Interpretation of Rohs Globalization and New Requirements for Packaging Labeling
Created At: 2022-02-28

I. Interpretation of RoHS 2.0 and its current status

RoHS is a mandatory standard set by EU legislation, the full name of which is the Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive. The standard was implemented on 1 July 2006 and aims to eliminate six substances - lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers - from electrical and electronic equipment.

On 1 July 2011, ROHS 2.0 (2011/65/EU) was officially published in the Official Journal of the European Union and came into force on 21 July.

RoHS 2.0 differs from the original RoHS in the following ways.

  • The inclusion of all electrical and electronic equipment, including medical devices, in the scope of control.

  • The addition of an 11th category of products, i.e., other electrical and electronic equipment not covered by the previous 10 categories.

  • Selection of 4 toxic and hazardous substances (DIBP, DEHP, DBP and BBP) as candidates for restriction.

  • Incorporation of ROHS compliance for electrical and electronic equipment into the CE marking requirements.

II. Requirements for RoHS in various countries

The RoHS requirements are mainly used to regulate the material and process standards of electrical and electronic equipment to make them more beneficial to human health and environmental protection. For this purpose, many countries will adopt the same or similar standards as EU RoHS to limit the harm of imported products to human health or the environment of their consumers.

①Eurasian Economic Union

Restrictions on hazardous substances are mandatory in the Eurasian Economic Union (EAEU) countries, whose EAEU-RoHS follows the regulation EAEU TR 037/2016. effective 1 March 2020, penalties may be imposed if a product complying with TR EAEU 037/2016 is not properly approved, as the product will be deemed not to comply with the relevant requirements. The scope of harmful substance restrictions is the usual 6, and the scope of product control is as follows.

1. Electrical apparatus and appliances for domestic use.

2. Electronic computers and devices connected to them, including their combinations.

3. Means of telecommunication (terminal telecommunication devices).

4. Copiers and other electrical office (office) equipment.

5. Electronic tools (manual and portable electric machines).

6. Sources of light and light equipment, including equipment, built into furniture.

7. Eelectromusical tools.

8. Game and trading automatic machines.

9. Cash registers, ticket printing machines, ID card readers, ATMs, information kiosks.

10. Cables, wires and cords intended for use at a rated voltage of not more than 500 V AC and / or DC, except for fiber optic cables.

11. Automatic switches and residual current devices.

12. Fire, security and fire-security detectors.

Products that have passed the EAEU TR conformity assessment shall be marked with the EAC mark. The marking requirements are as follows:

  • The letters “E”, “A”, “C” designed just with the right angles

  • The letters enclosed in the square, so the height=width

  • The size of the mark should be not less than 5 mm

  • The mark is monochrome (one-color), contrast with the color of surface

  • The size and design of the mark should ensure that it is legible and that the letters on the mark are clearly visible to the naked eye.

  • The EAC mark can be used only after confirmation to all Regulations concerning exact product.

②Europe

The implementation of RoHS in European countries is undoubtedly mandatory, following the regulations of Directive 2011/65/EU, (EU) 2015/863 and amendments and the test standard IEC 62321. RoHS 2.0 restricts the range of hazardous substances to 10 types and the scope of product control is as follows.

1. Large household appliances

2. Small household appliances

3. IT and telecommunications equipment

4. Consumer equipment

5. Lighting equipment

6. Electrical and electronic tools

7. Toys, leisure and sports equipment

8. Medical devices

9. Monitoring and control instruments including industrial monitoring and control instruments

10. Automatic dispensers

11. Other EEE not covered by any of the categories above.

The restrictions for DEHP, BBP, DBP and DIBP will apply from 22 July 2019 to all electrical and electronic equipment (except medical devices and monitoring instruments, but including cables or spare parts required for the repair, reuse, functional update or capacity upgrade of electrical equipment). It will apply to medical devices and monitoring and control instruments from 22 July 2021.

③ Singapore

RoHS is mandatory in Singapore from 1 June 2017, following the regulation EN 50581:2012. currently the test standard is EN 62321, but according to EN 50581:2012, EN 62321 will be replaced by a series of standards designated as EN 62321- x. The range of hazardous substance restrictions is the usual 6 types and the product control range is as follows.

1. Mobile phone

2. Portable computers

3. Refrigerators

4. Air conditioners

5. Panel TVs

6. Washing machines

These controls are implemented at the import stage. Controlled EEE which exceed the allowable concentration limits for the 6 HS, are not allowed to be imported for local use and distribution after 1 June 2017. However, existing stocks of the controlled EEE imported prior to 1 June 2017, will be allowed for sale until these stocks are depleted.

Automotive electronic products out of the RoHS requirement. There are no clear requirements for RoHS labelling in Singapore and no requirements for testing laboratories.

④ UAE

UAE RoHS is mandatory under ECAS certification and voluntary under EQM certification. The applicable standards are IEC/TR 62476, IEC 63000, IEC 62321 - x, IEC 62474 and IEC TR 62474 - 1. The range of restrictions on hazardous substances is 10 and the scope of product control is as follows:

1. Large household Appliances

2. Small household Appliances

3. IT and Telecommunication equipment

4. Consumer equipment and photovoltaic panels

5. Lighting equipment

6. Electrical and electronic tools (with exception of largescale stationary industrial tools)

7. Toys, leisure and sports equipment

8. Medical devices (with exception of all implanted and infected products)

9. Monitoring and control instruments

10. Automatic Dispensers

11. Other EEE not covered by any of the categories above

The enforcement of the restriction of hazardous substances is phased: from 2018 to 2020 and then to 2022. from 1 January 2022, the restriction of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers in cables and spare parts for medical devices, in vitro diagnostic medical devices, monitoring and control instruments and industrial monitoring and control instruments. DEHP, BBP, DBP, DIBP in Restrictions in medical devices, in vitro diagnostic medical devices, monitoring and control instruments, industrial monitoring and control instruments, including cables and spare parts.

For automotive electronics, if the product is an electrical device, it requires ECAS ROHS. The test report should be issued by an ISO 17025 laboratory. There are no special requirements for the ECAS RoHS icon and the EQM RoHS icon is covered by the EQM certification icon.

In addition to the four countries listed above, there are many other countries where concentration limits for hazardous substances are mandatory, such as Vietnam, Ukraine, Turkey, Korea, India, etc. But there is still a lot of room for RoHS globalization as far as it goes, as many countries such as Malaysia, Mexico, South Africa, Thailand, Australia, Brazil etc. do not currently have mandatory implementation. If you would like more information on RoHS restrictions for electrical equipment in your importing country, please feel free to contact us.

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