Guide to becoming RoHS compliant

The following guide is intended as a tool for assessing RoHS compliance for the products you manufacture.

1. Determine if your products need to comply with the RoHS directive

Your company only needs to comply with the RoHS directive if you produce, import or export electrical and electronic equipment on a professional basis that meets all of the following criteria:

• It is introduced into a Member State of the European Union.
• It is dependent on electric or electromagnetic fields in order to work properly. This also includes equipment for the generation, transfer and measurement of such currents and fields.
• It is for use with a voltage rating not exceeding 1,000 volts for alternating current and 1,500 volts for direct current.

2. Register your company with the proper authority

The directives indicate that if you are a producer in the European Union, you must register your company with the environmental agency that has been designated by your Member State. However, not all Member States are currently set up to take registration and each is developing its own system for implementing the WEEE and RoHS directives. Some states require registration by exporters as well.

Implementation progress by member state
(While this site is primarily set up for US exporters, it has a great deal of useful RoHS/WEEE implementation information by EU member state including registration, enforcement, contacts and links.

3. Acquire RoHS compliance verification from your suppliers

One of the most important steps to compliance is to ensure that all of the materials and components used in your product are compliant. In order to validate compliance, request that your suppliers provide a statement that the products they provide are free of the six restricted substances (Lead, cadmium, mercury, hexavalent chromium, PBB or PBDE flame retardants) or within accepted tolerances.

4. Test suspect components

If a supplier is not able to provide a statement of compliance you must either have the product analyzed or find a vendor that can provide verification of compliance. If for any reason you are suspect of a product’s compliance, you should have it analyzed or use an alternative product.

5. Maintain RoHS compliance records

Keep all of your supplier compliance statements on file as well as any test analysis data you have run. It will be important to have this data in the event that your customer requests verification or if a breach of the RoHS directive is suspected. It is also a good practice to keep strict control of your entire inventory, separating nonconforming and conforming product and thoroughly tracking all nonconforming material throughout your facility.

6. Prepare a statement of RoHS compliance

It is likely that your customer will ask you to provide a statement of RoHS compliance. It is a good practice to have this prepared ahead of time deferring any concerns your customer may have about your RoHS awareness and status. This statement should indicate compliance for each homogenous material used in the manufacture of your product and that they may be used to manufacture electronic equipment regulated by the RoHS directive.