RoHS Compliance in Membrane Switch

 

In several articles published in the past, one concept is often mentioned: RoHS. So what does RoHS mean, and what is its function? Today JRPanel would like to introduce RoHS in membrane switch production to everyone.

What is RoHS?
RoHS stands for Restriction of Hazardous Substances. RoHS, also known as Directive 2002/95/EC, originated in the European Union and restricts the use of specific hazardous materials found in electrical and electronic products (known as EEE). All applicable products in the EU market after July 1, 2006 must pass RoHS compliance.

What are the restricted materials mandated under RoHS?
The substances banned under RoHS are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four different phthalates (DEHP, BBP, BBP, DIBP).

Why is RoHS compliance important?
The restricted materials are hazardous to the environment and pollute landfills, and are dangerous in terms of occupational exposure during manufacturing and recycling.

How are products tested for RoHS compliance?
Portable RoHS analyzers, also known as X-ray fluorescence or XRF metal analyzers, are used for screening and verification of the restricted metals. With the advent of RoHS 3 and the four added phthalates, different testing is needed to ascertain levels of these compounds, which are extracted with a solvent. 

Which companies are affected by the RoHS Directive?
Any business that sells or distributes applicable EEE products, sub-assemblies, components, or cables directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilize any of the restricted materials. Since RoHS-like regulations have spread to a number of other countries, this just doen't apply to EU countries anymore.

RoHS also applies to the metal industry for any application of metal plating, anodizing, chromating or other finishes on EEE components, heatsinks, or connectors.

What is RoHS 2 and how does differ from the original RoHS?
RoHS 2, or the Recast RoHS 2 Directive 2011/65/EU, was published in July 2011 by the European Commission. The scope of the original RoHS was expanded to cover all electrical/electronic equipment, cables, and spare parts with compliance required by July 22, 2019 or sooner depending on product category.

RoHS 2 is also a CE-marking directive, with RoHS compliance now being required for CE marking of products. As such, all manufacturers of electrical/electronic products must comply with RoHS 2 before the CE mark can be applied on their products. The original green RoHS label with the checkmark is no longer required or used as the CE mark now includes RoHS compliance.

RoHS 1 required that any product in scope should not contain any of the 6 restricted substances and that the company (manufacturer, importer, or distributor) placing the product on the EU market should maintain records to show compliance. RoHS 2 requires additional compliance recordkeeping from everyone in the supply chain. Additional compliance recordkeeping (which must be kept for 10 years) can include a conformity assessment, CE marking, maintenance of compliance throughout production, and self reporting of non-compliance.

The proposed changes to the original RoHS Directive in RoHS2 (2011/65/EU) are relatively minor. No additional substances have been added to the six currently restricted. Inclusion of RoHS categories 8 (medical devices) and 9 (control and monitoring instruments) products in RoHS has been added as well. RoHS 2 took effect January 2, 2013.

What is RoHS 3 and how does it differ from RoHS 2?

RoHS 3, or Directive 2015/863, adds four additional restricted substances (phthalates) to the orginal list of six, as cited under REACH legislation. It also adds Category 11 products. RoHS3 takes effect 22 Jul 2019.

What is RoHS 5/6?

RoHS 5/6 refers to compliance for 5 out of the 6 restricted substances (no compliance for lead (Pb)). Lead in very specific applications for Categories 8 and 9 is also exempted under Annex III for a few more years. 

Will there be a "RoHS 4"...are there additional substances that will be restricted in the future?
Maybe/probably. There are discussions (called RoHS Pack 15) taking place for the possible admendment and inclusion of seven new substances. The seven additional substances being assessed are: Beryllium, Cobalt (dichloride and sulphate), Diantimony trioxide, Indium phosphide, Medium-Chain Chlorinated Paraffins (MCCPs), Nickel (sulphate and sulfamate), and Tetrabromobisphenol A (TBBP-A).

How are RoHS and REACH related?

REACH is a general regulation and stands for Registration, Evaluation, Authorization, Restriction of Chemicals, and addresses the production and use of chemical substances and their potential impact on human health and the environment. REACH is monitored by the ECHA and deals with 197 Substances of Very High Concern (SVHC) currently. While RoHS restricts substances present in electrical/electronic equipment (wiring, components, circuit boards, displays, sub-assemblies, cabling), REACH controls all chemicals that might be used to manufacture the product, including enclosures, brackets, coatings, paints, solvents, and chemicals used during manufacture.

Of note is that all the RoHS restricted substances are also on the REACH restricted list. Substances on the list have been identified as being carcinogenic, mutagenic, reprotoxic, bio-accumulative and toxic, or as endocrine disruptors. 

How are RoHS and WEEE related?
WEEE is the acronym for Waste from Electrical and Electronic Equipment. WEEE, also known as Directive 2002/96/EC, mandates the treatment, recovery and recycling of electric and electronic equipment. All applicable products in the EU market after August 13, 2006 must pass WEEE compliance and carry the "Wheelie Bin" sticker. WEEE compliance aims to encourage the design of electronic products with environmentally-safe recycling and recovery in mind. RoHS compliance dovetails into WEEE by reducing the amount of hazardous chemicals used in electronics manufacture.

Put another way, RoHS regulates the hazardous substances used in the manufacture of electrical and electronic equipment (EEE), while WEEE regulates the disposal of this same equipment. 

How is RoHS and the ELV Directive related?

The EU End of Life Vehicle (ELV) Directive relates to automobiles, while the RoHS directive covers a broad array of electrical and electronic products across many industries. The ELV directive applies to electrical cables, wiring, and associated components used in transportation vehicles. It went into effect July 1, 2003, and limits the use of lead, mercury, cadmium and hexavalent chromium (also restricted under RoHS).

In general, XLP (cross-linked polyethylene) insulated automotive-use wire such as SAE (Society of Automotive Engineers) types SXL, GXL and TXL comply with this directive. However, PVC-insulated automotive wire types such as GPT, TWP, SGT and SGX may contain lead and as such may not be compliant unless specifically requested in purchase specifications.

How is RoHS related to Conflict Minerals (T3&G)?

Mainly in the form of a Full Materials Declarations (FMD). Often a compliance declaration will list RoHS, Reach, and Conflict Minerals (T3&G) together. The conflict minerals are tantalum, tungsten, tin, and gold - referred to as 3TG minerals if they originate from the Democratic Republic of the Congo (DRC). Also mined in the DRC is cobalt, which is used in the manufacture of batteries for electric vehicles. Cobalt mining is set to increase dramatically to meet this demand. Under the Dodd-Frank Act, all publically-traded companies must report to the SEC the origin of conflict minerals.

Does RoHS apply to batteries?

No. All batteries, regardless of type or application, are covered under the EU Battery Directive (2006/66/EC and Amendment 2013/56/EU). The Battery Directive restricts the use of lead to 0.004%, mercury to 0.0005%, and cadmium to 0.002% (medical devices/equipment and alarm/emergency systems are excluded for cadmium).

NOTE: Under China RoHS, batteries ARE included/covered. This has particular implications for the electric vehicles market given the size of the battery pack.

Does RoHS apply to RFID tags?
Yes, both passive and active RFIDs are included under RoHS. In the case of packaging, it falls under Category 3. Where RFID tags are permanently attached to equipment or device, it falls under the category of the parent device.

Does RoHS apply to printer cartridges?
Only if the cartridge contains electrical parts that require electric currents or electromagnetic fields to function. Printer cartridges that merely consist of ink and a container, without electrical parts, do not apply.

How is RoHS and HIPAA related?
The healthcare industry is regulated by HIPAA, with its own compliance requirements. If you manufacture EEP for the healthcare industry, you will also need to be HIPAA certified under the Security Rule. This just doesn't apply to medical devices, but also to office equipment including scanners, printers, hard drives, hardware security modules (HSM), smart-card readers, network devices, paper shredders, media degaussers, and hard drive "Destroyers" that bend, break, and mangle hard drives that are decommissioned.

How is RoHS and the cannabis industry related?
Only indirectly. Although e-cigarettes, cannabis vape pens, and other electronic nicotine delivery system (ENDS) products are manufactured to be RoHS-compliant, the associated consumable vape carts (vaporizer cartridges) have been found to contain relatively high levels of lead (Pb), a restricted substance. This is also true for other electronic devices that heat up a substance that can be inhaled, such as for electronic diffusers and nebulizers. In all these products, testing labs are beginning to find traces of other heavy metals such as cadmium, chromium, barium, silver, selenium, iron, manganese, nickel, and zinc.

How is RoHS compliance enforced and what are the penalties?
By national enforcement bodies such as the NMO (National Measurements Office). Penalties and fines for non-compliance can vary considerably between EU countries but include fines and also imprisonment in some member states.

How can your workforce be trained to help meet RoHS compliance?
This is an important issue. The world is getting exponentially more digitized and electronic from mobile devices, IoT, AI modules, machine vision systems, wireless cams, drones, robots, Alexa, smart homes, gaming, 3D printing, medical wearables, green tech, cloud datacenter equipment, and the cabling for all these. These can come with their own set of regulations in addition to REACH/RoHS/WEEE - particularly in the area of food, pharma, and medical devices.