EU Environmental Regulation: What Is the Difference Between RoHS, REACH and WEEE?

Since the early 2000s, the European Union has passed several directives that aim to create products that are not only safer for human health, but also more environmentally friendly. These directives include RoHS, REACH, and WEEE. All three of these regulations must be taken into account when placing products on the EU market.

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

RoHS defines EEE as: “Equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields” (Directive 2011/65/EU). All EU directives that focus on EEE (such as WEEE) use the same definition.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. The current restrictions are the result of one original directive and two additions known as RoHS II and RoHS III.

Substances Restricted by RoHS

The ten hazardous materials currently included in RoHS can only be used in electronic equipment under the maximum levels laid out by the directive. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

  • Cadmium (Cd)
  • Mercury (Hg)
  • Lead (Pb)
  • Hexavalent Chromium (Cr VI)
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE)
  • Bis(2-Ethylhexyl) phthalate (DEHP)
  • Benzyl butyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Read more: What is RoHS?

Who Is Subject to RoHS Regulation?

Any manufacturer, importer, or distributor of electronic and electrical equipment (EEE) sold in the EU market must be compliant with RoHS. Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

It is the manufacturer’s responsibility to ensure their product complies with RoHS. The manufacturing and testing requirements necessary for RoHS compliance may also increase costs for manufacturers. 

Read more: What is ‘RoHS Compliant’?

What is REACH?

REACH stands for Registration, Evaluation, Authorisation, and Restriction of Chemicals, and is an EU regulation that manages and restricts the use of hazardous chemicals in products manufactured and sold in the EU. Like RoHS, REACH restricts hazardous chemicals, but is not specific to electronics, as RoHS is.

The regulation entered into force on June 1, 2007. 

REACH is designed to protect human health and the environment from the effects of harmful chemicals. The regulation also helps the European Chemicals Agency (ECHA) gather information about chemical substances used in products on the EU market. Ultimately, the goal of REACH is to encourage companies to research and use safer alternatives.

All EU manufacturers and importers must register any substances used (above a specific yearly amount) with ECHA. This helps to:

  • Identify risks that these substances pose to human health
  • Prove to ECHA that the company is managing that risk
  • Create guidelines for safe use of their product to protect public health of consumers

Products Restricted by REACH

REACH has an extremely widespread impact, as it applies to all chemical substances used in products manufactured, imported and sold on the EU market. This does not include only industrial processes, but also products we use every day, such as clothes or cleaning products.

REACH also applies to chemicals used in electronic products. When a substance that is restricted by RoHS is added to the list of REACH restricted chemicals, RoHS and REACH may overlap. Usually RoHS is given priority when it comes to regulating EEE, but authorities often try to ensure that REACH and RoHS are compatible.

There are several products that have total exemption from REACH regulation, such as radioactive materials. There are also partial exemptions, products that are exempt from certain restrictions. For example, substances used in food or medicinal products are exempt from the registration and authorisation requirements. For a full list of total and partial exemptions, visit the European Chemicals Agency website.

Substances Restricted by REACH

Chemicals that are regulated by REACH are known as SVHCs, Substances of Very High Concern. SVHCs include chemicals that are carcinogenic or mutagenic, cause reproductive problems, or bioaccumulate. 

SVHCs include several substances also restricted by RoHS, such as phthalates, cadmium, lead, and mercury.

REACH requires companies to disclose and report SVHCs used in their products or packaging.

If a chemical’s risk is viewed to be unmanageable, its use can be banned entirely, restricted, or require prior authorization from the ECHA before use in production. Companies must ensure that their products do not contain substances in amounts exceeding REACH thresholds.

A full list of restricted SVHCs can be found on the ECHA website. 

Who is Subject to REACH Regulation?

REACH affects companies in almost every sector of industry. Companies are responsible for complying with REACH regulation. This includes:

  • Manufacturers in the EU, both of chemicals and finished products
  • Importers in the EU, both of chemicals, chemical mixtures, and finished products
  • Downstream companies: If you handle chemicals in a professional or industrial setting, you may be subject to REACH regulation.

Unlike RoHS and WEEE, companies established outside the EU are not obligated to comply with REACH, even if their products are imported into the EU market. Instead, it is the importers that lie within the EU who are responsible for ensuring REACH compliance.

Regulation and compliance differs by the type of product placed on the market. However, all companies must identify the risks of the substances they manufacture or use in manufacturing, and then demonstrate to ECHA how they are safely and effectively managing that substance’s use. Additionally, information on how to manage risk when using that product must be communicated to consumers.

What is WEEE?

WEEE, Waste Electrical and Electronic Equipment Regulation, is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use.

The directive works to:

  • Reduce the amount of e-waste that ends up in landfills
  • Encourage redesign of EEE so that it can be dismantled and properly disposed of
  • Increase re-use of WEEE and its components and materials

To achieve these goals, WEEE requires Member States to set specific targets for the amount (by weight) of EEE collected, recycled, and recovered. These targets differ by country.

Products Restricted by WEEE

As of 2018, all EEE is included under WEEE, as every EEE device becomes WEEE at the end of its use.

EEE subject to WEEE regulation is classified under six categories:

  1. Temperature exchange equipment
  2. Screens, monitors, and equipment containing screens with a surface larger than 100 cm2.
  3. Lamps
  4. Large equipment (any dimension larger than 50cm)
  5. Small equipment (no dimension larger than 50cm)
  6. Small IT and telecommunication equipment

Read more: What is WEEE?

Who is Subject to WEEE Regulation?

All producers of EEE must comply with WEEE requirements. The directive defines producers as anyone who:

  • Manufactures and sells EEE under his/her own brand
  • Resells EEE produced by other suppliers under his/her own brand
  • Imports or exports EEE into an EU Member State
  • Sells EEE by “distance” (for example, over the internet) to Member States, even if this seller is in a different country.

The directive sets out specific requirements producers must follow to be WEEE compliant, such as reporting the amount of EEE placed on the market and providing e-waste recycling services to customers. 

Read more: WEEE Compliance

Similar Objectives: Goals of RoHS, REACH, and WEEE

RoHS, REACH, and WEEE all share a similar objective: to protect the environment and human health. 

RoHS- The RoHS directive restricts the use of toxic materials in EEE. RoHS aims not only to protect the health of users of EEE devices, but also to reduce occupational health hazards for manufacturers of EEE. RoHS also keeps hazardous materials from accumulating in the environment after EEE is thrown out.  

REACH- REACH aims to protect human health from the effects of dangerous chemical substances used in products we use in our everyday lives, ranging from clothing to furniture. REACH also seeks to protect the environment by keeping large amounts of dangerous chemicals out of manufacturing, and out of landfills when products are disposed of.

WEEE- WEEE aims to safeguard human health from the effects of EEE at the end of its lifecycle. By improving recycling of e-waste, WEEE keeps hazardous materials used in EEE out of landfills, and thus, out of soil, water, and air. This protects the environment, animals, and human health against toxic materials contained in EEE.

Read more about each regulation’s protection of human health and the environment below.

All three regulations seek to protect the environment and human health by placing requirements on manufacturers and producers of potentially harmful products, rather than on consumers. 

Different Methods: Requirements of RoHS, REACH, and WEEE

While RoHS, REACH, and WEEE all aim to protect the environment and human health, each regulation works to achieve this goal through a different method or set of requirements. 

RoHS, REACH, and WEEE create requirements that fall into three categories, based on where in a product’s life cycle the requirements are focused: during a product’s manufacturing, during a product’s use, or upon a product’s disposal. Even requirements that target the same stage in a product’s life cycle vary greatly by directive.

Product Manufacturing Requirements

Each regulation creates requirements that manufacturers or importers must follow either before placing the product on the market or upon placing the product on the market.

RoHS- RoHS requires that manufacturers of EEE do not exceed the allowable limits of restricted substances. 

Manufacturers must follow a series of steps to confirm compliance and demonstrate compliance to authorities and the public, including testing the product and compiling documentation about the product’s manufacturing. These steps must be taken prior to the product’s placement on the market.

Read more: What is ‘RoHS Compliant’?

REACH- Like RoHS, REACH works to keep dangerous chemicals out of products sold on the EU market. 

Manufacturers and importers are required to research and report on the chemicals used in their products in order to prove the company is able to safely manage the chemical’s risk. Companies must register with the European Chemical Agency before manufacturing a product using potentially toxic chemicals.

REACH requirements emphasize information gathering, as all data is reported to the European Chemical Agency, who compiles data and makes decisions about requirements for chemical use on a case by case basis.

WEEE- Under WEEE, producers must take several steps upon placing EEE products on the market. Producers must:

  • Register and report the volume of EEE placed on the EU market to the correct governing body (which varies by country). 
  • Provide recyclers with the necessary information on how to recycle the EEE product or prepare the product to be re-used.

Read more: WEEE Compliance

Product Use Requirements

Each regulation requires manufacturers to create a marking or messaging that is intended to educate the buyer.

RoHS- RoHS requires manufacturers to put a CE marking on RoHS compliant EEE products. This shows authorities and the public that the product has been carefully evaluated and documented, and does not exceed allowable amounts of hazardous substances restricted by RoHS.

REACH- REACH requires manufacturers and importers of products that use dangerous chemicals to provide guidelines to consumers for how to use the products safely and properly.

WEEE- WEEE requires that all compliant EEE be marked with the “WEEE symbol,” a recycling bin that is crossed out. This helps customers to properly dispose of their EEE products.

Product Disposal Requirements

Only WEEE creates requirements related to disposal of products at the end of their lifecycle.

WEEE- Producers of EEE must create or finance a system for customers to recycle old EEE. This may entail a collection service or a drop-off location. This recycling program must be free of charge to the customer. 

Customers are not penalized for improper disposal, but still benefit from recycling of e-waste. Read more: What is WEEE?

Impacts of ROHS, REACH, and WEEE

EU environmental regulation’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. RoHS, REACH, and WEEE all impact the cost of relevant products for sellers and buyers and work to protect the natural environment and human health.

1) The Market

All three regulations raise costs for sellers, as they must use new materials or create new compliance programs. This in turn raises costs for buyers, who pay increased prices for their devices. 

RoHS- RoHS raises costs for sellers and buyers of EEE alike. 

EEE manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing EEE products and ensuring RoHS compliance may be costly.

Buyers also experience increased prices of electronics in order to offset costs faced by manufacturers.

REACH- Like RoHS, REACH may increase costs for sellers and buyers. Manufacturers face increased expenses related to registering with the ECHA. Additionally, using substitute chemicals may be costly.

Buyers may experience increased costs as a result of REACH requirements on manufacturers.

WEEE-  Prices may increase for producers as a result of WEEE requirements, such as the creation of new recycling programs.  However, WEEE allows companies to save costs on materials, as companies can begin to use reused, and thus cheaper, materials. 

Buyers may also face higher prices for their electronic devices due to WEEE. As producers pay increased costs to produce WEEE-compliant products and recycling programs, consumers often offset these costs by paying more for their devices

WEEE has wider-spread market impact as well; a central goal of WEEE is to create a circular economy, an economy in which industry reuses and recycles raw materials. The circular economy minimizes waste and addresses resource scarcity in a world of finite raw materials.

2) The Environment

All three regulations work to keep hazardous materials out of landfills, and thus out of water, soil, and air. This protects the environment and other species from the toxic effects of hazardous materials.

RoHS- The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

REACH- REACH reduces the amount of toxic chemicals used in everyday products. Not only does this make the manufacturing process safer, but it also keeps those hazardous chemicals out of the environment when products are disposed of. 

SVHCs restricted by REACH can have far reaching environmental effects, such as river acidification and injury to wildlife. By requiring prior authorization for use of these chemicals, or by outright banning them, REACH works to ensure companies are effectively managing environmental risks.

WEEE- Many electronic devices contain materials such as heavy metals and chemicals that have large environmental consequences upon becoming e-waste. WEEE protects against improper disposal of EEE, which creates environmental pollution, destroys habitats, and impacts the health of other species.

When e-waste is improperly disposed of, toxins and particles are released into the air, causing pollution. These toxic materials can also leech into the soil or groundwater, which can impact crops and drinking water. 

Lastly, WEEE takes up land area when it sits in landfills. By increasing proper recycling measures and encouraging reuse of materials, the WEEE directive helps reduce the amount of space landfills use globally. 

3) Consumer Health

All three regulations protect human health, either by keeping toxic materials out of the manufacturing process or by reducing human exposure to toxic materials in product waste.

RoHS- Several materials restricted by RoHS create toxic waste and occupational hazards that negatively impact human health. EEE that uses higher than allowed amounts of restricted substances cause health problems not only for workers manufacturing the products, but also for recyclers of the products. 

Manufacturing products that use restricted substances also negatively impacts the health of communities located near manufacturing plants.

Lastly, RoHS works to protect human health during the use of products. For example, toys whose paint contains lead, a toxic heavy metal, are not RoHS compliant.

REACH- REACH protects human health by managing the use of dangerous chemicals in products we use every day. SVHCs restricted by REACH can cause extreme damage to human health, such as reproductive harm and cancer. 

REACH helps gather information on dangerous chemicals and ensures that the risks to human health are being managed.  If the ECHA determines that a chemical’s risk cannot be managed and will harm manufacturers or consumers, then the chemical will no longer be used in products sold on the EU market.

WEEE- The WEEE directive works to reduce risks to human health caused by exposure to e-waste. 

E-waste can contain toxic substances such as lead, mercury, sulfur and cadmium. If these materials are not disposed of properly, the buildup of contamination in water and soil can cause health problems.

A 2013 WHO study found that exposure to e-waste can cause severe health impacts, including adverse birth outcomes, changes in thyroid function and cell function and decreased lung function (Grant et al. 2013). By creating proper and accessible recycling pathways, WEEE reduces human exposure to e-waste.

RoHS, REACH, and WEEE at a Glance: Comparison Table

RoHSREACHWEEE
Scope: Restricted ProductsRoHS applies to all EEE sold on the UK market, with some exemptions, listed in Article 2 of RoHS 2 (Directive 2011/65/EU).
Read more: What is ‘RoHS Compliant’?
REACH applies to all parts and products sold on the EU market, with some exemptions, listed on the European Chemicals Agency website.WEEE applies to all EEE products sold on the EU market at the end of their life-cycle, with some exemptions.
Read more: WEEE Exemptions.
Restricted SubstancesRoHS includes 10 restricted hazardous substances that are restricted by ppm.These substances are evaluated at the homogenous materials level.REACH restricts a list of over 200 SVHCs (Substances of Very High Concern) that are subject to registration, restriction, or prior authorization. The full list can be found on the ECHA website.WEEE does not include restricted substances.
Party Responsible for ComplianceAll manufacturers of EEE sold on the EU market.Manufacturers, importers, and downstream users of chemicals and products restricted by REACH.All producers of EEE sold or distributed on the EU market.
Read more: WEEE Compliance
Relevance to Companies Outside the EUAll companies who sell or import their products in the EU must comply, even if they are established outside of the EU.Companies that are not based in the EU are not subject to REACH regulation. Instead, importers based in the EU must ensure compliance.All producers who sell or import their products in the EU must comply, even if they are established outside of the EU.
EnforcementRoHS is a directive, so each Member State must put it into law separately, and is responsible for enforcement.REACH is a regulation, so it is legally binding across all Member StatesWEEE is a directive, so each Member State must put it into law separately, and is responsible for enforcement.
NoncompliancePenalties may include financial and legal consequences, such as fines and orders to stop shipping or selling a product. Penalties differ across Member States.Penalties may include financial and legal consequences, such as fines and orders to stop shipping or selling a product. Legal consequences may include imprisonment. Penalties differ across Member States.Penalties may include financial and legal consequences, such as fines or prosecution. Companies are often provided with a warning letter following inspection before further steps are taken. Penalties differ across Member States.

What Is the Function of Heavy Metals in Electronics?

Devices that consumers use every day, such as televisions and computers, contain heavy metals. This article explores why heavy metals are used in electronics and, as well as the toxic effects of those heavy metals.

What Are Heavy Metals?

There is no agreed upon definition of heavy metals. Instead, heavy metals have two definitions.

  1. Heavy metals are metals that have a high density (particles are packed closely together). 

Most heavy metals under this definition have a high atomic number (the number of protons in the nucleus of an atom) and a high atomic weight (the total weight of the atoms making up an element).

  1. Heavy metals are metals with relatively high density that are toxic at low concentrations, meaning even a small amount of the metal is toxic.

To be considered a heavy metal, the material must meet either of these definitions, but does not need to meet both. Some metals, such as mercury or lead, are both high density and toxic at low concentrations. Other metals may simply fit one of the definitions.

Many of the metals you’ve heard of, such as iron, copper, platinum, and gold, are heavy metals due to their high density. Some of these high density heavy metals, such as iron, cobalt, and zinc act as nutrients. Others, such as silver, are not toxic in small amounts, but can be toxic in higher amounts or different states.

Other heavy metals, such as hexavalent chromium and cadmium, are highly toxic in low concentrations and can cause severe health problems when a human is exposed.

Which Heavy Metals are Found in Electronics?

Heavy metals are necessary to create many of the electronic devices an average consumer uses every day. The following heavy metals, while not the only heavy metals used, perform important functions in a wide variety of electronics. 

Cadmium

Cadmium is a heavy metal used in electronics, and is popular due to its malleability. Cadmium selenide, a cadmium compound, is an easily shaped metal that is most often used as semiconductors. 

Semiconductors can conduct electricity in high heat, but not in low heat. Cadmium is a good semiconductor because it is highly resistant to high temperatures. Semiconductors like cadmium selenide have a conductivity (ability to conduct electricity) that lies in between a conductor (like metal) and a non-conductive insulator (like ceramic). As temperature rises, the conductivity of the semiconductor increases, and the cadmium material can act as a conductor. At low temperatures, the same material blocks the flow of electricity. 

Semiconductors are found in most electronic devices today. Semiconductors have an extremely wide variety of functions, but generally they work to amplify signals in a circuit, convert energy, and pass current in a specific direction.

Cadmium also is resistant to corrosion. This makes it a popular metal to use as a protective shield against corrosion in electronics.

Read more about cadmium in electronics: Cadmium

Mercury

Mercury is a heavy metal commonly used in LCD (liquid crystal display) screens. LCD screens use cold-cathode fluorescent lamps (CCFLs) that contain mercury. CCFLs include fluorescent tubes that work to backlight an LCD TV or monitor screen. The light is produced when electricity is used to excite (add energy to) mercury vapor. The vapor is discharged, which creates a fluorescent coating on the inside of the tube that emits light.

Mercury is also used in some laptop screen shutoffs. In a mercury tilt switch used in some laptops, mercury moves to the other side when the laptop is opened or closed. This shift turns the screen on or off.

Mercury was also used to create switches in televisions that were produced before 1991.

Read more about mercury in electronics: Mercury


Lead

Lead is considered one of the most important metals in electronic production. Lead is malleable, does not break easily, and, when combined with tin, has a low melting point, which means it can be worked with at a lower temperature and is less sensitive to variations in temperature.

The main use of lead in electronics is lead soldering. Lead-tin soldering is used to attach electronic components. The lead solder connects two metals securely, allowing an electric signal to pass through. For example, lead solder could attach a wire to a circuit board

Lead is also used in alloys (a mixture) with other metals, such as copper and steel, which expands the use of these metals. Lead alloy in steel is often used in electronic products.

Read more about lead in electronics: Lead

Nickel

Nickel is a heavy metal used in a variety of electrical equipment and devices. Pure nickel conducts electricity well, is magnetic, and is resistant to corrosion. Nickel is often used in electronic wiring. 

Nickel is often used in electronics in alloy form, particularly in heating coils of electric appliances like irons, toaster ovens, and grills. Nickel is also used in powder form in cell phone capacitors, a device that stores electrical energy. Nickel powder may also be mixed in with a non-conductive substance, such as silicone and rubber, to allow for conductivity through the substance. This technique is most frequently used in cell phone microphones.

Hexavalent Chromium

Hexavalent chromium is a form of the heavy metal chromium that is not found in nature, and is thus manmade. Hexavalent chromium is commonly used in anticorrosive coatings on metal parts in electronics or as a pigment or paint.

The process of protecting metal from corrosion using hexavalent chromium is called chromating or passivation. In passivation, a thin layer of chromium salts are added to a metal in an electronic device. Chromium-coated metal is used in many components, including nuts and bolts, electric switches, and antennae.

Read more about chromium in electronics: Hexavalent Chromium

Exposure to Heavy Metals

Some heavy metals used in electronics are toxic. Exposure to heavy metals used in electronics can cause serious environmental and health problems. 

Most people are not exposed to heavy metals when using electronics. For example, it is unlikely that you are frequently exposed to your phone’s circuit board or the inner workings of your LCD television screen. However, exposure may occur either during manufacturing of electronics or during recycling, when the parts are broken down and heavy metals are exposed.

According to a paper published at Stanford University in 2011, heavy metals can harm not only workers in the production and recycling phases, but also communities located near manufacturing plants (Nimpuno et al. 2011).

Additionally, if electronics are not recycled and are instead allowed to break down in a landfill, it is likely that heavy metals will eventually leak out. This not only creates a risk of toxic exposure for humans, but also has severe environmental impacts. Toxic substances can leach into water, soil, and air, harming not only human health, but other species.

Negative Impacts of Heavy Metals

Cadmium

Exposure to cadmium is most famous for causing a degenerative bone disease, Itai-itai disease. This disease was caused by cadmium poisoning contracted as a result of mining. Cadmium is highly water soluble, and so as mining byproducts, including cadmium, were released into a nearby river, cadmium pollution occurred. Eventually, cadmium was absorbed into crops irrigated by the river, causing widespread disease.

Cadmium can also soften the bones and cause kidney damage.

Mercury

Mercury exposure at high levels can cause a host of health impacts, including damage to the brain, heart, lungs, kidneys, central nervous system, and immune system. 

Mercury can be released into the air a number of ways, one of which is through burning of electronic products containing mercury. Mercury can be transported in the air for great distances before it is deposited in soil and water.

While mercury exposure is most common by eating seafood containing mercury, exposure to mercury vapor is also possible if an electronic device containing mercury breaks. For example, if an LCD screen containing cold-cathode fluorescent lamps (which contain mercury) breaks, toxic mercury dust or powder can be released.

Mercury can also cause significant environmental damage. When animals are exposed to mercury at high levels, death and reproductive damage can occur.

Lead

There is no safe exposure level to lead. When lead is swallowed or breathed in, or enters the body another way, it gets stored in blood, which can cause long-term harm.

 Lead exposure, particularly in children, can cause damage to the brain and nervous system, slowed growth, and problems with hearing and speech. Long term exposure in adults can also cause fertility problems, heart disease, and kidney disease.

Nickel

Industrial use of nickel has led to environmental pollution and has increased human exposure to the toxic heavy metal.

Nickel has a wide variety of health impacts caused by exposure, including allergy, headaches, cardiovascular and kidney diseases, lung fibrosis, lung and nasal cancer. While research is ongoing as to the mechanism for these diseases (how nickel acts in the body to cause the disease), inhalation is the clear route of exposure that causes respiratory tract cancer.

Hexavalent Chromium

Hexavalent chromium is carcinogenic and causes a wide range of health problems, particularly in people exposed to the metal in manufacturing.

If hexavalent chromium is breathed at high levels, it can cause lung cancer, damage to the respiratory tract, and damage to the eyes and skin (dermatitis). Prolonged exposure, such as working in a factory that uses hexavalent chromium to produce anti-corrosive coatings, is especially dangerous.

Solutions: Reducing the Risk of Heavy Metals in Electronics

Several countries have enacted legislation that aims to reduce the risks, both to the environment and human health, associated with heavy metals. The most impactful legislation in this area comes from the EU, in the form of RoHS and WEEE directives.

RoHS: Restriction of Hazardous Substances

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). 

Manufacturers may not use restricted substances in amounts above 1000ppm (cadmium’s limit is 100ppm). Restricted substances include heavy metals Cadmium (Cd), Mercury (Hg), Lead (Pb), and Hexavalent Chromium (Cr VI).

RoHS restrictions help reduce the risk of exposure to toxic heavy metals in electronics. For example, if those electronic devices were to break or be put in landfill, it is less likely that high amounts of toxic metals will leak out.

Read more: What is RoHS?

WEEE: Waste Electrical and Electronic Equipment

Waste Electrical and Electronic Equipment (WEEE) is an EU directive that aims to improve the collection, treatment, and recycling processes of electronic and electrical equipment (EEE) that is no longer in use. WEEE helps reduce the amount of electronic waste that ends up in landfills, and helps ensure proper, safe disposal of electronic waste.

Read more: What is WEEE?

Restriction of Hazardous Substances: The Difference Between RoHS 1, RoHS 2, and RoHS 3

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). 

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. The current restrictions are the result of one original directive, RoHS 1, and two additions known as RoHS 2 and 3.

RoHS regulation has evolved over the years to fit ever-increasing concerns about the effects of toxic materials. Each RoHS directive works to restrict the use of hazardous substances in order to protect both the environment and human health.

What is EEE?

It is important that manufacturers, importers and distributors determine whether their product fits the definition of EEE, because all EEE sold in the EU is subject to RoHS compliance requirements. 

All three directives define EEE in the same way: “Equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields” (Directive 2002/95/EC).

Who Is Responsible for Compliance?

All three iterations of the RoHS directive are directed at any manufacturer, importer, or distributor of electronic and electrical equipment (EEE) sold in the EU. Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

Under RoHS, it is the manufacturer’s responsibility to ensure their product complies with RoHS. 

Read more: What is ‘RoHS Compliant’?

RoHS 1: Directive 2002/95/EC

The original directive RoHS 1 was issued in 2002, and limits the use of six materials within EEE deemed to be hazardous to human health and the environment. 

Why Was RoHS 1 Created?

In 2002, the European Council commissioned research on hazardous substances found in electronics. These substances not only proved to be harmful to human health, but also caused environmental problems when EEE was disposed of.

As efforts to increase recycling of electronic products started in the EU, regulators found that materials such as cadmium and mercury could not be recycled safely, even if proper recycling methods were used. The RoHS directive’s method to keep these substances out of landfill is to simply restrict their use in products in the first place.

RoHS 1 aims to reduce risks to human health and the environment by taking hazardous substances out of electronic products, and instead, requiring the use of alternative, safer materials. 

Restricted Substances and Products Under RoHS 1

Manufacturers of EEE products must not exceed the maximum levels laid out by the directive. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

  • Cadmium (Cd)
  • Mercury (Hg)
  • Lead (Pb)
  • Hexavalent Chromium (Cr VI)
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE)

RoHS 1 focused on eight categories of EEE. The categories were taken from the original WEEE directive, a related directive focused on EEE recycling. EEE categories regulated under RoHS 1 include:

  • Category 1: Large household appliances (eg. refrigerators)
  • Category 2: Small household appliances (eg. hair dryers)
  • Category 3: Computing & communications equipment (eg. computers)
  • Category 4: Consumer electronics  (eg. televisions)
  • Category 5: Lighting (eg. lamps)
  • Category 6: Power tools (eg. electric drills)
  • Category 7: Toys, leisure and sports equipment (eg. electronic dolls)
  • Category 10: Automatic dispensers (eg. vending machines)

RoHS 2: Directive 2011/65/EU

In 2011, the original directive was superseded by Directive 2011/65/EU, known as RoHS 2 or RoHS Recast. RoHS 2 created additional categories of EEE subject to regulation and created new compliance requirements for manufacturers and importers.

Why Was RoHS 2 Created?

As scientific research progresses, more manufacturing substances are found to be hazardous. However, new substitutes for restricted substances are also discovered. RoHS 1 takes scientific progress into account by mandating the directive be updated, if necessary, in order to better address and implement new manufacturing methods and materials. 

RoHS 2 was created to ensure that the RoHS directive was up to date with scientific progress made since the passage of RoHS 1. This included expanding the scope of the restricted products and creating new compliance requirements.

RoHS 2 was also created to bring the RoHS directive better in line with other environmental regulations in the EU, such as WEEE and REACH. 

Read more: The Difference Between RoHS, REACH, and WEEE

Restricted Products Under RoHS 2

All categories in RoHS 1 are also regulated under RoHS 2, in addition to two new categories of EEE added by RoHS 2. This includes:

  • Category 8: Medical devices and equipment, such as in-vitro diagnostic devices, known as IVDs. Read more: RoHS Category 8
  • Category 9: Monitoring and control instruments, such as thermostats and smoke detectors. Read more: RoHS Category 9

RoHS 2 also included a list of product types that are exempt from compliance. For example, military equipment and active implantable medical devices are not restricted by RoHS. Exempt products are listed in Article 2 of RoHS 2 (Directive 2011/65/EU)

Read more about RoHS exemptions: What is ‘RoHS Compliant’?

Compliance Requirements under RoHS 2

RoHS 2 created new compliance requirements for manufacturers and importers of EEE. This includes a declaration of conformity and a CE marking.

The declaration of conformity (sometimes known as a certificate of compliance) is the final step in RoHS compliance. This is a legal document that contains information about the product and the measures taken to ensure compliance. The manufacturer signs the declaration of conformity before the product is put on the market to certify that the product is RoHS compliant. 

The CE marking is a visible mark on the product that demonstrates that the manufacturer has taken the proper steps to ensure the product meets RoHS requirements. 

RoHS 3: Directive EU 2015/863

RoHS 3 was passed in 2015 as an amendment to RoHS 2. As RoHS 3 is merely an amendment, companies that are RoHS compliant must comply with all of RoHS 2 as well as updates included in RoHS 3. RoHS 3 added new types of restricted products, as well as four new hazardous substances.

Why Was RoHS 3 Created?

The main purpose of RoHS 3’s creation was to add a new class of restricted chemicals, phthalates. The amendment was passed partly in response to research showing that these chemicals, mainly used as insulation plasticizers, can have serious adverse health and environmental impacts.

Restricted Substances under RoHS 3

In addition to the previously restricted substances, RoHS 3 adds four phthalates. These substances may not be used in EEE at amounts above 1000 ppm:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP) 

Restricted Products under RoHS 3

RoHS 3 greatly expanded the scope of the RoHS directive by introducing a new category of restricted EEE products that serves as a “catch all” category. 

Category 11 includes any EEE not covered in the previous ten categories. For example, this includes EEE products such as two-wheeled electric vehicles, e-cigarettes and vapes, and electrical cables of less than 250 volts.

Read more: RoHS Category 11

Global RoHS Legislation

While RoHS 1, 2, and 3 apply only in the EU and its Member States, rules similar to RoHS have spread to other regions, including India, China, South Korea, Vietnam, Japan, and U.S. states California and New Jersey. It is important for electronic companies to remain aware of shifting hazardous substance legislation in markets around the world.

Why Is RoHS Important?

RoHS has important impacts on the market, and also helps reduce environmental and health risks resulting from hazardous substances.

The Market: Increased Costs

RoHS increases costs for both sellers and buyers of EEE. All three RoHS directives increase costs for sellers due to new manufacturing and testing requirements necessary for compliance. Buyers often face higher prices for their devices as a result of these increased costs of manufacturing.

The Environment: Reduced Pollution

The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

Human Health: Reduced Disease

RoHS aims to minimize health impacts caused by EEE in every stage of a product’s lifecycle, from production to use to disposal.

Several materials restricted by RoHS create occupational hazards during manufacturing and toxic waste upon product disposal, both of which negatively impact human health. 

Additionally, restriction of certain levels of hazardous substances protects human health during the use of products. For example, toys whose paint contains lead, a toxic heavy metal, are not RoHS compliant.

Read more about the impact of RoHS: What is RoHS?

What is RoHS? Understanding Restriction of Hazardous Substances in Electronics

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. The current restrictions are the result of one original directive and two additions known as RoHS 2 and 3.

RoHS 1 – The original directive, Directive 2002/95/EC, was issued in 2002, and included six materials deemed to be hazardous to human health and the environment. 

RoHS 2 – In 2011, the original directive was superseded by Directive 2011/65/EU, known as RoHS 2. RoHS 2 included additional requirements for assessment of electronic products in the EU, as well as additional categories of appliances subject to RoHS.

RoHS 3 – The directive was amended in 2015 when Directive EU 2015/863, or RoHS 3, added 4 new restricted phthalates. RoHS 3 is simply an amendment to its predecessor, and businesses must still comply with all requirements of RoHS 2.

Read more: The Difference Between RoHS 1, 2 and 3

Which Hazardous Substances Are Restricted by RoHS?

The ten hazardous materials included in RoHS can only be used under the maximum levels laid out by the directive. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

  • Cadmium (Cd)
  • Mercury (Hg)
  • Lead (Pb)
  • Hexavalent Chromium (Cr VI)
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE)
  • Bis(2-Ethylhexyl) phthalate (DEHP)
  • Benzyl butyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Which Products Are Restricted?

EEE regulated under RoHS includes a wide variety of products separated into eleven categories, ranging from large household appliances to medical devices. The eleventh category is all-encompassing, as it includes any EEE not covered in the previous ten categories. 

It is important that manufacturers determine whether their product fits the definition of EEE, because all EEE is subject to RoHS compliance requirements. RoHS defines EEE as: “equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields” (Directive 2011/65/EU). 

Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

Who Does RoHS Impact?

RoHS has widespread impact, but directly affects sellers of EEE and buyers of EEE.

1) Sellers of EEE: Manufacturers, Importers, and Distributors

Any manufacturer, importer, or distributor of electronic and electrical equipment (EEE) sold in the EU market must be compliant with RoHS.

It is the manufacturer’s responsibility to ensure their product complies with RoHS. The manufacturing and testing requirements necessary for RoHS compliance may also increase costs for manufacturers. 

Read more: What is ‘RoHS Compliant’?. 

EEE regulated under RoHS includes a wide variety of products separated into eleven categories ranging from large household appliances like dishwashers to medical devices. 

Rules similar to RoHS have spread to other regions, including India, China, South Korea, the UAE, Vietnam, Japan, and the United States, including California and New Jersey. It is important for electronic companies to remain aware of shifting hazardous substance legislation in markets around the world.

2) Buyers of EEE: Consumers

Buyers may be impacted by higher prices of EEE due to RoHS. These increased prices, however, come in exchange for better protection of human health and the environment. 

RoHS often increases the cost of manufacturing EEE, as more testing and regulation is required. These increased manufacturing costs are then reflected in increased prices for consumers.

RoHS requires many EEE manufacturers to use new or different processes in order to remain below the allowable limits for hazardous materials. While these alternative methods and materials do have environmental benefits, they often cost more to implement, especially at first. Increased consumer prices act to offset these costs.

3) Other: The General Public

Ultimately, RoHS affects everyone, as RoHS works to protect the health of our environment and communities. Read more about the environmental impact of RoHS below.

Even the rare person who does not buy or use any electronic equipment may be affected by the negative environmental and health effects of improper disposal of electronic waste, commonly referred to as e-waste. 

Additionally, the restriction of certain levels of hazardous substances protects human health during the use of products. For example, toys whose paint contains lead, a toxic heavy metal, are not RoHS compliant.

Why is RoHS Important?

RoHS’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. While RoHS creates increased costs for sellers and buyers of EEE, the directive also protects the natural environment and human health.

1) The Market

As discussed previously under “Buyers of EEE,” RoHS raises costs for sellers and buyers of EEE alike. 

EEE manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing EEE products and ensuring RoHS compliance may be costly.

Buyers also experience increased prices of electronics in their day to day lives as a result of RoHS.

Of course, these increased prices come hand in hand with safer, more environmentally friendly devices.

2) The Environment

The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

RoHS works in tandem with WEEE, an e-waste directive, to minimize the negative environmental impacts of e-waste. 

Learn more: Waste Electrical and Electronic Equipment (WEEE).

3) Consumer Health

RoHS works to protect consumers of EEE and broader communities from the harmful health effects of hazardous materials. RoHS aims to minimize health impacts caused by EEE in every stage of a product’s lifecycle, from production to use to disposal.

Several materials restricted by RoHS create toxic waste and occupational hazards that negatively impact human health. According to a paper published at Stanford University in 2011, the materials restricted by RoHS can harm not only workers in the production and recycling phases, but also communities located near manufacturing plants (Nimpuno et al. 2011).