RoHS Compliance and Restriction of Hazardous Substances
RoHS, sometimes pronounced /ˌɹɒʃ/ (‘rosh’), is short for the Restriction of Hazardous Substances. The full name is the Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment, which is an EU directive, and its updates, which was first implemented on 1 July 2006.
The aim and definition are simple: certain dangerous or harmful substances are not permitted in electric and electronic equipment in excess of 0.1% per component (0.01% for Cadmium), unless exempted.
The substances are:
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent chromium (Cr6+)
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ether (PBDE)
- Bis(2-ethylhexyl) phthalate DEHP
- Butyl benzyl phthalate (BPP)
- Dibutyl phthalate (DBP)
- Diisobutyl phthalate (DIBP)
The first six are from the original directive, and seven to ten were later added, becoming effective back on 22nd July 2019.
The toxicity of the four heavy metals has been known for some time. Lead is used as an alloy to make metals softer and more malleable. Mercury is used in lights and tilt switches. Cadmium is largely found in batteries, to which different directives apply. Hexavalent chromium is used in chrome plating and corrosion-proofing. PBB and PBDE are possibly carcinogenic flame retardants found in plastics. The four phthalates (DEHP, BPP, DBP, DIBP) are plasticisers used in soft or elastic plastics that can be dissolved by saliva.
Developments in scientific testing, greater availability of medical records, and changing attitudes towards chemicals have brought this issue to the fore. Lead, commonly used in solder, is the most known for both historical lead poisoning and as the most high-profile substance in RoHS.
However, the presence of even low quantities of any heavy metals can be dangerous to health, with developmental, neurological and reproductive effects recorded. Many people are potentially exposed throughout a product’s life cycle, from the factory’s employees in the manufacturing process, the consumers handling the item, and then either those recycling the equipment, or to the local environment once in landfill or incinerated. RoHS power cables are important throughout their product life.
RoHS power cables testing is non-destructive, and can be an overall surface scan with EXDRF spectroscopy, followed by ICP-OES, UV-Vis, and GC-MS wet chemical tests depending upon which substance is being tested for.
RoHs power cables exemptions
There are approximately 39 exemptions covering 77 situations in annex 3, but the most relevant for electrical mains plugs, cords, and RoHS power cables are:
- 6(c) Copper alloy containing up to 4% lead by weight
- 7(a) Lead in high melting temperature type solders (i.e. lead-based alloys containing 85% or more lead by weight)
- 8(b) Cadmium and its compounds in electrical contacts
There are other exemptions specific to the end user, e.g. use of mercury in lighting, or lead in circuit boards.
Spare parts and materials used to repair equipment pre-dating the directive may be exempted depending upon the substance, the application, and the date used. The definition of RoHS power cables as spare parts is clear if they are hard-wired, but debatable if detachable.
RoHS power cables applications vary widely, and the directive does not apply to some environments, which are summarised generally:
- Defence/military
- Outer space
- A critical part of a larger piece of equipment which is outside the scope of the directive
- Large stationary industrial tools
- Large fixed installations
- Vehicles
- Professional non-road machinery
- Implanted medical devices
- Solar panels
- Research and development
RoHS power cables internationally
Each member state must comply through national legislation, as must any goods imported into the European Union. Different member states may interpret, implement and enforce the directive differently: for example, some countries include plastic children’s toys whether or not they contain electric or electronic components. Since the RoHS 2 directive (2011/65/EU), RoHS compliance is a requirement of the CE mark.
Other than the CE mark implying RoHS conformance, there is no requirement for RoHS logo or marking. However, various marks have been created, usually in colour green and incorporating ‘RoHS’, ‘lead-free’ or ‘Pb-free’ and sometimes a tick or leaf.
Whilst limited to the EU, other countries recognise or even require RoHS, for example Australia.
UK RoHS
Despite Brexit, the UK is still aligned on the EU for RoHS, so this still applies exactly, through national legislation.
Iceland RoHS
Likewise, Iceland, as a non-EU European country, has fully adopted RoHS regulations.
China RoHS power cables
The Chinese ‘e’ in arrowed circle may also imply conformance to EU RoHS for the first 6 substances: this is the ‘Envrionmental Friendly Use Period’ (EFUP). A number in the arrowed circle is the mininmum duration in years before the controlled substances may start to leach out of the product; ‘e’ means the substances are below the threshold. ‘China RoHS II’ is valid since 2016 as Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products. This applies to the following 15 categories of electrical items: air conditioners; electric water heaters; fax machines; miniature computers; mobile communication devices; monitors; photocopiers; printers; refrigerators; telephones; televisions; washing machines; mini fans; powerbanks; electric gadgets.
RoHS in North America
The USA does not recognise RoHS, and has no legislation at a federal level. Since 1976, the Environmental Protection Agency (EPA) administers the Toxic Substances Control Act (TSCA), regulating chemicals with an “unreasonable risk of injury to health or the environment”.
USA RoHS power cables may be required at a state level, however. Most notably to do this is California, which has applied the first four restricted substances to a limited list of electronic equipment (California RoHS), and also has Proposition 65. Other individual states with Rohs power cables requirements include (in alphabetical order): Illinois (Electronic Products Recycling and Reuse Act); Indiana (E-Waste Law); Maine (38 M.R.S. §1614); Minnesota (Waste Management); New York (Electronic Equipment Recycling and Reuse Act); New Jersey (Electronic Waste Management Act); Rhode Island (Electronic Waste Prevention, Reuse, and Recycling Act); Wisconsin (Electronic Waste Recycling).
Brazil
Brazil has implemented the national ABNT NBR IEC 63000 as a local copy of the IEC standard that covers RoHS requirements.
J-MOSS in Japan
Mercury has long been heavily restricted, and individual states may also ban PBDE. Due to The Law for Promotion of Effective Utilization of Resources, the Japanese recycling law, Japan has limited the use of lead and requires warning labels for some harmful substances since 2001. Since 2005, JIS C 0950 The Marking for presence of the Specific chemical Substances for electrical and electronic equipment (“J-MoSS”) has been in effect. Included categories of electrical items are: computers; air conditioners, televisions; refrigerators; washing machines; clothes dryers; microwave ovens.
This standard is mentioned in the Japanese Recycling Law, and includes the chemicals: Lead, Mercury, Cadmium, Hexavalent chromium, Polybrominated biphenyl, Polybrominated diphenyl ether.
RoHS power cables in South Korea
The Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles is the South Korean equivalent of RoHS, applicable since 2007. It is often simplified to ‘Korea RoHS’.
Taiwan RoHS
In 2013, BSMI published a voluntary standard, CNS 15663, Guidance to reduction of the restricted chemical substances in electrical and electronic equipment (EEE), sometines shortened to Restricted chemical substances in EEE. It covers the first 6 substances, and has largely the same applications. Conformance can be shown by use of the BSMI mark with ‘ROHS’ added, as image.
India RoHS
The India Waste (Management) Second Amendment Rules 2023 was issued by the Ministry of Environment, Forest and Climate Change and is similar in scope to EU RoHS, but has a far larger list of exemptions listed in Section II c. It is still known under its previous name, the Indian E-Waste (Management) Rules 2022.
Singapore RoHS power cables
In 2016, the Ministry of the Environment and Water Resources in Singapore (MEWR) published an update to the 1999 Environmental Protection and Management Act (“SG RoHS”) to include the first 6 RoHS substances. This has largely the same exemptions, and applies to: mobile phones; computers; air conditioners; televisions; refrigerators; washing machines.
Australia
Australia does not have RoHS, but instead Hazardous Substances in EEE, which covers the same chemicals. Legislation is still to be agreed at a state-level, so (technically at least) currently the restriction of the substances is guideline-only.
UAE RoHS
The Emirates Authority for Standardisation and Metrology (ESMA, the only UAE standards body) issued Cabinet Decision 10 of 2017 in Dubai in April of that year, which is in line with EU RoHS, and applicable in the United Arab Emirates since January 2018.
SASO RoHS
Saudi Arabia published ‘SASO RoHS’ in 2021 which covers the first 6 substances. Compliance is a requirement of the G-Mark.
Turkey RoHS
The Turkish Ministry of Environment, Urbanisation and Climate Change issued T.C. Resmî Gazete (Turkish official gazette) No. 32055 in December 2023, effective January 2024. This is applicable in the Republic of Türkiye and is within the conformance framework of EU RoHS, including CE-marking requirements.
Considerations for the customer
If a product is sold both into and outside the EU, it may be easier to standardise on RoHS power cables as a single compliant product line rather than dual-stocking the same item with and without RoHS. RoHS power cables may therefore be specified when not required for that country, or even specified for an application outside the scope of the directive. RoHS power cables compliance is good practice, but is not always required; unfortunately there are popular misconceptions which cloud the issue.
For the moulded power cables and rewireable plugs and sockets supplied by Morvan Trading, RoHS largely does not apply. Generally, the only restricted substance found is lead in copper alloy, which is necessary for flexibility in cable and current-carrying contacts; this however carries an exemption, and can be used up to 4% by weight. The only other consideration is the use of lead-free solder if cable is being stripped and tinned. Lead-free solder is more brittle, less electrically conductive, and is harder to work with than its predecessor. Another major criticism of RoHS is that 90% of the world’s lead is used in the manufacture of electric batteries, to which RoHS does not apply.
RoHS declaration
Morvan Trading Ltd designates RoHS power cables as RoHS compliant based on information provided by our manufacturers and suppliers. RoHS compliant means that the supplier has confirmed the compliance of the product, because:
- They do not contain the restricted substances in Article 4(1)
- They contain the restricted substances, but below the specified limits
- They contain the restricted substances, but are exempted in Annex 3
Morvan has taken all reasonable steps to confirm suppliers’ statements regarding the absence of the restricted substances.
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Morvan Trading Ltd,
Westover Farm,
Goodworth Clatford,
Andover, Hampshire,
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