Five Things You Didn’t Know About RoHS

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:

  1. It's not over.
  2. 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.

  3. You can fall “out of scope.”
  4. 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.

  5. There is no such thing as a RoHS logo.
  6. 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.

  7. CE does not equal RoHS.
  8. 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.

  9. Your EMS is not your ticket to compliance.
  10. 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.

22 comments on “Five Things You Didn’t Know About RoHS

  1. Nemos
    December 15, 2011

    As I know all the mobile manufacturers in Europe, they have applied long years ago Rohs policies in their products. As far I know sony Ericsson has applied lead-free rules in its products five years ago maybe more.









  2. mfbertozzi
    December 15, 2011

    You are right Nemos, RoHS adoption from major players started several years ago. It is trues, is a key factor within global supply chain world, but despite restrictions and rules from specifications, the matter is quite complex for the fact Internet could allow potentially the chance, through, for example several public e-market places, for buying something not compliant but low cost appealing.

  3. Daniel
    December 16, 2011

    “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”

    Barbara, I think in EBN and similar websites had covered the RoHS topics many times. But still it’s a hot topic with all of the OEM companies. Most of time I felt that, OEM companies are becomes victims rather than those who manufactured un compliance RoHS components. I mean the user becomes victims rather than the manufacturer.

  4. mfbertozzi
    December 16, 2011

    This is another point to consider Jacob, I believe time spent for providing end-users in educational / self-learning sessions on risks in using goods not RoHS compliant wasn't so much, are you agreeing?

  5. t.alex
    December 16, 2011

    RoHS really needs the push from end consumers as well. If they do not demand for RoHS products, manufacturers will not need to comply anyway.

  6. mfbertozzi
    December 16, 2011

    t.alex, it is correct, definitely; neverless, at the end, maybe only a small portion of endusers (or as you right said, “endconsumers”) is aware of RoHS standard and its implication. Not to say that recommendation is unknown, but I don't think across the globe, that topic appears so friendly.

  7. Barbara Jorgensen
    December 16, 2011

    Readers–I am not sure consumers are as aware of RoHS as manufacturers–theoretically, consumers should benefit from the law anyway because almost everything is lead-free (at least). It remians an issue for manufacturers because products are being added to the scope of RoHS, which means developments on haz-substance free manufacturing will continue. Also, if there is a major enforcement event–which there hasn't been yet–there would be a lot of publicity. If a major infrastructure investment had to be dismantled–and there are provisions in RoHS for “industrial” electronics-RoHS will become more visible.

  8. mfbertozzi
    December 16, 2011

    I agree Barbara, producers have to know in depth the standard and endconsumers (potentially) could receive benefits in case products, inside the market, are compliant to. Be aware of, at least, in terms of general issues, could help endusers in protection their safety. Sometimes people buy products on-line and are attracted by low costs and it happens quite often reasons to be cheaper then are exactly due to low production's quality and rules not respected.

  9. Taimoor Zubar
    December 17, 2011

    “There is no such thing as a RoHS logo”

    Barbara, does the absense of logo means that RoHS compliance is not something that consumers can take as an indicator to help them while picking products? What could be the reason behind not having the logo?

  10. prabhakar_deosthali
    December 18, 2011

    Since the list of material covered under ROHS complaince will be evr changing the ROHS compliance has to have a date or some kind of version associated with it.  So like new car  emission norms are declared every now and then, new ROHS norms will come into force from time to time. 


    A product claiming ROHS complaince has to say which ROHS version.

  11. Barbara Jorgensen
    December 19, 2011

    @Taimoor–good question. From what I hear, the CE label is more important to consumers than a RoHS designation. And, in fact, it is not so much RoHS as it is “green.” In other words, I think consumers know that RoHS equals green (for the most part) so a manufacturer's logo–a leaf, a pb-free symbol, etc., may do the trick for consumer awareness.

  12. Jay_Bond
    December 19, 2011

    It is going to be interesting to see how many more items get added to their list. This ever changing  RoHS could have some serious implications for companies, especially if they have developed porducts that currently comply only to find out they will be noncompliant in a few years.

  13. t.alex
    December 20, 2011

    Ahh how to indicate version on Rohs logo?

  14. Barbara Jorgensen
    December 20, 2011

    How about the ever-popular 2.0 designation?

    RoHS 2.0

  15. mario8a
    December 21, 2011

    In my experience, meeting RoHS requirements was not our. Biggest concern, but managing all the i formation and certificates merried to the SGS report, until today many suppliers do no know how to fill the MDF correctly.

  16. mario8a
    December 21, 2011

    Many testing labs have their own logo such as ETL CSA, not having a logo prevents any kind of restriction on what lab to use and avoids confusion for the end customer about what logo or what lab is better. Besides RoHS do not enforce labeling, I think only RoHS China

  17. William K.
    December 21, 2011

    This is an interesting and worthwhile write-up. One thing that I do on those occasions when I look for a “consumer electronics” item, is to avoid those items that claim to be RoHS compliant, since it immediately identifies that the solder is inferior, and less reliable. We all know that this is true, although many will say that the higher temperatures and more brittle solder, combined with a greater tend toward whisker growth, really don't matter.

    The products that we produce are not consumer items, and they are worth recycling, so our policy is to pay for the return of any of our products that our customers wish to discard. So far, the only items to be sent back to us have been sent for repairs or calibration recertification, not for disposal. So it seems that we have a decent product niche.

    It would be a valuable service to the worlds ecology for some to acquire information on the actual reduction of the movement of the removed hazardous substances into the enviroment caused by this RoHS mandate. Understanding the actual benefits of any costly change is a very valuable insight for any business, which many sucsessful organizations work to achieve prior to making such changes. Of course, they often continue such a study after the changes are implemented, so as to verify the value of their action. It would be worthwhile for the various governing bodies to also know the actual value and benefits of their mandates. After all, many of us understand that there are unintended consequences of many actions.

  18. t.alex
    December 28, 2011

    Really the solder is not reliable? This means RoHS affect product lifetime and quality? Something contradicting here?

  19. William K.
    December 28, 2011

    Yes, the reliability of lead free solders is acknoledged as being quite a bit lower. That is why they are not used in military equipment or in heart pacemakers. The reduced reliability is in several areas: first, the lead free solders are more brittle, thus more likely to fail due to cracking under repeated stress and strain; second is the greater tendancy of those using tin to develop conductive whiskers that lead to short circuits; and third is the relibility reduction caused by the need for the soldering to be done at higher temperatures.

    None of these reasons are “new”, they are well known and have been discussed in the publications such as EDN and Design News. I certainly did not discover them, others did. 

    Of course, when the only target is maximum product sales and profit, having a product fail leads to more sales, so the shorter product lifetimes have not bothered some manufacturers. On the opposite side, I would not knowingly sell a product with an intrinsic structural flaw that would reduce the value to my customers.

  20. mario8a
    December 30, 2011

    Hi William, in fact you listed three of the main concerns implementing lead free soldering, i'll like to add the extra cost for lead free soldering SAC alloy commonly use in the industry. Back in 2006 the SMD process was not ready for lead free, currently i'll say it is more estable, specially in uBGAs

  21. William K.
    December 31, 2011

    Mario, you make a good point about cost. Of course the cost increase of soldering would probably be passed on to the buyer, but it certainly is a consideration. My guess is that the higher temperature needed may reduce the production line yield a bit, although I have not read any comments about that aspect.

    I do wonder about how much solder, by weight, really is in many of the small consumer electronic items. Has anybody researched that? The original lie that was used to start the discussion claimed that the weight of lead in each computer was several pounds. That is the result of doing the division on the weight of lead claimed to have been dumped by the number of computers dumped. I wonder now if they were adding in the weight of the leaded glass in the monitor CRTs. Does anyone have information about how the lead in leaded glass might escape? My observation of glass is that it does not seem to deteriorate when it is buried in the ground.

  22. almost retired
    March 28, 2012

    Does anyone have experience using a swab method for checking for lead in solder? One item on market is called Lead Check by 3m… wondering if it is reliable checking solder connections…

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