RoHS documentation

The RoHS Directive impacts on contracting and procurement. The managment of information could become the most challenging issue for complying with the regulations.

The supply-chain and contracting implications of RoHS are complex. Many Producers are not aware of the make-up and construction of their own products; hence the declarations provided by the supply-chain partners are essential. The Producer is legally responsible for compliance under RoHS and has to show due-diligence.

Each supplier of sub-assemblies and components for products falling within the scope of the RoHS Directive should be required to certify that they do not contain any of the following above the allowable concentration levels:

• Lead
• Mercury
• Hexavalent Chromium
• Cadmium
• Polybrominated biphenyl
• Polybrominated diphenyl ether

There are a number of exemptions from RoHS. See the Actions for complying with RoHS - Restrictions and exemptions section of the toolkit.

It is vital that definitions are fully understood.

Homogenous material" is taken to mean a material (of uniform composition throughout) that cannot be mechanically disjointed into different materials. Therefore, a PCB is not homogenous material, but the solder on it would be. A semiconductor package contains many homogenous materials including the plastic moulding material, the tin-electroplating coatings on the lead frame, the lead frame alloy and the gold-bonding wires.

Producers must demonstrate compliance with the regulations by providing the enforcement authority with satisfactory evidence of such compliance in the form of technical documentation. The UK is taking a self-declaration approach as the basis of compliance. The enforcement authority will carry out market surveillance to detect non-compliant products and may conduct tests for this purpose.

Producers will need to demonstrate compliance by collecting supplier declarations and retaining them for four years after the particular product was placed upon the market. A sample materials declaration form is provided here.

This sample focuses solely on RoHS proscribed materials; however, it is possible to build in other hazardous materials.

A further option is for producers to undertake their own analysis. Whilst most suppliers will accurately complete material declarations it is possible that they may not. Additionally, there are higher-risk components that producers may wish to test in any case. Testing may also be appropriate where material declarations are not available. See this flowchart for guidance on testing. There are a range of self-test kits on the market and numerous laboratory facilities that can undertake testing on a commercial basis. Further details are available from eco3 at info@eco3.co.uk.