Differences between RoHS 1, RoHS 2, and RoHS 3

In July 2020, Nikon Corporation discovered that the content of dibutyl phthalate (DBP) in its Nikon F6 film cameras exceeded the level allowed by the EU RoHS Directive and had to recall about 150 units of the product.

Importers of electrical and electronic products into the EU are generally aware of the RoHS Directive. What some people don't know is that the directive has been amended twice. If Nikon had manufactured the Nikon F6 film camera in 2007, it would not have fallen foul of the RoHS Directive.

This article explains some of the key information you need to know about the EU RoHS Directive, including the differences between RoHS 1 vs. RoHS 2 vs. RoHS 3

What is RoHS?

RoHS is the abbreviation of "Restriction of Hazardous Substances", which is a directive applicable to electrical and electronic equipment sold in the European market. The purpose of this directive is to reduce the impact of electronic products on the environment and health.

Below are the ten restricted substances and their acceptable limits under RoHS.

1. Mercury: < 0.1%

2. Cadmium: < 0.01%

3. Lead: < 0.1%

4. Hexavalent chromium: < 0.1%

5. Polybrominated Diphenyl Ethers: < 0.1%

6. Polybrominated Biphenyls: < 0.1%

7. Bis(2-Ethylhexyl) phthalate (DEHP) < 0.1%

8. Dibutyl phthalate (DPB) < 0.1%

9. Benzyl butyl phthalate (BBP) < 0.1%

10. Diisobutyl phthalate (DIBP) < 0.1%

Since RoHS was adopted in 2002, its scope and the responsibilities of importers of electrical and electronic products have been continually revised. In fact, an electrical product you import may meet the hazardous substance threshold requirements but still not be RoHS compliant.

These scope modifications are reflected in different amendments to RoHS, namely RoHS 2 and RoHS 3. Let’s first discuss the differences between RoHS 1 and RoHS 2.

Differences between RoHS 1 and RoHS 2

RoHS 1, also known as Directive 2002/95/EU, was published in 2002. Its scope was simple: restricting the use of the first six hazardous substances mentioned earlier. It also required all applicable products placed on the EU market after July 1, 2006 to pass RoHS compliance testing.

The original version of the RoHS Directive was later repealed and replaced in July 2011 by RoHS 2 (also known as RoHS 2 Directive Amendment 2011/65/EU). The RoHS 2 legislation simply expanded the scope of products covered by RoHS 1 and imposed new obligations on importers and manufacturers of electrical and electronic equipment.

For example, the RoHS 2 Directive adds medical devices and monitoring instruments to its product categories and sets different compliance deadlines for each category. The RoHS 2 Directive also provides for some exemptions, such as aerospace and military equipment, large fixed installations (LSFI), non-road mobile machinery, and active implantable medical devices.

The RoHS 2 Directive also requires importers or manufacturers of RoHS-classified products to conduct conformity assessments and affix the CE mark to all compliant products.

The introduction of RoHS 3 and its impact

In 2015, RoHS was revised to add four substances to the original list of six substances. These substances include

1. Di (2-ethylhexyl) phthalate (DEHP) < 0.1%

2. Dibutyl phthalate (DPB) < 0.1%

3. Benzyl butyl phthalate (BBP) < 0.1%

4. Diisobutyl phthalate (DIBP) < 0.1%

The amendment, also known as RoHS 3 or Directive 2015/863, came into effect on July 22, 2019. RoHS 3 also added “Category 11” products, which include two-wheeled electric vehicles, straws, e-cigarettes, etc.

Failure to comply with RoHS 3 can result in significant fines and legal consequences. For example, the UK typically imposes fines of up to £5,000 per non-compliant product. Germany is even worse, with fines of up to €30,000 and up to 2 years in prison per product.

In addition to fines, cases of non-compliance with RoHS standards are usually gradually removed from the public eye. Therefore, if you want to enter the European sample, you must ensure that your product meets all RoHS requirements. For relevant solutions, please contact us at Haida.