New substances included in RoHS 2
Reminder: what the 2011/65/UE directive says
The 2011/65/UE diretive aims at restricting the use of some dangerous substances in electrical and electronic equipment. It also draws a parallel between the RoHS (Restriction of Hazardous Substances) and WEEE (Waste Electrical and Electronic Equipment) directives in order to have a better control over the protection of human health and the environment, as well as the environment-friendly elimination of waste derived from EEE.
The RoHS 1 directive already banned the use of six substances over 0.1% of concentration. They were the following:
- Polybromminated biphenyl (PBB)
- Hexavalent chromium
- Polybrominated biphenyl ethers(PBDE)
- Cadmium (limit of concentration of 0.01%)
RoHS 2 adds up four newly banned substances to this already existing list. Their use is limited to a concentration of 0.1%. They are:
- Bis(2-ethylhexyl) phtalate (DEHP)
- Butyl benzyl phtalate (BBP)
- Dibutyl phtalate (DBP)
- Diisobutyl phtalate (DIBP)
Involved categories of products
RoHS identifies nine categories of products affected by the (UE) 2017/2102 directive. Here is the list:
- Large and small household appliances
- IT and telecommunications
- Consumer equipment
- Electrical and electronics tools
- Lighting equipment
- Toys, leisure and sport equipment
- Medical devices
- Monitoring and control instruments
- Automatic dispensers
Therefore, the categories of products excluded by RoHS are :
- Military and space equipment
- Large scale, industrial tools and fixed installations
- Means of transport
- Non-road mobile machinery
- Active, implantable medical devices
- Photovoltaix panels
- R & D equipment
- Batteries and accumulators
The implementation of RoHS 2 proves to be challenging for some specific categories of products
On January 2017, a proposal of modification of RoHS 2 was submitted to the European Commission so as to solve some difficulties. The Commission’s answer, voted in October, withholds four essential topics.
- First, the Commission proposes that the resale of EEE be exempt of restrictions after the expiration date of the RoHS directive, on July 2019.
- Then, the Commission also tackled the issue of spare parts. It appears that said parts are no longer submitted to the obligation of conformity established by RoHS 2.
- About the distortion between non-road mobile machinery connected through a cable and identical machinery powered by a battery or an engine (aside from RoHS2), the Commission decided to exclude double machinery connected through cables from the application scope of the directive.
- Finally, pipe organs are now allowed on the market.
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