You have to verify whether your products are RoHS compliant. It can be one product intended for a specific EU market, multiple models, or even your entire production. Your designs can have a dozen or thousands of different components, depending on their complexity. Therefore, you are considering RoHS testing of electrical or electronic equipment against the RoHS requirements. If this applies to you, read below!
How do you test your products and verify their compliance against the RoHS substances? In other words, what kind of information is necessary and sufficient to perform valuable RoHS conformity assessments?
You essentially have two options: either you do the test yourself or benefit from tests a stakeholder in your supply chain has already conducted. Then, you will use the gathered information to make your technical file. In other words, the sources of information are:
With the analytical testing approach, you will do physical testing on samples. We can find various types of analytical testing on the market, depending on the chemicals to be analyzed. Here are some of the main ones.
Probably the most popular analytical testing method is the XRF one. XRF means X-ray fluorescence.
With this method, it is possible to identify a material composition by bombarding it with high-energy X-rays. Then, the emission of “secondary” (or fluorescent) X-rays gives the nature of the excited atoms. The XRF method detects the presence and concentration of heavy metals like lead in a homogeneous material. XRF is one of the least expensive analytical testing methods.
Chromatography consists of chemically separating the elements of a dissolved mixture. As a result, chromatography allows us to identify and quantify these elements.
Gaz chromatography detects PBB, PBDEs, or phthalates and determines their concentration in a given material.
The analytical testing approach works well when verifying compliance with specific materials. While it is usually not the primary approach to test complex products, lab testing helps you confirm compliance. Get a sampling plan to prioritize the tests you must have:
To confirm your RoHS sample plan, ask an Enviropass expert!
Since it is not realistic to do comprehensive analytical testing on your products, another option is available: the Documentary approach. Here, you will perform a risk analysis based on your product bill of materials and use the information your suppliers have already collected from their suppliers to confirm compliance with RoHS.
Enviropass recommends gathering as much relevant RoHS information as possible from your supply chain, building a robust technical file, and demonstrating due diligence. As a rule of thumb:
Therefore, they are more likely to commit to the RoHS compliance of their parts.
When available, their certificates of compliance (CoC) are significant pieces of information as long as :
A CoC can be of different formats. Use the Enviropass EPEC form to gather the needed environmental information from your supply chain.
Other documents, such as specifications and harmonized safety data sheets, may also enable you to determine the RoHS status of certain materials.
Likewise, you can use testing reports as proof of compliance. However, test reports of samples don’t guarantee that all supplied parts remain compliant over time. Therefore, the supplier of parts should accompany its test report by a CoC.
The quick answer is yes for complex products like electronic devices with more than ten homogeneous materials.
To help you build sufficient technical documentation, the International Electrotechnical Commission (IEC) has issued Standard 63000 for technical documentation for electrical and electronic products assessment concerning the restriction of hazardous substances. Here is what the IEC 63000 Standard states in its introduction:
For those restrictions that apply at the ‘homogeneous material’ level, it is impractical for manufacturers of complex products to undertake their (…) testing of all materials contained in the final assembled product.
Instead, manufacturers work with their suppliers to manage compliance and compile technical documentation as evidence of compliance.
Therefore, IEC 63000 promotes technical documentation with a documentary review for complex products. Both industry and most enforcement authorities recognize this approach.
Along with IEC, CENELEC (European Committee for Electrotechnical Standardization) recommends the documentary approach towards RoHS compliance. Indeed:
It is a comprehensive method. You will assess the documents of every product component and homogeneous material.
It is reliable because it is comprehensive and relies on suppliers’ statements.
Based on quality control of the collected information, you can rely on the statements you receive.
Importantly, it is cost-effective. The tests themselves are much less expensive than chemical analyses.
It is not destructive. Reuse the tests that your supply chain has already completed. Implement a quality control system to verify the statements and reports you receive from your supply chain are up-to-date and consistent with the RoHS requirements.
It is a sustainable method because it avoids product transportation and destruction.
Finally, to update your technical file, you only need to gather the missing information for the additional parts according to the latest applicable regulatory changes.
The RoHS documentary review is an efficient approach that you can easily update for new product versions.
Analytical testing may be necessary for medium to high-risk homogeneous materials without sufficient RoHS compliance guarantee from the suppliers. Here is why:
For a part without sufficient RoHS information that is risky according to your IEC 63000 type assessment, you can try to find a compliant replacement, like an alternative part. However, in some cases, it is impossible to replace that part because there is no alternative. Then, you will initiate an analytic testing plan on the risky homogeneous materials.
If the suspected restricted substance is present in the risky homogeneous material, then corrective actions are necessary to make the product compliant. For instance, it may be changing the design to bypass this part.
Here are some takeaways:
First, let’s briefly recap what RoHS is. RoHS stands for:
Restriction
Of certain
Hazardous
Substances.
RoHS applies to electrical and electronic equipment (EEE). Tens of countries, especially in Europe and in Asia, even some US states, have voted for RoHS regulations. EU RoHS has pioneered in this sector and remains a reference.
RoHS usually targets these six substances:
Some countries have added four phthalates to the RoHS list:
Different compliance rules apply, depending on the RoHS regulation. For example, the scope varies a lot from one market to another. But what remains the same is that the restrictions apply at the homogeneous material level and are reasonably low, either 0.1% or 0.01%. Additionally, various applications and materials benefit from RoHS exemptions. For example, lead in some copper alloys can exceed the general concentration limit of 0.1% under certain conditions. Since these exemptions are regularly revised, you should monitor the RoHS exemptions that apply to your products and ensure they remain compliant.
Then, you should be able to prepare your product declaration of compliance.
Ask Enviropass for a free online consultation to see a RoHS technical file.
*Note: This article shows the current understanding of Enviropass Expertise Inc. It is developed solely for information purposes and can not replace official legislation.
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