On July 1st 2011, an updated version of the Restriction of Hazardous Substances (RoHS) Directive was published in the Official Journal of the European Union. EU member states have 18 months to enact the new directive into local law. DIRECTIVE 2011/65/EU termed the “RoHS Recast” has a number of changes that could affect manufacturing in the United States. The most impactful change is that the updated version of RoHS now includes electrical and electronic equipment (EEE) that was previously outside the scope of the directive. The RoHS Directive will now include Medical Devices and Monitoring and Control Instruments.
Manufacturers of these types of EEE will have 3 years to come into compliance with the changes to the directive. The RoHS recast will also require manufacturers to draw up a declaration of conformity and affix the CE mark to their products in order to demonstrate compliance. There has also been a number of changes regarding exemptions. There is now a process for applying for an exemption to the directive. All exemptions will expire and the manufacturer will need to reapply for the exemptions 18 months prior to expiration.
The recast did not add additional substances to the banned list, although the recast requires a review of the substances within three years. The current banned substances are; Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated Biphenyls, and Polybrominated Diphenyl Ethers. It is important for companies to start thinking about how these changes are going affect the importation of EEE into the EU. Companies will also need to be able to demonstrate that they are in compliance with the directive at the member state level. If you have any questions about the RoHS Recast please contact Travis Wheeler at 508.970.0033 ext. 115 or firstname.lastname@example.org.