6 Replies Latest reply on Aug 14, 2012 9:07 AM by mike

    ROHS II Compliance

    pcorbin

      I've been looking around and can't quite get an answer to this one:

       

      Does ROHS I (2002/95/EC) documentation need to be updated to reflect ROHS II (2011/65/EU) compliance?

       

      Just curious if anyone knows if we have to update all drawings to relect ROHS II compliance or does ROHS I compliance

      automatically roll over to ROHS II compliance in the PCB FAB/PCB ASSY world?

       

      Thanks,

      Patrick

        • 1. Re: ROHS II Compliance
          DenisL

          Oh, good question.

          I confess, I am not intimately familiar with the content of the ROHS directives, however it is my understanding that with respect to "Lead-Free" compliance the two are no different.

          So, my answer would be, No, you do not need to update any documentation.

          Don't take this as gospel - it is just my understanding. I think a thorough examination of the EU's would be in order or at least a consultation with someone who knows the directives intimately.

          -D

          • 2. Re: ROHS II Compliance
            pcorbin

            Yes. You are correct. The 6 banned substances in ROHS 2 are the same list as ROHS I.

            I'm just afraid there is a bureaucratic requirement in the documentation process.

            Hopefully not. I will post anything I find out.

            Thanks.

            • 3. Re: ROHS II Compliance
              mike

              Well, the answer depends on what you mean by "RoHS 1" documentation. If it's just a bunch of certificates of compliance then yes, you'll have to do some work.

               

              RoHS is now a CE Mark directive; it requires you to sign a Declaration of Conformity (article 13) and maintain technical documentation backing up the DoC. EN 50581, available now in final draft form (it has been approved and will be available in the next month or so), defines what is required. Basically, if you have reason to trust the data provided by your suppliers, you can take their word for it; if you can't, you need to get more information, control them better, and maybe even get test data to prove compliance. This all needs to be documented in your internal procedures.

               

              So it's not just a matter of updating drawings; it's a matter of updating and rolling out changes to existing business processes, working with your compliance people to get them ready and willing to sign the DoC (which is the same piece of paper they already sign for safety and EMC; RoHS just gets added to it...or you can have a separate DoC), and working with your suppliers to make sure they're providing you the data you need and controlling their materials and processes.

               

              There's an FAQ draft out for RoHS 2 now; you should read it:

               

              http://ec.europa.eu/environment/waste/rohs_eee/events_rohs3_en.htm

               

              Michael Kirschner
              President
              Design Chain Associates, LLC
              415.904.8330

              • 4. Re: ROHS II Compliance
                mike

                Sorry to be the bearer of bad news but yes "there is a bureaucratic requirement in the documentation process" and I've tried to generally describe it below.

                 

                Michael Kirschner
                President
                Design Chain Associates, LLC
                415.904.8330

                • 5. Re: ROHS II Compliance
                  pcorbin

                  Hi Mike,

                  THanks for the great response. I know that ROHS will now be a CE mark directive and we have people working on all of that.

                   

                  I was just curious (in my little world) - since "ROHS I" is officially going to be repealed 02 JANUARY 2013, do pbc fabrication drawings and

                  pcb assembly drawings for products going to EU member states need to state compliance with the new directive specifically (2011/65/EU)

                  ,

                  or does compliance with 2002/95/EC roll into compliance without changing the actual documentation? It seems that the actual banned substance list

                  relating to pcb fab and assembly does not change in scope or quantities.That is a ton of drawings to touch, if so.

                   

                  Thanks again for your comprehensive response!

                  Patrick

                  • 6. Re: ROHS II Compliance
                    mike

                    Hi Patrick,

                     

                    Glad you found the info useful. There's no need to change drawings for PCBs or any other component to indicate compliance to this specific regulation (or with the previous version 2002/95/EC) - the directive does not require that. The only compliance indication required (or allowed!) is the CE Mark on the finished good (there are some minor exceptions that are addressed in the FAQ I mentioned above).

                     

                    Cheers,

                    Mike