Label:RoHS, Membrane Switch, Mobile Devices, LoT
Dec 25, 202025860
In several articles published in the past, one concept is often mentioned: RoHS. So what does RoHS mean, and what is its function? Today JRPanel would like to introduce RoHS in membrane switch production to everyone.
RoHS also applies to the metal industry for any application of metal plating, anodizing, chromating or other finishes on EEE components, heatsinks, or connectors.
RoHS 2 is also a CE-marking directive, with RoHS compliance now being required for CE marking of products. As such, all manufacturers of electrical/electronic products must comply with RoHS 2 before the CE mark can be applied on their products. The original green RoHS label with the checkmark is no longer required or used as the CE mark now includes RoHS compliance.
RoHS 1 required that any product in scope should not contain any of the 6 restricted substances and that the company (manufacturer, importer, or distributor) placing the product on the EU market should maintain records to show compliance. RoHS 2 requires additional compliance recordkeeping from everyone in the supply chain. Additional compliance recordkeeping (which must be kept for 10 years) can include a conformity assessment, CE marking, maintenance of compliance throughout production, and self reporting of non-compliance.
The proposed changes to the original RoHS Directive in RoHS2 (2011/65/EU) are relatively minor. No additional substances have been added to the six currently restricted. Inclusion of RoHS categories 8 (medical devices) and 9 (control and monitoring instruments) products in RoHS has been added as well. RoHS 2 took effect January 2, 2013.
RoHS 3, or Directive 2015/863, adds four additional restricted substances (phthalates) to the orginal list of six, as cited under REACH legislation. It also adds Category 11 products. RoHS3 takes effect 22 Jul 2019.
RoHS 5/6 refers to compliance for 5 out of the 6 restricted substances (no compliance for lead (Pb)). Lead in very specific applications for Categories 8 and 9 is also exempted under Annex III for a few more years.
REACH is a general regulation and stands for Registration, Evaluation, Authorization, Restriction of Chemicals, and addresses the production and use of chemical substances and their potential impact on human health and the environment. REACH is monitored by the ECHA and deals with 197 Substances of Very High Concern (SVHC) currently. While RoHS restricts substances present in electrical/electronic equipment (wiring, components, circuit boards, displays, sub-assemblies, cabling), REACH controls all chemicals that might be used to manufacture the product, including enclosures, brackets, coatings, paints, solvents, and chemicals used during manufacture.
Of note is that all the RoHS restricted substances are also on the REACH restricted list. Substances on the list have been identified as being carcinogenic, mutagenic, reprotoxic, bio-accumulative and toxic, or as endocrine disruptors.
Put another way, RoHS regulates the hazardous substances used in the manufacture of electrical and electronic equipment (EEE), while WEEE regulates the disposal of this same equipment.
The EU End of Life Vehicle (ELV) Directive relates to automobiles, while the RoHS directive covers a broad array of electrical and electronic products across many industries. The ELV directive applies to electrical cables, wiring, and associated components used in transportation vehicles. It went into effect July 1, 2003, and limits the use of lead, mercury, cadmium and hexavalent chromium (also restricted under RoHS).
In general, XLP (cross-linked polyethylene) insulated automotive-use wire such as SAE (Society of Automotive Engineers) types SXL, GXL and TXL comply with this directive. However, PVC-insulated automotive wire types such as GPT, TWP, SGT and SGX may contain lead and as such may not be compliant unless specifically requested in purchase specifications.
Mainly in the form of a Full Materials Declarations (FMD). Often a compliance declaration will list RoHS, Reach, and Conflict Minerals (T3&G) together. The conflict minerals are tantalum, tungsten, tin, and gold - referred to as 3TG minerals if they originate from the Democratic Republic of the Congo (DRC). Also mined in the DRC is cobalt, which is used in the manufacture of batteries for electric vehicles. Cobalt mining is set to increase dramatically to meet this demand. Under the Dodd-Frank Act, all publically-traded companies must report to the SEC the origin of conflict minerals.
No. All batteries, regardless of type or application, are covered under the EU Battery Directive (2006/66/EC and Amendment 2013/56/EU). The Battery Directive restricts the use of lead to 0.004%, mercury to 0.0005%, and cadmium to 0.002% (medical devices/equipment and alarm/emergency systems are excluded for cadmium).
NOTE: Under China RoHS, batteries ARE included/covered. This has particular implications for the electric vehicles market given the size of the battery pack.
Only if the cartridge contains electrical parts that require electric currents or electromagnetic fields to function. Printer cartridges that merely consist of ink and a container, without electrical parts, do not apply.
The healthcare industry is regulated by HIPAA, with its own compliance requirements. If you manufacture EEP for the healthcare industry, you will also need to be HIPAA certified under the Security Rule. This just doesn't apply to medical devices, but also to office equipment including scanners, printers, hard drives, hardware security modules (HSM), smart-card readers, network devices, paper shredders, media degaussers, and hard drive "Destroyers" that bend, break, and mangle hard drives that are decommissioned.
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