RoHS Compliance


Frequently Asked Questions
Courtesy of IMR Test Labs
Partnerships Built on Excellence


1. What is RoHS?

2. What hazardous substances are covered by RoHS?

3. What products are covered by RoHS?

4. When do my products have to be compliant with RoHS?

5. What are Maximum Concentration Values (MCVs)?

6. What is a “homogeneous material”?

7. What does “mechanically disjointed” mean?

8. Are there any exemptions to RoHS?

9. My company is based in the US. Why should we worry about RoHS?

10. Where do I find information on RoHS?

11. My customer has sent me a “material declaration”; why does it ask for information on substances not covered by RoHS?

12. Do I need to test all my products for every item on the material declarations?

13. We sell populated circuit boards. How do we demonstrate compliance with RoHS?

14. Why can’t we just grind components into a powder, then test for RoHS compliance?

15. This is all very confusing. Isn’t there a better way to regulate substances?

16. What is being done to help companies comply with RoHS?

17. What test methods are used to assess RoHS compliance?

18. What is “Due Diligence” defense?

19. How do I document my compliance efforts to show due diligence?

20. Is plating a “homogeneous material”?

21. Where in “old” electronic equipment is hexavalent chromium found?

22. What are the steps my company should take toward demonstrating RoHS-compliance of our products?

23. What is the difference between a PBDO and a PBDE?

24. What is the official definition of "homogeneous material"?

25. Should energy dispersive XRF be used to determine RoHS compliance?


1. What is RoHS?

RoHS is European Union Directive 2002/95/EC on the Restriction of Certain Hazardous Substances in Electrical and Electronic Equipment. It is pronounced “ross”.


2. What hazardous substances are covered by RoHS?

RoHS restricts the use of lead (Pb), cadmium (Cd), mercury (Hg), hexavalent chromium (Cr6+), polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs). Those restrictions are in addition to existing regulations, such as the 47 categories of dangerous substances restricted for use in nearly every product by EU Directive 76/769/EEC and its numerous amendments.


3. What products are covered by RoHS?

The scope of RoHS is given in the EU WEEE Directive Annex IA, categories 1 -7 and 10. The following is a summary of covered product categories:

1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (except large-scale stationary and industrial tools)
7. Toys, leisure and sports equipment
10. Automatic dispensers

Categories 8 and 9, which cover medical devices and measuring and control instruments, are exempt from RoHS requirements until which time the EU Commission includes them (estimates are that this will occur in 2008 or 2009).

Electrical and Electronic Equipment (EEE) is defined as devices which are dependent on electric current or electromagnetic fields to work properly, including that equipment used to generate, transfer, or measure such currents or fields. The definition of EEE for RoHS is limited to those devices operating on a maximum 1000 Volts AC or 1500 Volts DC.



4. When do my products have to be compliant with RoHS?


The RoHS Directive goes into effect on July 1, 2006. If you are selling products on the EU market, your products must be RoHS/WEEE compliant by that date. Note, however, that many manufacturers are requiring compliance from their suppliers earlier than July 1, 2006 so they can make sure they can supply finished goods to the EU.


5. What are Maximum Concentration Values (MCVs)?

Maximum Concentration Values (MCVs) are limits set by the European Commission for each RoHS-restricted substance in the Commission Decision 2005/618/EC amending the RoHS Directive.  MCV limits apply to each “homogeneous material” making up a product. Note that EU officials have stated that RoHS is considered to be a ban on the listed substances, and that any intentional use of those substances is not allowed. Other EU officials have stated that the term “intentional use” has no meaning in relation to RoHS.  The MCVs are as follows:

0.1% by weight maximum for Pb, Hg, Cr6+, PBBs, and PBDEs
0.01% by weight maximum for Cd



6. What is a “homogeneous material”?


The term “homogeneous” is understood as “of uniform composition throughout”. Examples of “homogeneous materials” are individual types of: plastics, ceramics, glass, metals, alloys, paper, board, resins, and coatings. The Commission further states that a “homogeneous material” cannot be mechanically disjointed into different materials.


7. What does “mechanically disjointed” mean?

The term “mechanically disjointed” means that the materials can be, in principle, separated by mechanical actions. This means that an insulated wire is considered as two homogeneous materials: the metal wire and the plastic insulating material.


8. Are there any exemptions to RoHS?

Yes. The list of exemptions is growing all the time. Exemptions may be found in RoHS and the RoHS Directive Annex. Information on pending exemptions may be found at the UK DTI website.


9. My company is based in the US. Why should we worry about RoHS?

If you sell electrical or electronic equipment to any member country of the European Union, or if you sell parts or materials to companies that then sell their products on the EU market, your products are likely to be covered by RoHS. But even if your products aren’t destined for the EU market, you still may have something to worry about. First, laws such as SB 20 and SB 50 in California are already taking effect in the US, and many more are in the works here and in countries such as China, Japan, and Canada. Also, you may find that availability and reliability are issues, since the “old” products containing restricted substances will become harder to find and more expensive to buy. For example, even though medical devices are now exempt from RoHS, manufacturers may have problems getting printed circuit boards with the tried and true tin-lead solder. That means they will have to test circuit boards with “lead-free” solders to make sure they will be as reliable as the “old” boards.


10. Where do I find information on RoHS?

The following are good sources:

The United Kingdom Department of Trade and Industry (DTI) – they have the lead responsibility for RoHS, WEEE, ELV, and Packaging Directives in the EU. Search for “DTI” and go to the environment department, or click on the link above.

DTI - Sustainable Development and Environment: Latest TAC Committee meeting notes

Europa is the website of the European Union. Information on RoHS is available on that site, but is not as easy to find as on the DTI site. Click on any of the links below.

EUROPA - Environment

EUROPA - RoHS Directive

EUROPA - WEEE Directive

EUROPA - Committee on Environment, Public Health and Food Safety

EEA - European Environment Agency - Home

SCADPlus: WASTE MANAGEMENT

The Electronics Industry Alliance (EIA) often has free information on RoHS, but you may have to join to get full access.

iNEMI is also a good source of free information.

AeA is a good source for RoHS seminars and other information. AeANET : Advancing the Business of Technology


11. My customer has sent me a “material declaration”; why does it ask for information on substances not covered by RoHS?

Material Declarations are prepared by electrical and electronic OEMs and companies throughout the supply chain. Rather than being specific to RoHS, they are a compilation of all requirements concerning restricted substances world wide. Those requirements may be from regulations or they may be something your customer wants or needs. Material Declarations also include elements or compounds that are not restricted but either may become restricted or are needed by the company to assess other issues, such as residual value. For example, it is desirable to know the gold content of a material even though gold is not restricted, since the material may have residual value depending upon its mass and gold content.


12. Do I need to test all my products for every item on the material declarations?

No. If you tried to do that, you would get a very big bill from a laboratory. First, you should try to obtain information on the concentration of RoHS and other declarable substances in your materials from your suppliers or from the manufacturer of the materials. If that information is not available, you have two real choices: 1) test each homogeneous material you use, but limit the testing to one set per unique material to avoid duplication; only test the materials for substances that are likely to be present as additives or contaminants (your lab should be able to help with this); or 2) stop doing business with that client. Note that the substances to be tested will vary from material to material; for example, it does not make sense to test steel for brominated flame retardants, but it does make sense to test for them in plastic.

In every case, it is highly recommended that you have your legal representative(s) review the material declaration before and after you fill it out. These material declarations may be used to place blame on you and/or your company in case of an infraction in the EU. Tell your legal representative(s) that the UK (and probably all other EU member states) will allow “due diligence” as a defense for infractions. That means that third parties, such as your company, may be prosecuted for infractions if your customer can show due diligence. Part of that due diligence will be based on the material declarations received from suppliers.


13. We sell populated circuit boards. How do we demonstrate compliance with RoHS?

This is a difficult subject. The best and cheapest way is to get information on RoHS compliance for each material or component from your suppliers. If this is not possible, you have a difficult task. You will have to get information for each “homogeneous material” comprising your populated circuit board. It would be best to test each material BEFORE they get made into individual components. Barring that, supply enough individual parts to your lab (including samples of solders) so they may be tested – it is very difficult, if not impossible, to test every homogeneous material on a populated board for RoHS compliance. That is why ASTM International Committee F40 has proposed testing materials for compliance prior to their use in component manufacture: it is easier, and it is less costly to the entire supply chain.


14. Why can’t we just grind components into a powder, then test for RoHS compliance?

Remember, RoHS compliance is based on each “homogeneous material” and not components or devices.  If a component or populated circuit board is ground up and tested, restricted substance concentrations in the homogeneous materials are diluted.  If a lab grinds up a complex component or entire product, they will not be able to state anything about RoHS compliance, since they will not know which material any restricted substances found come from, or if the restricted substance comes from an exempt application.

The grinding equipment specified by the electronics OEMs to use in grinding up components is difficult if not impossible to clean.  Plastic and low melting elements (e.g., lead) get smeared onto the blades and other surfaces of the equipment.  Also, abrasive samples such as populated circuit boards will abrade parts of the equipment such as stainless steel and contaminate the sample with chromium and/or nickel or other elements. 

For example, let’s say that a circuit board is ground up using the electronic OEM technique.  The first issue will be whether the ground sample has been contaminated by past samples or the grinding equipment.  Even if that was not an issue, let’s say the final ground sample is analyzed for TOTAL lead, cadmium, hexavalent chromium, mercury, PBB, and PBDE.  The analysis cannot separate exempt lead from non-exempt lead, exempt cadmium from non-exempt cadmium, and so on.  So which is the “good” lead and which is the “bad” lead?  No one can tell.  Besides, there is no way to create a certified reference material to validate the results.  So such testing is essentially WORTHLESS.  If an electronics OEM tells you to grind up your sample and you tell us to grind up your sample, we cannot state compliance.  Neither should you.  Let the OEMs have the data and let them state conformance or non-conformance based on the results.


15. This is all very confusing. Isn’t there a better way to regulate substances?

While the EU has noble goals concerning protection of human health and the environment, their means of doing so cause confusion and great expense to industry.  There is a better way to do this, and the EU is bound by the World Trade Organization Agreement on Technical Barriers to Trade (TBT) to do things to minimize costs and unnecessary work.  Unfortunately, no sector affected by the EU hazardous substances Directives has decided to take the EU to task on the issues.  The result is that supply chains all over the world are spending billions of dollars more than necessary to comply with the EU legislation.  It is likely to get worse before it gets better, but something must be done.  If you feel your business is spending too much on compliance issues PLEASE WRITE YOUR REPRESENTATIVES IN GOVERNMENT!  Government will only take action if industry says there is a problem.  Here are two people you can write to concerning RoHS issues:

Robert Straetz
Dept. of Commerce, International Trade Admin.
14th & Constitution Ave.
Room 3632
Washington, DC 20230

202.482.4496 Email


Jim Sanford
Deputy Assistant USTR for European Affairs
Office of the U.S. Trade Representative
1724 F Street, NW.
Washington, DC 20508

202.395.3320 Email


16. What is being done to help companies comply with RoHS?

ASTM International has created Committee F40 on Declarable Substances in Materials. This Committee was formed to help industry develop the standards and test methods necessary to comply with RoHS and other legislation. ASTM is working with the US government and industry trade associations to help fix this mess. If you would like to help, please feel free to get involved – email Don Shuman at IMR Test Labs.


17. What test methods are used to assess RoHS compliance?

Standard test methods are under development. The EU Member States have not told anyone how they will test products for compliance, which is a violation of the WTO TBT Agreement. Meanwhile, most labs are adapting current tests to determine concentrations of RoHS substances in materials. X-Ray Fluorescence (XRF), Inductively Coupled Plasma Atomic Emission Spectrometry (ICP-AES), Cold Vapor Atomic Absorption Spectrometry (CVAAS), Direct Mercury Analysis (DMA), UV-VIS, GC-MS, and other techniques are currently being used.


18. What is “Due Diligence” defense?

Due diligence means that you can show that you did everything “a reasonable person would do” in order to comply with the law. It also means that you may be able to show that an infraction was not due to your or your company’s actions; you may be able to show that an infraction was due to someone else’s action or inaction. Material Declarations are used to show due diligence, since they are used to get statements of compliance from suppliers. Once such a document is in the possession of a company, it may be possible to point to the document and state that there was no reason to disbelieve the information given. Then, an infraction may be assigned to a third party as if they had committed it themselves. So anyone making false, misleading, or incorrect statements on material declarations may be prosecuted as if they had committed the infraction.


19. How do I document my compliance efforts to show due diligence?

Keep your test results, Certificates of Analysis, and Material Declarations in a safe, accessible place. It is recommended that you keep both hard copies and electronic copies. Make sure you keep records of everything you fill out for other companies. Also, it is important to document any changes you made to your products, production method, or materials in order to comply with RoHS – this also helps show due diligence. Keep track of costs associated with compliance as well.


20. Is plating a “homogeneous material”?

According to the EU Commission, plating and coatings are “homogeneous materials”.  The problem with this view is that in chemical analysis, plating and coatings are commonly removed from substrates by chemical means, and are not “mechanically disjointed” from the substrate.  This is not such a big problem technically, however, since there are quite a few chemical methods for removing plating and coatings from surfaces.  But if the Commission or the TAC decides to specify that plating and coatings must be removed by mechanical means, we will be left with insurmountable technical challenges involved with mechanical removal of plating and coating from small, complex parts. Imagine trying to mechanically remove a 0.001” zinc coating from the surface of a galvanized screw without removing any of the steel.  Impossible?  Maybe.  Impractical?  Absolutely.

One exception to the chemical removal of coatings from substrates is hexavalent chromium conversion coatings.  Since hex chrome coatings vary in mass over time due to exposure to the environment and because hexavalent chromium coatings are often very thin (on the order of 200 nanometers), determining the total coating mass on a chromated surface is difficult if not impossible.  Besides, there exist no certified reference materials with which such a method could be evaluated, and it is unlikely that such reference materials will ever be produced.  It is the standard practice that hexavalent chromium coatings are determined in units of mass of hexavalent chromium per unit area (such as ug/cm2) instead of weight percent.  But the EU Commission has not backed away from their definition of hexavalent chromium conversion coatings as homogeneous materials, nor have they changed their MCV units of weight percent.


21. Where in “old” electronic equipment is hexavalent chromium found?

Hexavalent chromium is used in two general applications in relation to electronic equipment: as a chromate conversion coating on metal surfaces to act as a corrosion inhibitor, and as pigments in plastic and ink.  Other possible applications in relation to electronic equipment are the use of hexavalent chromium in the textile, leather, and glass industries.  Note that the chromium found in a metal alloy such as stainless steel is not considered to be in the hexavalent state, and it is not environmentally available; the exception to this statement is when high chromium steels are welded, hexavalent chromium may be created and released in the fumes.

Pigment colors that may contain hexavalent chromium include red, yellow, orange, and green. 


22. What are the steps my company should take toward demonstrating RoHS-compliance of our products?

The first step is education.  It is very important to understand, as much as possible, what it means to be RoHS-compliant and what products are affected by RoHS.  One of the most important things to know is that the (proposed) basis of compliance is each “homogeneous material”; that means that each material used to construct every part in every covered electrical and electronic product must comply with RoHS.  It is also important to know what is and is not exempt from RoHS.  There are several ways to go about educating yourself and your company, including attending seminars, hiring in a consultant for a seminar, and reading free information available on the internet (the best official sites are
www.dti.gov.uk/sustainability/ and www.europa.eu.int/comm/environment/index_en.htm.) 

The second step is awareness.  Make sure that upper management is aware of RoHS, when it comes into effect, why the company's products are affected, and what the potential impact on the company might be.  Most people in the know about RoHS will tell you that it is vital that leadership and support for a RoHS-compliance effort comes from upper management.  RoHS-compliance can be a costly and time-consuming endeavor, so upper management will have to be on board.  RoHS-compliance can mean that your company will have to go through big changes, including retooling, redesign, renumbering of part numbers, adjustment of purchasing practices, and editing of drawings and other internal company documentation such as material specifications.

The third step is assessment of your product line.  In a very real sense, this is risk assessment: you are trying to determine in which cases you know you are compliant, in which cases you know you are not in compliance, and in which cases you do not know if you are compliant.  Risk assessment should be conducted with “due diligence” in mind, meaning that you should do what a reasonable person would do to ensure your products comply.  That usually means you have to be able to back up your claims of compliance with statements and/or data. The following mantra should be running through your head: “What do we think, what do we know, what can we prove?”

The fourth step is to do a survey of your materials and parts suppliers.  You should ask them if their products are RoHS-compliant and if they are, ask them if they can supply either a statement to that effect or a certificate of analysis.  If not, ask them if and when they expect to be compliant or if they would be willing to get the necessary information together to support their product compliance.  That may require them to do a survey of their suppliers and/or test their products.  You may want to test their products if the statements you receive are suspect.

The fifth step is to fill in the gaps in your product compliance.  That may mean you will have to change suppliers to those who can demonstrate RoHS-compliance, or you may have to test your remaining items for compliance.  Make sure that any testing you have done is done by a competent laboratory; the best choice is a materials testing laboratory with accreditation to ISO 17025.  It is not recommended that you engage a laboratory without the assurance that their results are trustworthy.  A key to making such a judgment is to ask the laboratory if, based on the results of testing, they will make a statement of RoHS-compliance.  If they will not do so, you may as well be throwing your money away.

The sixth and last step is to organize all the information you have gathered to back up statements of compliance for each product.  This information should be kept available in case it is requested by your clients or by an enforcement authority.  It is recommended that you keep hard copies in addition to electronic copies of the information.


23.  What is the difference between a PBDO and a PBDE?

There is no difference.  These are acronyms which stand for different names of the same compounds.  So PBDOs are restricted by RoHS, because they are PBDEs.


24.  What is the official definition of “homogeneous material”?

Unfortunately, there isn’t one, and there will not be an official definition.  The EU Commission says that only the European Court of Justice may decide what the definition will be.  The best advice I can give is to follow the definition(s) given in the EU Commission FAQ document or the UK DTI draft RoHS regulations, because the definitions will not appear in any official document.


25.  Should energy dispersive XRF be used to determine RoHS compliance?

Because energy dispersive XRF, or EDXRF, is a quick and easy technique for measuring chemical compositions, IMR Test Labs has hoped that it would be a useful, time and cost-saving method for analysis of samples for RoHS substances.  But even the IEC TC 111 WG3 has shown in a recent round robin that the technique is not yet accurate or precise enough to yield dependable results.  We continue to hope that EDXRF will be developed into a sound, trustworthy technique for analysis of RoHS substances in a wide variety of materials.  Right now, we suggest that anyone using XRF to measure RoHS substance concentrations take care in evaluating the results.

©2015 Paramount.  All Rights Reserved.                                                                  P A R A M O U N T