23115 rohs booklet for the web

8/8/2019 23115 RoHS Booklet for the WEB

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RoHS Guidance

Producer Support Booklet


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Introduction

The purpose o this document is to provide support to producers o electrical and electronicequipment in complying with RoHS. The Directive came into orce on 1st July 2006, meaningany electrical goods placed on the market ater this date should meet its requirements.However, the Enorcement Authority still nds non-compliance across industry even inbusinesses that claim to have a good knowledge o RoHS. This can be due to an over-relianceon guarantees rom suppliers or a lack o sucient knowledge to ully understand thesedeclarations, which can be in the orm o certicates or test reports.

In writing this booklet, the NMO Enorcement Authority aims to share with producers itsexperience o assessing the compliance systems that should be in place. By doing this it ishoped the levels o compliance in the UK can be raised and producers can, through theinormation presented in this document, improve their compliance systems.

It is a producers corporate responsibility to keep up to date with the Regulations and to makesure they have the appropriate documentation demonstrating compliance beore placing theelectrical product on the market. Documentation should be held in a technical le beore thedate the product is made available or the rst time, not sought ater this time. UK law providesprotection to businesses that are seen to have taken all reasonable steps to avoid committing anoence. This is known as a due diligence deence.

This booklet should provide guidance regarding the reading o documentation, advice oncontrol processes to ensure goods are compliant with RoHS and other useul inormation toavoid leaving businesses open to risk. We aim to work with producers to reach compliance andhope this booklet will raise levels o awareness across industry.


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Method How is the report conducted and presented? The method used or testing is usually shownon the ront page o the report and there should be some level o understanding by the producer o thetesting processes, including how they are being conducted. There can be dierent methods o testing

or each hazardous substance and these should be listed on the report. It is important or producersto ask the question o suppliers to understand the ways in which compliance is being reached. A testreport should list the levels o the hazardous substances in each component, either detected in parts

per million, expressed as a percentage, or both. I the presentation o the report is not clear then anexplanation should be sought rom suppliers to avoid conusion and possible non-compliance. Other

actors such as whether the test house is amiliar and the report is signed by a trusted source should alsobe taken into consideration.

Steps Substances Polymers Metals Electronic

(PWBs/components)

Mechanical samplepreparation(see Clause 5)

Direct measurement

Grinding

Grinding

Chemical sample

preparation

Microwave digestion

Acid digestion

Microwave digestion

Acid digestion

Microwave digestion

Acid digestion

Solvent extraction

Analytical techniquedenition (includingtypical margins o error)

PBB/ PBDE GC-MS(see Annex A)

NA GC-MS(see Annex A)

Cr(VI) Alkaline digestion/colorimetric method(see Annex C)

Spot-test procedure/boiling water extractionprocedure (see Annex B)

Alkaline digestion/colorimetric method(see Annex C)

Hg CV - AAS, CV - AFS, ICP - OES, ICP - MS (see Clause 7)

Pb/Cd ICP-OES, ICP-MS, AAS(see Clause 8)

ICP-OES, ICP-MS, AAS(see Clause 9)

ICP-OES, ICP-MS, AAS(see Clause 10)

Homogenising What exactly has been tested? A denition o the term homogeneous can be oundlater in this booklet and the components tested and shown in the report should refect this denition.The results o the testing should be specic to each component and not show general areas o theproduct to be compliant. It is the producers responsibility to recognise that the report demonstrates thetesting o homogeneous materials in order to represent satisactory compliance inormation.

Process Control How are manuacturing processes controlled? This relates to the age o the testreport. Manuacturing processes, as mentioned, can change over time. Usually this is due to choicesmade by the company but changes can occur, deliberately or inadvertently, under the control o thesupplier too. For example, solder baths used have the potential to become contaminated i there is noprocess control in place to ensure clean processes. Joints can also be re-soldered in the actory using

leaded solder, making the whole product non-compliant.

Factories based overseas may be harder to infuence and monitor processes so UK producers need tomaintain a high level o trust with these manuacturers in order to avoid potential non-compliance.Producers should have an awareness o the processes used in the manuacture o their products andhave an awareness o possible problems. For instance, something as simple as taking a sample rom asolder bath at targeted intervals could prevent a whole product being non-compliant.

Language Is the test report in English? Some test reports rom suppliers overseas are written in thelanguage o the country in which the product was manuactured. For instance, a product imported

rom China and accompanied by a test report written in Chinese may not be understandable to a Britishproducer. Again, simply holding a report in a technical le is not sucient. There should be a level o

competence rom the company in understanding the compliance inormation held, including the abilityto interpret any test reports.


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Declarations

Many organisations supply declarations o compliance or their components, materials and assemblies.These are a valuable tool because they oten make a clear statement o compliance. When declarationsare received there are various things to consider.

Content What is being declared and is it a generic declaration or specically related to the goodssupplied? The Enorcement Authority oten sees declarations that are not relevant to RoHS compliance.

They may be stating that there was no intentional use, the parts used in the assembly were screened orthat that they are limited to lead in solder only. Many declarations are generic and use standard wordingthat could relate to any company or any product. Specic declarations that clearly oer high levels ocondence have the greatest value.

The Authority also sees many caveats such as made best eorts or to the best o senior managementsknowledge. Best practice is to careully read any declaration and ensure it is providing theprotection expected.

Authority Most declarations are signed on behal o the issuing organisation. This is oten by anexecutive ocer o the organisation but sometimes the declarations are not signed or the personauthorising the declaration is unclear. Good practice is always to ask who is making the declaration andwhether they have authority to sign on behal o the company.

Supporting inormation As discussed under Risk, to accept a declaration at ace value, considerationshould be given to the relationship between organisation and supplier, taking reputation into account.

Where there may be concern over the validity o a declaration, there is value in requesting access to anydocumentation supporting that declaration.

Risk

A due diligence deence relies on the producer taking all reasonable steps to ensure compliance. As part

o any compliance regime there is a responsibility or the organisation to assess and target those areas obringing the product to market where there may be the greatest likelihood o ailure. It is the producersresponsibility to take all reasonable steps to minimise the risk o non-compliant product being placed onthe market.

The ollowing section discusses some o the risks and controls that should be associated with acompliance system. However, it must be recognised that this is a general support document and the

ollowing inormation is not exhaustive. Ultimately it is the responsibility o the producer to assess andcontrol both internal and external risks.


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Suppliers Producers should look to establish a level o trust with their suppliers. Some will readilyproduce documentation showing compliance o the materials they supply, but others may have lesserlevels o awareness and can not produce the necessary inormation. In extreme cases, orged documentsstating compliance are given. The inormation in this booklet stating what to look or in a declarationshould support producers in their examinations o these declarations.

Ater using a certain supplier over a sustained period o time, trust and the knowledge o the processeso manuacture may increase so that a written declaration stating RoHS compliance is deemed sucientto be relied upon. It is ultimately the producers decision to assess the risk o the documentation theyare provided with. There is no statutory obligation or suppliers o raw materials, components or subassemblies to hold inormation regarding RoHS compliance, but market orces may drive suppliers tohold such documentation to support their customers.

Second Party Audits Where there may be less condence in a supplier, second party audits can be amore cost eective alternative to carrying out independent testing. An inspection o the manuacturingprocesses and the systems in place to ensure compliance can not only aid understanding rom bothsupplier and producer, but can also build a level o trust

As mentioned in Test Reports, there should be sucient processes in place to show all reasonablemeasures have been taken to ensure RoHS compliance. Producers should have a level o awarenessregarding manuacturing and look to examine the checks that are in place along the supply line orbest practice.

Second party audits o manuacturing can take place to examine the stringency o suppliers in providingcompliant material. Potentially this can provide a better idea o the processes in place and improve thelevel o trust between producer and supplier. Some producers have little contact with suppliers, butbuilding a rapport with them can be benecial to both organisations. Producers should look to gainunderstanding with suppliers and develop trust on which to base systems o compliance.

Corrective Action I non-compliance is ound prior to the product being placed on the market,immediate action should be taken to rectiy the problem. Again, awareness rom both producers andsuppliers is vital so that any non-compliant component can be identied and modied beore theproduct is made available on the community market. Regular checks o compliance systems and o newparts contribute to reducing this risk.

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Internal Control

Whilst suppliers need to maintain control o their manuacturing processes, producers ultimately haveresponsibility or ensuring compliance and thereore need to use all resources available to them. Thissection explores some o the measures it may be useul or producers to take.

There should be an ocer within the organisation who manages compliance issues in many businessesthis can all into the department o Quality Assurance or Production Control. The producer should

be aware o who is responsible or ensuring this and make sure that the compliance inormation isbeing assessed and not simply gathered and stored. This responsible party should be competent inunderstanding what the company holds to show its product is RoHS compliant. This person or personsshould have authority to act, should it be ound that compliance systems are ailing. Direct contact withthe companys senior management would be considered good practice, as problems can be addressedswitly and smoothly.

I manuacturing takes place within the UK it can be easier to control compliance. Inspections canbe carried out without long distance travel and there is no language barrier to cause complications.Compliance inormation should be understandable and suppliers can be questioned with less diculty,incurring ewer problems or the organisation.

Homogeneous Materials

The Enorcement Authority receives a range o enquiries covering the term homogeneous material.When assessing documentation and test reports the Authority is also presented with a range oapproaches are taken to the interpretation by test houses.

The Directive states in Article 4:

Member States shall ensure that, rom 1st July 2006, new electrical and electronic equipment puton the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated

biphenyls (PBB) or polybrominated diphenyl ethers (PBDE).

This eectively generates an absolute ban. However, 2005/618 EEC amends the directive and states:

For the purposes o Article 5(1)a), a maximum concentration value o 0.1 % by weight inhomogeneous materials or lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB)and polybrominated diphenyl ethers (PBDE) and o 0.01 % by weight in homogeneous materials orcadmium shall be tolerated.

Thereore, although there is an absolute ban, maximum concentration values have been set orhomogeneous materials.

The Commission FAQ helps by dening homogeneous materials by setting two criteria that must be metor a material to be homogeneous.

Homogeneous material means a material that cannot be mechanically disjointed intodierent materials.

Denitions:

The term homogeneous means o uniorm composition throughout. Examples o homogeneousmaterials are individual types o: plastics, ceramics, glass, metals, alloys, paper, board, resinsand coatings.

The term mechanically disjointed means that the materials can, in principle, be separated bymechanical actions such as: unscrewing, cutting, crushing, grinding and abrasive processes.


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Thereore or the purposes o compliance with the Directive, the maximum concentration values o0.01% by weight or cadmium and 0.1% by weight or the other restricted substances applies tohomogeneous materials within the equipment and an absolute ban o the restricted substances appliesto non-homogeneous materials within the equipment.

This is important when assessing test reports where whole components may have been ground up

(or homogenized) due to sample size. In such cases, levels o the restricted substances identied atconcentrations below the maximum concentration values may not demonstrate compliance.

Within the UK, a pragmatic view is taken o what constitutes a homogenous material. Particularly whenassociated with hexavalent chromium nishes. Typically these passivate layers have a depth o between0.1m and 0.7m with potential variances in concentration o the hexavalent chromium throughout thelayer. However, or the purposes o the Directive the Authority takes the view that the chromate layershould be considered a separate homogeneous material rom the base plating and thereore the 0.1%by weight maximum concentration value applies.

Exemptions

There are various exemptions to RoHS or products and parts. Categories 8 and 9 (Medical Devicesand Monitoring and Control Equipment) are currently out o scope, but may be brought within scopearound 2014. This is ultimately a decision made by the European Commission, but the RoHS Website iskept regularly updated with inormation so any change will be published.

A ull list o exemptions or the use o some hazardous substances in certain instances is also providedon the RoHS website. It is presented so that the allowances can be viewed either by substance or the ulllist. The exemptions are occasionally altered, with new additions or deletions being made. The list on theRoHS website is kept up-to-date or reerence regarding these exemptions.

Areas o Non-Compliance

The Regulations speciy that each homogenous material must not contain any o the restrictedsubstances, but there are certain parts o electrical products that are more likely to be non-compliantthan others. Every component must comply or the whole product to be deemed compliant, but beloware some o the areas in which problems are more commonly detected;

i) Solder RoHS has sometimes been reerred to as the lead in solder Directive and lead-reesolder should be used to ensure a product is compliant. However, this term should not distract

rom the act that there are six substances covered by the Directive and all parts o the product

are covered not just solder. Contaminations in the production process can also cause traceso lead to be ound at over the maximum concentration limit and, as mentioned above, it isadvisable to keep a regular check on production to ensure compliance.

ii) Coloured Plastics Pigments used to colour various parts o electrical equipment can containhazardous substances. These are usually ound at a level o between 0.1-2%, but this levelsignies non-compliance and gives a good indication o why test reports need to be checkedthoroughly.

iii) Hexavalent Chromium This commonly has an oily-gold/green appearance and is used asan anti-corrosive coating on metals. It is the most easily recognisable o the substances and isconsidered a homogenous material when used, meaning its detection results in the products

ailure.

iv) Cadmium in Zinc Cadmium naturally exists with zinc, so i the zinc is not properly rened inthe manuacturing process non-compliance can occur.


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Further Relevant Inormation

There is a vast amount o inormation available on the RoHS website. The ollowing sections areeasily accessible:

i) About RoHS There is plenty o inormation about the legislation, both in detail and in shortsummary ormats.

ii) Decision Tree This allows a company to examine whether their product needs to be compliant.It gives a list o the Categories o electrical product covered by RoHS and the responsibilities oproducers.

iii) Due Diligence Inormation is provided on the concept o due diligence and what levels oprecaution need to be taken in order to have a deence in the event o a non-compliance being

ound.

iv) Exemptions There are a number o instances in which RoHS does not need to apply. A ull listo material exemptions is given on the RoHS website.

v) Links A wide range o links to documents that are potentially helpul in understanding the

Directive are also available. These include a link to the Government Guidance Notes which aretargeted toward UK business.

vi) Trakker The RoHS Trakker allows questions to be asked directly to the UK RoHS EnorcementTeam. Any questions producers have can be answered using this service.

Other useul inormation relating to RoHS include documents such as the Government GuidanceNotes, the Ocial Journal and the Blue Guide. The Government Guidance Notes are constructed to aidproducers in understanding RoHS and their obligations. It has no legal authority, but is written with theintent to be inormative. For a ull statement o the legal requirements, producers should reer to the

Regulations themselves.

The WEEE Directive can be useul to categorise electrical product, in some cases to determine whetherit alls within the scope o RoHS. A list o product that alls into each Category is provided, making thisdecision easier in most cases. Occasionally there is electrical product which appears ambiguous in termso the Category it belongs in in these cases it may be sensible to seek advice rom the Enorcement

Authority via their Enquiries Trakker.

The Blue Guide explains how New Approach Directives such as RoHS should be implemented. SectionTwo is particularly useul in urther understanding the scope o RoHS.

RoHS Regulations:http://www.rohs.gov.uk/Docs/Links/RoHS%20Regulations%202008.pdf

RoHS Guidance Notes:http://www.rohs.gov.uk/Docs/Links/RoHS%20Regs%20Guidance%20-%201%20July%202008.pdf

WEEE Directive:http://www.rohs.gov.uk/Docs/Links/WEEE%20directive.pdf

Blue Guide:http://ec.europa.eu/enterprise/newapproach/legislation/guide/document/1999_1282_en.pdf


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Copyright 2010

National Measurement Ofce

Enforcement Authority

Stanton AvenueTeddingtonMiddlesexTW11 0JZ

Tel. 020 8943 7227www.RoHS.gov.uk

23115 rohs booklet for the web

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