Annex II of Directive 2011\/65\/EU lists ten substances with a maximum tolerated concentration in homogeneous materials, expressed in weight percentage. Nine of these have a limit value of 0.1% by weight. Only cadmium is ten times lower, at 0.01%. <\/p>\n\n The last four are phthalates, plasticizers used in plastics. They were added later, with a specific implementation date for medical devices and monitoring and control instruments. They have been applicable to other categories for a longer period. <\/p>\n\n The directive defines a homogeneous material as a single material of uniform composition. Material that cannot be separated into different materials by mechanical actions also counts. Unscrewing, cutting, crushing, grinding, and abrasive processes are examples of mechanical actions. <\/p>\n\n In practical terms, this means your product consists of dozens to hundreds of homogeneous materials. The coating on a screw is one. The solder on a PCB is one. The insulation of a wire is one. The core of that same wire is another. <\/p>\n\n The limit value applies to each such material. Not per component, not per PCB, and certainly not per product. <\/p>\n A product weighing 800 grams containing 0.4 grams of lead is at 0.05% and appears to be well within limits. However, if that lead is contained in a solder joint of 0.5 grams, then that joint is 80% lead and the product fails. The question is therefore not how much is in it, but where it is located. <\/p>\n<\/div>\n\n You cannot demonstrate RoHS compliance with a single measurement of the complete product. You need supporting documentation per material. Or at least per component, backed by a supplier declaration. It is a chain of evidence rather than a single report covering everything. <\/p>\n\n In practice, you build this using a Bill of Materials (BOM). For each component, you record which materials it contains and what supporting evidence you have: a supplier declaration, a test report, or your own measurement. If supporting evidence is missing for a component, that constitutes a gap in your technical file. <\/p>\n\n Furthermore, this approach scales. If you use the same connector in ten products, you only need to arrange that supporting documentation once. <\/p>\n\n The directive applies to electrical and electronic equipment in eleven categories, ranging from household appliances and IT equipment to lighting, tools, toys, medical devices, monitoring and control instruments, and automatic dispensers. The eleventh category is a catch-all category for everything that does not fit into the first ten. <\/p>\n\n This catch-all category is important. It means you cannot conclude that RoHS does not apply simply because your product does not fit into one of the well-known categories. If it runs on electricity, assume it falls under the scope unless an exemption applies. <\/p>\n Briefly describe the product and the supporting evidence you have. We will contact you regarding what is still required. <\/p>\n\t\n\t\n <\/p>
Substance<\/th> Limit value<\/th><\/tr> <\/thead> Lead<\/td> 0,1 %<\/td><\/tr> Mercury<\/td> 0,1 %<\/td><\/tr> Cadmium<\/td> 0,01 %<\/td><\/tr> Hexavalent chromium<\/td> 0,1 %<\/td><\/tr> Polybrominated biphenyls (PBB)<\/td> 0,1 %<\/td><\/tr> Polybrominated diphenyl ethers (PBDE)<\/td> 0,1 %<\/td><\/tr> Bis(2-ethylhexyl) phthalate (DEHP)<\/td> 0,1 %<\/td><\/tr> Butyl benzyl phthalate (BBP)<\/td> 0,1 %<\/td><\/tr> Dibutyl phthalate (DBP)<\/td> 0,1 %<\/td><\/tr> Diisobutyl phthalate (DIBP)<\/td> 0,1 %<\/td><\/tr> <\/tbody> <\/table> What constitutes a homogeneous material<\/h2>\n\n
What this means for your technical file<\/h2>\n\n
Which products it applies to<\/h2>\n\n
Unsure if your RoHS file is correct?<\/h3>\n\n\t\t\t
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