EU rohs2.0 exemption clause update considerations
Date:2022-07-04 17:12:39Views:728
RoHS directive 2011/65/eu (also known as RoHS 2.0 directive) is a re update of the previous EU ROHS directive 2002/95/ EC. The new directive came into force on 21 July 2011 and is consistent with the new legislative framework. It stipulates restrictions on the use of hazardous substances in electrical and electronic equipment (EEE). Such harmful substances are Mercury, lead, cadmium, polybrominated biphenyls, dibutyl phthalate, diisobutyl phthalate, hexavalent chromium, polybrominated diphenyl ethers, etc.
RoHS exemption means that some specific products can be put on the market even if their materials cannot meet the RoHS limit requirements. The reason why there is an exemption list is that the existing technology cannot meet the requirements or no alternative materials have been found.
After the expiration of the exemption clause, the materials using the exemption clause must meet the RoHS limit requirements. At this time, the corresponding hazardous substances should be limited in order to meet ROHS requirements, or to find alternative materials.
Precautions for updating rohs2.0 certification exemption conditions. The European Commission issued amendment directive (EU) 2021/884 in its official gazette (OJ), which amended article 42 of Annex IV of the RoHS Directive (2011/65/eu) and extended the validity of the exemption for mercury in electrical rotary connectors used in intravascular ultrasound imaging systems with high operating frequencies (> 50MHz).
All Member States need to adopt and issue relevant laws, regulations or administrative provisions before June 30, 2022, and implement them from July 1, 2022.
Note: the rohs2.0 directive exemption list is listed in Annexes III and IV of 2011/65/eu respectively, of which Annex IV is an exemption clause specifically for the application of medical and monitoring equipment, and Annex III is an exemption clause for the application of all electronic and electrical equipment.
In the authorization directive (EU) 2015/574 (2), the European Commission approved the exemption for the use of mercury in intravascular ultrasound imaging systems. According to the rohs2.0 directive on the exemption period of medical equipment and monitoring and control equipment, the exemption expired on June 30, 2019, and the European Commission received an application for the renewal of the exemption as early as October 6, 2017, before the expiration of the exemption period. In order to adapt to scientific and technological progress, on March 8 this year, the European Commission officially revised the validity period of the exemption and published it in the Official Gazette (OJ) on June 2. The effective date is the 20th day after the publication.
Rohs2.0 Annex IV exemption rules
Rules for the maximum exemption period -2011/65/eu Article 5 (2)
For the exemptions listed in Annex III on July 21, 2011, the maximum exemption period for products of categories 1-7, 10 and 11 in Annex I is 5 years, and the maximum exemption period for products of categories 8 and 9 is 7 years, unless a shorter period is specifically indicated.
For the exemptions listed in Annex IV on July 21, 2011, the maximum exemption period is 7 years, unless a shorter period is specifically indicated.
Exemption extension application rules -2011/65/eu Article 5 (5)
The application for renewal should be submitted 18 months before the expiration of the exemption.
The existing exemptions remain valid until the updated decision is issued.
Exemption withdrawal transition period rules -2011/65/eu Article 5 (6)
When an exemption application is rejected or an exemption is revoked, the validity of the exemption expires within 12 months from the date of decision at the earliest and 18 months from the date of decision at the latest.
The update of RoHS exemption clauses has a great impact on electronic and electrical related industries, especially whether some exemption clauses frequently used by enterprises will be extended, which may directly affect the production process and business activities of enterprises. In order to ensure the compliance of entering the EU market, CREC Lianke suggests that relevant enterprises should always pay attention to the exemption of RoHS directive, and replace the exemption materials that are about to expire or have expired in advance, so as to avoid compliance problems caused by the expiration of exemption for products exported to Europe.
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