I pride myself on keeping pretty up to date on RoHS. Any journalist who has been in the electronics trade for a while has been writing about the EU's Restriction on Hazardous Substances for more than a decade.
However, as with many directives that become laws, some changes have been made to RoHS. The consulting firm Design Chain Associates recently presented two Webinars on the topic. Here are some highlights from today's presentation:
- It's not over.
- You can fall “out of scope.”
- There is no such thing as a RoHS logo.
- CE does not equal RoHS.
- Your EMS is not your ticket to compliance.
When RoHS became a law, it included a phase-in period for products that were not covered in the original directive. Those products, which are outlined in what's called the RoHS Recast, will be phased in through 2021.
Thanks to many of the clarifications in the recast, products that were subject to RoHS under the directive may not have to comply under the law. Don't assume that, once you are compliant, you are always compliant.
Many of the icons that designate a lead-free product were designed by the companies manufacturing the product. RoHS compliance has to be demonstrated through documentation.
Products that carry the “CE” seal may be RoHS-complaint, but they are not one and the same. Conversely, a RoHS-compliant product may or may not have to carry the CE seal. Either way, RoHS and CE apply to the finished product and do not have to be attached to individual components.
RoHS compliance is the responsibility of the brand owner, not the contract manufacturer. Though your EMS may follow all the RoHS rules, the buck stops with the OEM.
These particular items were a surprise to me. A lot more information was covered by DCA. I recommend logging on to the Design Chain Associates Website, where you can request copies of the presentations.