Apply ROHS-Directive correctly: What requirements result from the CE marking for my product?

The avoidance of substances affects electrical and electronic equipment. Compliance with the requirements is intended to protect persons who use or deal with the corresponding products. In addition, a contribution to environmental protection is made. Pollutant-free components can, for example, be recycled and thus become starting materials for new products.

The content of EU-Directive 2011/65/EU consists of the legal text and the annexes, in which definitions, limits and exceptions can be read. At the national level, the RoHS Directive is represented in Germany by the Electrical and Electronic Equipment Substances Regulation (ElektroStoffV). This lists eleven categories of electrical and electronic equipment, which fall within the scope of the current RoHS Directive. The categories include, for example, household appliances, IT technology, consumer electronics, lighting technology, electrically operated tools as well as sports and leisure equipment, medical technology or monitoring electronics. The eleventh category - in contrast to the previous regulation - now stands for all other electrical and electronic devices that are not covered in the other categories. The previously valid restriction on certain products is thus eliminated.

• mercury (Hg)
• cadmium (Cd)
• lead (Pb)
• chrome (Cr VI)
• polybrominated biphenyls and diphenyl ethers

These substances may contain a maximum of 0.1% in the materials used. Cadmium has a lower maximum concentration of 0.01 %, although there are exceptions in the Annex to the Directive. In addition to the substances mentioned, since 2019 , further restrictions apply to the use of certain types of plasticizers for plastic components.

This includes on the one hand the conformity assessment and on the other hand the CE marking if the provisions are met. While RoHS 1 did not yet require the CE mark, it is now mandatory.

All electrical and electronic equipment that can be delivered to an end consumer and fulfil an independent function must comply with the guidelines. In principle, individual components are not affected by the requirement for CE marking, but it will be difficult to prove and explain the RoHS conformity of a finished product if components are contained in which the limit values are exceeded. The product may not subsequently be sold on the EU market.

On the other hand, it creates trust with the customer. Consumers or intermediaries can rely on the CE mark to ensure that the European standards regarding quality and safety of the products are met. As a manufacturer, dealer or importer, you gain a competitive advantage. If you label your product with the CE mark, you must declare this marking by completing the EU declaration of conformity.

• Include complete technical documentation
• Submit the result of the material tests

Proof based on technical documentation

The verification by means of documentation is based on the DIN EN IEC 63000. Manufacturers of electrical appliances and electronic components can read about the technical details that need to be listed and traced. Depending on the supplier, however, the manufacturer can decide for himself whether a simple declaration of conformity is sufficient for him or whether he needs a list of all substances used. It is also possible to request random test results that prove compliance with the limit values. The verification documents must be clearly assigned to the components in the RoHS product.

Proof by means of material tests

The DIN EN 62321 is decisive for the verification of material tests. This provides methods that can be used to test the material components. Every homogeneous material in the RoHS product must be subjected to an analysis. Before a complete chemical analysis is carried out, a screening can first be set up to determine the individual substances qualitatively before relevant components are subjected to qualitative analysis. For example, fluorescence analyses are suitable as screening tests. The detection of a substance listed in the RoHS directive must then be followed by more precise analyses.

Since it is often not easy for manufacturers of RoHS products who need a CE mark for the European market to submit an in-depth material test for each component of an electrical or electronic device, many choose the path via the technical documentation. The CE marking is the sole duty of the manufacturer. However, external bodies can be enabled for determination of the relevant guidelines and verification of conformity to speed up and facilitate the labeling process.