SGS Can Help to Ensure Compliance with Upcoming RoHS II

The European Parliament completed its first reading of the draft of RoHS II in November 2010. Items that were previously in question have now been clarified and RoHS II is on its way to becoming a CE Mark directive. No new restricted substances have been introduced and the publication of the directive is expected in the first quarter of this year.

Taunusstein, Germany, March 31, 2011 --( Everything EEE

The new RoHS directive is expected to cover all but a very few instances of Electrical and Electronic Equipment (EEE). Annex I of the directive introduces a new, eleventh product category – "other electrical and electronic equipment not covered by any of the categories above (categories 1–10)." Thus electrical and electronic equipment types that were not covered before will be covered by RoHS II, including formerly grey zone items such as electric toys.

RoHS II Exemptions

In its current draft form, RoHS II exempts ten types of electrical and electronic equipment: equipment pertaining to the security and protection of Member States, including arms, munitions and war materials intended specifically for military use; equipment designed to be sent into space; equipment designed for installation as part of equipment that is exempt from the directive, specifically if the equipment is only for use in exempt equipment and can only be replaced by equipment of the exact same design; large scale stationary industrial tools; large scale fixed installations; transport means for persons or goods, excluding electric two wheel vehicles that are not type approved; mobile machinery unintended for road use that is available exclusively for professional use; active implantable medical devices; photovoltaic panels intended for use in a system that is designed, assembled and installed by professionals for permanent use at a specific location for the production of energy from solar light for public, commercial, industrial or residential use; equipment designed solely for the purposes of research and development and for utilization on a strictly business-to-business basis.

Nothing New Under RoHS II

RoHS II introduces no new restricted substances. What it does, however, is to introduce a simplified mechanism for the review and amendment of the restricted substances list in the future. Substances highlighted for future review include: hexabromocyclododecane (HBCDD), phthalates (DEHP, BBP, DBP) and nanomaterials.

To investigate the list and limits of all restricted substances, review is recommended of the annexes of the new directive ( ).

RoHS II will be a CE Mark Directive

RoHS II is set to become a CE Mark directive, which means that CE marking will be affixed to all finished products, as per Module A of Annex II of 768/2008/CE. With CE marking ( ), the responsibility is now to be shared between manufacturers and importers and distributors. CE declaration remains the manufacturer’s obligation, while the release of compliant products onto the EU market becomes the responsibility of importers and distributors.

Formal adoption of RoHS II by the European Council is expected in the first quarter of 2011, with the directive becoming mandatory legislation 20 days after publication in the Official Journal of the European Union. At that point, member states have eighteen months to enforce the directive into law. Until that happens, the current RoHS directive 2002/95/EC remains in force. It needs to be considered though that some EU member states may have national laws in place which will automatically enforce updates of directive 2002/95/EC.

SGS can help ensure compliance with RoHS II and its global restricted substances service ( enables full support of products with REACH, SHVC and other relevant international, national and regional regulations and legislation. SGS can also provide compliance assessment, which is essential for the preparation of the CE declaration of conformity.

For further details please contact:

SGS Consumer Testing Services
Dr. Udo Krischke
Global Technical Manager RSTS
Im Maisel 14, 65232 Taunusstein, Germany

t: +49 6128 744 235

SGS is the world’s leading inspection, verification, testing and Certification Company. SGS is recognised as the global benchmark for quality and integrity. With 64'000 employees, SGS operates a network of over 1,250 offices and laboratories around the world.

SGS Consumer Testing Services
Dr. Udo Krischke
+49 6128 744 235