ROHS PRODUCT CATEGORIES - RULES AND CERTIFICATION

EU RoHS now applies to most electical and electronic equipement. However the rules are slighly different depending on the RoHS product categories.

The Table of RoHS Product Categories

Product Category	Concentration Limit
1.	Large household appliances.
2.	Small household appliances.
3.	IT and telecommunications equipment.
4.	Consumer equipment.
5.	Lighting equipment.
6.	Electrical and electronic tools.
7.	Toys, leisure, and sports equipment.
8.	Medical devices.
9.	Monitoring and control instruments (including industrial ones).
10.	Automatic dispensers.
11.	Other EEE not covered by any of the categories above.

Examples of Product per RoHS Category

These examples are available from the WEEE Directive. They are only examples. Therefore, by analogy, feel free to see which ones seem to approach the primary function of your products.

RoHS Product Category 1 - Large Household Appliances

Cooling and refreshing:

Large cooling appliances
Refrigerators
Freezers
Other large appliances used for refrigeration, conservation, and storage of food
Electric fans
Air conditioners
Other fanning, exhaust, ventilation, and conditioning equipment

Heating:

Electric heating appliances
Electric radiators
Other large appliances for heating rooms, beds, and seating furniture

Cooking:

Cookers
Electric stoves
Electric hot plates
Microwaves
Other large appliances used for cooking and food processing

Clothing:

Washing machines
Clothes dryers

Dishwashing

RoHS Product Category 2 - Small Household Appliances

Measuring:

Clocks, watches, and devices for measuring, indicating, or recording time
Scales

Food Processing:

Toasters
Fryers
Grinders, coffee machines, and devices for opening or sealing containers or packages

Textile processing:

Appliances for sewing, knitting, weaving, and textile processing
Irons and other appliances for ironing, pressing, and clothing care

Cutting:

Electric knives
Appliances for hair cutting, hair drying, tooth brushing, shaving, massage, and other body care tasks

Cleaning:

Vacuum cleaners
Carpet sweepers
Other cleaning appliances

RoHS Product Category 3 - IT and Telecommunications Equipment

Centralized Data Processing:

Mainframes
Minicomputers
Printing units

Personal Computing:

Desktop computers (including CPU, mouse, monitor, and keyboard)
Laptops (including CPU, mouse, monitor, and keyboard)
Notebook PCs
Tablet PCs
Printers
Photocopy machines
Pocket and desktop calculators
Other devices for the collection, storage, processing, display, or communication of information electronically

User Terminals and Systems:

Mobile phones / Cell phones
Facsimile devices (fax)
Telex devices
Telephones
Cordless telephones
Other devices for transmitting audio, visuals, or data via telecommunications

RoHS Product Category 4 - Consumer Equipment and Photovoltaic Panels

Sound and Images:

Radios
Televisions
Camcorders
Video players
Hi-fi systems
Audio amplifiers
Musical instruments
Other devices for recording or reproducing sound or visuals, including signals or other technologies for distributing audio and video beyond telecommunications

Solar panels

RoHS Product Category 5 - Lighting Equiment

Fluorescent lamp fixtures, excluding household luminaires
Straight fluorescent tubes
Compact fluorescent lights (CFLs)
High-intensity discharge (HID) lamps, including high-pressure sodium and metal halide lamps
Low-pressure sodium lamps
Other lighting or devices for distributing or controlling light, excluding filament bulbs

RoHS Product Category 6 - Electrical and Electronic Tools (With the Exception of Large-Scale Stationary Industrial Tools)

Workshop:

Power drills
Power saws
Sewing machines
Machinery for turning, milling, sanding, grinding, cutting, shearing, drilling, boring, punching, folding, bending, or similar processing of wood, metal, and other materials
Tools for fastening, nailing, screwing, or removing fasteners, nails, screws, or similar applications
Tools for welding, soldering, or comparable uses

Managing liquids or gazes:

Devices for spraying, spreading, dispersing, or treating liquid or gaseous substances by other methods

Gardening:

Equipment for mowing or other horticultural activities

RoHS Product Category 7 - Toys, Leisure and Sports Equipment

Toys:

Electric trains or car racing sets

Sport:

Computers for cycling, diving, running, rowing, etc.
Sporting gear with electrical or electronic components

Leisure

Portable video game consoles
Video games
Coin-operated machines

RoHS Product Category 8 - Medical Devices (With the Exception of All Implanted and Infected Products)

Radiotherapy devices
Cardiology instruments
Dialysis machines
Respiratory ventilators
Nuclear medicine devices
Laboratory instruments for in vitro diagnostics
Analyzers
Freezers
Fertility test equipment
Other devices for detecting, preventing, monitoring, treating, or alleviating illness, injury, or disability

RoHS Product Category 9 - Monitoring and Control Instruments

Measuring, weighing, or adjusting devices for household or laboratory use
Thermostats
Smoke alarms
Heating controllers
Other monitoring and control instruments used in industrial settings (e.g., in control panels)

RoHS Product Category 10 - Monitoring and Control Instruments

Automatic dispensers for solid items
ATM – Automatic money dispensers
Automatic hot drink dispensers
Automatic dispensers for hot or cold bottles or cans
All devices that automatically dispense various types of products

RoHS Product Category 11 - Other EEE

This last category is a catch-all one. It applies only if your products:

Don’t fit into any of the 10 above categories, and
Are not excluded under EU RoHS.

RoHS Certification: Products Excluded from the Scope

Video transcription:

Do you know that the rules under the EU RoHS regulation can vary from a product to another? RoHS regulations share a set of rules, with slight differences depending on the type of product.

Different markets have restricted the use of certain hazardous substances in electrical and electronic equipment (EEE), like:

The European Union;
The United Kingdom;
The United Arab Emirates;
China;
Taiwan;
Russia;
California;
Turkey; or
Ukraine; etc.

There are the so-called RoHS regulations. In every jurisdiction, there is a list of out-of-scope products. This is the case in the European Union, under Directive 2011/65/EU and its amendments, for:

Military or aerospace equipment;
Large-scale stationary industrial tools or large-scale fixed installations, under specific conditions;
Non-road mobile machinery made available exclusively for professional use;
Equipment designed as part of excluded products, under conditions;
Etc.

If your products fall into such exclusions, then the RoHS limitations of hazardous substances like lead, mercury, or cadmium compounds, don’t apply.

EU RoHS Product Categories - Annex I

Despite exclusions, most products, B2C or B2B, fall within the EU RoHS scope, which is particularly broad. Annex I of Directive 2011/65/EU lists the eleven categories of RoHS in the table above.

Unless explicitly excluded, since July 22nd, 2019, EU RoHS applies to all EEE, including those of category 11.

Common Rules for RoHS Certification

All impacted products have to meet general requirements. Here they are:

#1 - General Thresholds

In essence, an in-scope product must contain:

less than 0.1 % by mass of homogeneous materials for:
- Chromium VI compounds;
- Lead compounds;
- Mercury compounds,
- PBB, PBDE brominated compounds;
- BBP, DBP DEHP, DIBP phthalates
- and;
less than 0.01% by mass of homogeneous materials for cadmium compounds.

#2 - General RoHS Exemptions

For technical reasons, several applications or materials benefit from exemptions from the general RoHS restrictions.

As a result, lead can exceed the threshold of 0.1% in aluminum, steel, or copper alloys, up to certain limits.
Cadmium used in a list of electrical contacts is another example of an exemption.

Such exemptions can apply to any categories listed in the RoHS Annex I, with different expiring dates.

Specific Exemptions

Because of their specificities, product categories 8 (medical devices) and 9 (monitoring and control instruments) also benefit from additional applicable exemptions.

For instance, a specific exemption applies to lead in shielding for ionizing radiation.

Infrared light detectors under product categories 8 or 9 can also contain lead, cadmium, and mercury above the regular concentration limit.

Takeaways for the Certification of RoHS Product Categories

Most complex products benefit from exemptions, either general or specific to categories 8 and 9. However, these exemptions are subject to revisions and are regularly revised. As a result, a product that was RoHS compliant last year does not necessarily conform today.
On top of being costly, test reports don’t necessarily reflect exemption statuses.
Instead, manufacturers can build technical files with certificates of compliance and other relevant documents with commitments of conformity from the supply chain.
IEC 63000 is a well-recognized standard that manufacturers use for RoHS risk assessments of complex products.

Enviropass is here to assist you with RoHS certification and compliance assessments of your products, according to its category.

Get your free online Enviropass consulting hour!