How Do Saudi Suppliers Respond to SASO's Draft Technical Regulations on RoHS
Created At: 2021-10-15

On 28 March 2018, Saudi Arabia issued Notification No. /TBT/N/SAU/1048 to develop a draft technical regulation on the restriction of the use of certain hazardous substances in electrical and electronic equipment, which is also applicable in the United Arab Emirates, Oman, Bahrain, Qatar, Kuwait, Yemen and other countries. The electrical and electronic equipment to which the draft regulation applies includes 11 categories of products such as large appliances, small household appliances, IT and telecommunications equipment, imaging equipment, lighting equipment, power tools, etc.

On 9 July 2021, the Saudi Standards, Metrology and Quality Organisation (SASO) officially published the draft technical regulation on Restriction of Hazardous Substances in Electrical and Electronic Equipment by RoHS (notification number G/TBT/N/SAU/1166), which mainly describes the product categories controlled by RoHS in Saudi Arabia, the conformity assessment procedures and the limit values of hazardous substances and related testing standards. All electrical and electronic equipment and devices under the controlled product category must meet the regulatory limits before they can be marketed in Saudi Arabia, and the regulation will become mandatory on 5 January 2022.

I. Content and purpose of RoHS certification

The Saudi SASO issued regulations on RoHS Restriction of Hazardous Substances (RoHS) in order for Saudi Arabia to ensure that commercially available electrical and electrical and electronic equipment and its spare parts have a lower percentage of hazardous substances than required to ensure the protection of the environment and the health and safety of consumers.

Product categories under RoHS control in Saudi Arabia.

a. Large and small home appliances

b. Information and Communication technology equipment

c. Lighting equipment

d. Electrical and electronic tools and equipment (other than large stationary industrial equipment)

e. Games, entertainment devices, and sports equipment

f. Monitoring and control tools

Hazardous substances used in products under control and limit value requirements.

The above range of products, whether imported from other countries or manufactured locally in Saudi Arabia, are required to comply with the RoHS technical requirements whether they are present in the market for display or sale in the Kingdom of Saudi Arabia. However, there are some products that are not included.

All materials excluded from the application of hazardous material limits

a. Medical equipment

b. Military weapons and equipment

c. Equipment to be sent to space

d. Large-scale stationary industrial tools

e. Large-scale fixed installations

II. The process of RoHS certification

Following the mandatory implementation of the Saudi Technical Regulation on Restriction of Hazardous Substances in Electrical and Electronic Equipment, the technical regulation requires that the supply of electrical and electronic devices and equipment within the mandatory scope, must not only meet the requirements of the relevant technical regulations previously issued by SASO, but the supplier must also provide a test report issued by a SASO-accredited laboratory demonstrating compliance with the RoHS technical limits in accordance with the provisions of the ISO/IEC 17067 standard specification "Guide to the Basis of Conformity Assessment Product Certification and Product Certification Scheme", and relevant documentation to pass the conformity assessment process, in order to obtain a Certificate of Conformity issued by a Conformity Assessment Body to demonstrate that the product meets the latest regulatory requirements for hazardous substances limits.

Note The above and below references to suppliers of electrical and electronic devices and equipment for sale in the Saudi market refer to the importer of the product, the manufacturer of the product locally in Saudi Arabia or in other countries, and any person in the supply chain, whose activities may affect the product properties.

In addition, the products should be accompanied by technical documentation which should include

a. Supplier (Manufacturer/Importer) Declaration of Conformity.

b. Risk assessment document.

c. The necessary warnings, cautions and manuals for safe and proper use of the product.

Type approval is defined as one of the conformity assessment procedures, under which a notified body reviews and verifies the technical design of the product and declares that the technical design meets the requirements of the relevant Saudi Technical Regulations.

Type approval may be conducted by one of the two following methods:

a. Examination of a representative sample of the entire product, that represent the expected production (production model).

b. Assessment of the conformity of the technical design of the product by auditing the relevant technical documentation and manuals (design model), and examining a representative sample of the expected production for one part or more involving hazardous parts of the product (a combination of the production model and the design model)

The Type of Operation approval application process requires the supplier to submit the following information and documentation to a SASO accredited conformity assessment body.

a. Name and address of the manufacturer

b. A written declaration not to submit the same request to any other Notified Body.

c. Technical documentation facilitating the assessment of the conformity of the product to the requirements of Saudi technical regulations. Such documentation shall include adequate analysis and evaluation of risks.

d. roduct design, production and operational documentation of the product

e. Technical documentation: description of the product, design and manufacturing drawings, structural drawings, disassembly of parts and components, with the necessary descriptions

f. Test reports

g. Representative samples of the planned production

Upon receipt of the above documents and samples, the conformity assessment body will review and evaluate them. If the product meets the requirements of the Saudi and related technical regulations, the Conformity Assessment Body will issue a Type Approval Certificate to the manufacturer. If the product does not pass the examination or testing, the conformity assessment body shall notify the applicant, make the appropriate changes and reapply. RoHS certificates are issued by conformity assessment bodies through SABER systems and are valid for one year.

In general, the type approval process is completed by the manufacturer's application, or the supplier may, with the manufacturer's consent, submit documentation and carry out the above process on behalf of the manufacturer.

III. Impact of RoHS certification on other certifications, customs clearance and sales

1. Impact on other certifications.

Before registration with SABER PCOC, the Gulf Technical Regulations for Low Voltage Electrical Equipment, IECEE and other relevant electrical technical regulations, a RoHS certificate must first be obtained.

SABER SCOC will not be issued on the basis of RoHS certificates, SCOC shall be issued on the basis of other applicable technical regulations (e.g. IECEE, G-mark etc. certificates)

CB certificates will only be issued after approval of RoHS and low voltage electrical equipment and other relevant electrical technical regulations.

2. Impact on customs clearance and sales.

The regulatory body responsible for customs, marketing and manufacturing shall verify that the product complies with the prescribed conformity assessment procedures as well as the customs port and the technical documentation attached by the manufacturer. And it has the right to take random samples of the product at the customs port and submit them to the laboratory to determine compliance with the RoHS technical regulations. If once the sample is taken, the regulator can charge the supplier (production manufacturer/importer) for the testing and related costs. Once a product is found to be non-compliant, the regulator shall take the necessary measures, including and not limited to withdrawing, destroying and restricting the product, cancelling the relevant certificate of conformity and imposing the appropriate penalties.

The RoHS technical regulations for electrical and electronic equipment further regulate the quality of products for the Saudi Arabian market and will become mandatory from 5 January 2022. In order for all products under the control category to pass the requirements of Saudi Arabia import customs and market supervision authorities, the product manufacturer and the Saudi market suppliers need to check as soon as possible whether the production materials, product components and production process are in compliance with the RoHS hazardous substance restriction requirements.

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