White paper helps EEE manufacturers prepare for updated EU RoHS2 regulations

17 May 2019

Woman using tablet with wifi symbol SGS
Woman using tablet with wifi symbol SGS

Manufacturers of electrical & electronic equipment (EEE) face fresh challenges to maintain CE Mark status for their products when the EU's new RoHS2 regulations come into force in 2019.

In its latest White Paper, ‘European Union RoHS2 – Understanding Requirements and Compliance Strategies’, SGS reviews the aims and objectives of the updated Directive (2011/65/EU), and explores the potential impact and consequences for EEE manufacturers.

Introduced in 2002 to contribute towards the protection of human health and the environment, the RoHS (Restriction of Hazardous Substances) Directive now forms an important part of the foundation for supply chain compliance in the EEE industry. From tumble dryers and TVs to laptops and lamps, the Directive provides an effective start point for the identification and removal of hazardous and/or toxic substances from such products. By designing these substances out of products and focusing on the product’s entire life cycle, materials can be recycled, and waste restricted.

From July 2019, enforcement of restrictions will be extended from six to ten substances, including lead, cadmium and mercury. Crucially, products that fail to conform to its requirements cannot display the CE Mark and are prohibited from being offered for sale in countries of the European Union (EU).

David Linder, RSTS Technical Manager, SGS, said: “Ensuring that products stay compliant is a time-consuming concern. This white paper highlights the ongoing challenge it places on all manufacturers. Regulations change, additional hazardous substances are being identified and suppliers may revise formulations or construction of their products at any time.

“SGS provides expert support for RoHS compliance. As the world’s leading verification, testing and certification company, we specialise in partial and complete testing of finished products, and offer options for non-destructive testing.”

Ensuring conformity through DoC
To ensure Conformity, manufacturers must create a technical file and issue a Declaration of Conformity (DoC), which requires them to collect current declarations from all operators in the supply chain, or perform a Complete Assessment of Finished Product.

Manufacturers can assess their products in the following ways:
•    Review the product and Bill of Materials (BoM) to determine the required information
•    Contact the supply chain to get applicable material and/or compliance information
•    Review and determine if the information obtained from suppliers is trustworthy and acceptable.

For many manufacturers the DoC approach can be extremely labour intensive, especially if they have complex products and/or supply chains. It compels the EEE manufacturer to obtain a current DoC or statement of compliance from every supplier, from raw material providers to sub-assembly manufacturers. In addition, the manufacturer becomes legally accountable if supplier information is out of date or inaccurate.

A risk-based approach (including Complete Assessment of Finished Product)
Alternatively, manufacturers can commission a certified laboratory or testing facility to analyse the supplied material or finished product for the presence of hazardous substances.

Complete testing may be necessary, where the product is broken down into its smallest ‘homogeneous’ components, but in many cases the process can be minimised by either:
1.    Testing the parts that would logically use a restricted substance (risk assessment) or
2.    Testing for those substances that would likely be found in such a product – for instance, testing for phthalates in flexible plastics

A trustworthy supply chain will help with obtaining the material content, hazardous substance statuses and/or declarations. Where testing is needed, the IEC 62321 series of standards can provide test methods and criteria for evaluating components and materials for restricted substances. This approach places the manufacturer in control.

Download a copy of the white paper.

SGS’s range of services includes the only globally accepted database of RoHS certification reports – the RoHS Certificate of Conformity. With over 36 accredited RoHS testing centers around the globe, staffed by more than 1,000 RoHS specialists, SGS has the capabilities to ensure products comply with relevant RoHS legislation worldwide.

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