RoHS

The Restriction of Hazardous Substances (RoHS) Directive (2002/95/EC, “RoHS 1”) was adopted in February 2003 by the European Union and took effect on July 1, 2006. This directive and its subsequent RoHS-Recast, RoHS 2011/65/EU (RoHS 2) imposed threshold limits (with exemptions) for six hazardous materials commonly used in Electronic and Electrical Equipment (“EEE”):

• Lead (Pb) – 0.1% of homogeneous material
• Mercury (Hg) – 0.1% of homogeneous material
• Cadmium (Cd) – 0.01% of homogeneous material
• Hexavalent Chromium (Cr+6) – 0.1% of homogeneous material
• Polybrominated Biphenyls (PBBs) – 0.1% of homogeneous material
• Polybrominated Diphenyl Ethers (PBDEs) – 0.1% of homogeneous material

On March 31, 2015, the EU Commission published Directive (EU) 2015/863, adding four phthalates to Annex II of the RoHS directive (RoHS 3), bringing the current number of restricted substances to ten. As of July 22, 2019, phthalates DEHP, BBP, DBP, and DiBP are restricted under RoHS for EEE:

• Bis (2-ethylhexyl) phthalate (DEHP) – 0.1% of homogeneous material
• Benzyl butyl phthalate (BBP) – 0.1% of homogeneous material
• Dibutyl phthalate (DBP) – 0.1% of homogeneous material
• Diisobutyl phthalate (DiBP) – 0.1% of homogeneous material

Why Phthalates?

DEHP, BBP, DBP, and Diisobutyl phthalate (DiBP) have been identified as toxic for the environment and human health and reproduction. Primarily used to soften and provide flexibility and elasticity to plastics, these phthalates are known to have been used in toys, food packaging, and PVC. They also might be found in medical devices, or cable and wire sheathing and other components of electrical and electronic products.

For more information about the intrinsic properties of DEHP, BBP, DBP, DiBP, or the other restricted substances, visit the European Chemicals Agency (ECHA) website, Candidate List of Substances of very high concern for Authorization (published in accordance with Article 59[10] of the REACH Regulation).

Supplier Declarations

When compliance with RoHS is demonstrated for EEE, manufacturers create a Declaration of Conformity and affix the CE mark to the finished product. Product technical documentation and the EU DoC must be retained for ten (10) years after the EEE item is last on the market. UNICOM Engineering relies on our suppliers to provide the documentation and information necessary to demonstrate compliance.

Suppliers agree to report product compliance to UNICOM Engineering in one of the formats below and to provide future updates promptly when requested by UNICOM Engineering.

Reporting Formats (Select One)

1. Supplier’s Own Declaration of Compliance. The document must include:

   • The manufacturer’s name and address
   • Reference to full EU RoHS standard including
   • Amendments An assertion that the product is either: “Compliant (without Exemption),” “Compliant with Exemption,” or “Does Not Comply.”
   • A list of every exemption taken if Compliant with Exemption Date signed
   • A legally binding signature on behalf of the organization
2. CE Declaration of Conformity (DoC) Provided by a manufacturer or his representative to declare how a product complies with the health and safety requirements of the European Union (EU) RoHS legislation.
3. MDDS – Material Declaration Data Sheet Material disclosure that identifies chemical constituency of the product by Substance Name, CAS, and % by mass.
4. UNICOM Engineering RoHS Data Collection Form (DCF) - download and complete this template for a single product, for a list of products, or universally for all products provided by a single manufacturer.

Email declarations to regulatory.compliance@unicomengineering.com.

Obtain a Declaration of RoHS Compliance for Your Product Platform

RoHS compliance declarations are available for our Customer products upon request. To request SKU level RoHS declarations, contact your Account Manager.

Additional RoHS Resources

For additional information about the RoHS Directive and the European Commission, visit https://ec.europa.eu/environment/waste/rohs_eee/index_en.htm.

Also, see our: Supplier Product On-Boarding Checklist section.

Questions?

Contact the UNICOM Engineering Environmental Compliance Specialist at 972-633-3430.