):
    - Drills
    - Saws - Sewing machines
    - Equipment for turning, milling, sanding, grinding, sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar processing of wood, metal and other materials
    - Tools for riveting, nailing or screwing or removing rivets, nails, screws or similar uses
    - Tools for welding, soldering or similar use
    - Equipment for spraying, spreading, dispersing or other treatment of liquid or gaseous substances by other means
    - Tools for mowing or other gardening activities

    Lighting equipment:
    - Luminaires for fluorescent lamps
    - Straight fluorescent lamps
    - Compact fluorescent lamps
    - High intensity discharge lamps, including pressure sodium lamps and metal halide lamps
    - Low pressure sodium lamps
    - Other lighting or equipment for the purpose of spreading or controlling light with the exception of filament bulbs

    Consumer equipment:
    - Radio sets
    - Television sets
    - Videocameras
    - Video recorders
    - Hi-fi recorders
    - Audio amplifiers
    - Musical instruments
    - And other products or equipment for the purpose of recording or reproducing sound or images, including signals or other technologies for the distribution of sound and image than by telecommunications

    Toys, leisure and sports equipment:
    - Electric trains or car racing sets
    - Hand-held video game consoles
    - Video games
    - Computers for biking, diving, running, rowing, etc.
    - Sports equipment with electric or electronic components
    - Coin slot machines
    · - Automatic dispensers

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     What alternatives are available to the restricted substances?

    There are various alternatives to the restricted substances, however none has exactly the same characteristics. Some of the most common alternatives are listed below:

    Component Banned substance Alternatives
    Passives and actives Tin/lead terminations Sn, SnCu, SnBi. Whiskers concern
    Galvanised fasteners Cr(6) passivation Various, all less Effective
    Solders Lead Lead-free alloys - all Different
    Contacts AgCdO AgSnO2
    Photocell CdS Silicon, etc.
    Switch, relays, sensors Mercury Usually gold
    Connectors Pb & Cd pigments, PBDE - flame retardant Various other flame retardants
    Batteries Pb, Cd, Hg RoHS does no include batteries but Battery Directive applies

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     How does RoHS affect maintenance and repair?

    Non-compliant components can be used to maintain or repair Electrical and Electronic Equipment (see 'What is the definition of EEE?') which is put on the market before 1st July 2006.

    Many components will not be available indefinitely in a non-compliant form. It is possible to make an acceptable tin/lead solder joint onto a "lead-free" component. Consequently repair of non-compliant EEE with compliant components should not normally cause any problems.

    The repair of non-compliant equipment with lead-free solders should be avoided if possible. Lead-free solders melt at higher temperatures than leaded solders and this may cause problems with existing solder joints and components.

    N.B. EEE put on the market after 1st July 2006 should only be repaired using compliant components and lead-free solder.

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     What are the maximum permitted concentrations of the restricted substances?

    The maximum concentrations by weight permitted in an homogeneous material are 0.1% for Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr [VI]) and the 2 brominated flame-retardants (PBB & PBDE), and 0.01% for Cadmium (Cd).

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     I have heard that cutting and welding materials containing Chromium can create Hexavalent Chromium. Is this a problem?

    It appears that welding stainless steel or chromium plated steel produces toxic fumes which contain chromium trioxide (CrVI). This is possible as chromium metal will oxidise if heated and at welding temperature may make a small amount of CrVI. This must form as minute dust particles to exist in the hexavalent state because the oxide (CrO3) is unstable above its melting point, which is 197 deg C, decomposing to trivalent chromium oxide. There will not be Cr6 on the welded stainless steel surface because the steel will be too hot and any CrO3 that is present will decompose to CrIII.

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